United States 

Department of 

Agriculture 

Forest Service 

Petersburg Ranger District 

Tongass 

National 

Forest 

R10-MB-633a 

October 2009 

Central 

Kupreanof 

Timber Harvest

Final Environmental Impact 

Statement 

Volume A 
Abbreviations and Common 

Acronyms 

ANILCA Alaska National Interest 

Lands Conservation Act 

ASQ Allowable Sale Quantity 

BMPs Best Management 

Practices 

CCF Hundred Cubic Feet 

CEQ Council on Environmental 

Quality 

DBH Diameter at Breast Height 

DEIS Draft Environmental 

Impact Statement 

EFH Essential Fish Habitat 

FEIS Final Environmental 

Impact Statement 

Forest Plan Tongass Land and 

Resource Management 

Plan 2008 

GIS Geographic Information 

System 

HSI Habitat Suitability Index 

IDT Interdisciplinary Team 

LTF Log Transfer Facility 

LUD Land Use Designation 

MBF Thousand Board Feet 

MIS Management Indicator 

Species 

MMBF Million Board Feet 

MMI Mass Movement Index 

NEAT_R NEPA Economic 

Analysis Tool 

NEPA National Environmental 

Policy Act 

NFMA National Forest 

Management Act 

NFS National Forest System 

POG Productive Old Growth 

RMA Riparian Management 

Area 

RMO Road Management 

Objective 

ROS Recreation Opportunity 

Spectrum 

SHPO State Historic 

Preservation Office 

VCU Value Comparison Unit 

WAA Wildlife Analysis Area 

 

 
Central Kupreanof Timber 

Harvest 

Final Environmental Impact 

Statement 

Tongass National Forest 

USDA Forest Service 

Alaska Region 

Lead Agency: USDA Forest Service 

Tongass National Forest 

648 Mission Street 

Ketchikan, AK 99901 

Responsible Official: Forrest Cole 

Forest Supervisor 

Tongass National Forest 

For Further 

Information Contact: Tiffany Benna/Planning Team Leader 

Petersburg Ranger District 

P.O. Box 1328 

Petersburg, Alaska 

(907) 772-3871 

________________________________________________________ 

Abstract: 

The USDA Forest Service proposes to harvest up to 70.2 million board feet (MMBF) of timber in the 

Central Kupreanof project area on Kupreanof Island, Petersburg Ranger District, Tongass National Forest. 

Timber volume would be offered through the Tongass timber sale program. The actions analyzed in this 

Final Environmental Impact Statement (FEIS) are designed to implement direction contained in the 2008 

Tongass Land and Resource Management Plan (Forest Plan) and the Tongass Timber Reform Act (TTRA). 

The FEIS describes four alternatives, which provide different combinations of resource outputs and spatial 

locations of harvest units. The action alternatives would make between 28.1 and 70.2 MMBF of timber 

available for harvest within the project area. The significant issues addressed by the alternatives include: 

Timber Economics, Roadless and Road Management/Access. Also analyzed in this document are Projects 

Common to All Action Alternatives. They are analyzed as common to all action alternatives and include 

such possible activities as; culvert replacement, second growth thinning, and road, cabin and trail 

maintenance. These projects will provide potential stewardship contracting opportunities in the local area. 
Central Kupreanof Timber Harvest FEIS Contents i

Summary 

Introduction 

The Central Kupreanof Timber Harvest project area is located on the 

western portion of Kupreanof Island, on the Petersburg Ranger District 

of the Tongass National Forest, Alaska Region (Region 10) of the 

Forest Service, an agency of the U.S. Department of Agriculture (see 

Vicinity Map, Figure 1-1). 

This chapter discusses the background of the Central Kupreanof 

Timber Harvest. The actions analyzed in this FEIS are designed to 

implement the direction contained in the 2008 Tongass Land and 

Resource Management Plan (Forest Plan). It includes the steps taken 

to identify environmental issues and public concerns related to 

implementation of the project. 

Purpose and Need 

The purpose and need for the proposed action responds to the goals 

and objectives identified by the Tongass Land and Resource 

Management Plan, and helps move the area toward the desired 

conditions as described in the Forest Plan. The Forest Supervisor is 

the Responsible Official for this action and will decide whether or not 

to harvest timber from the Central Kupreanof Timber Harvest area, 

and if so, how this timber will be harvested. The decision will be 

based on the information that is disclosed in the environmental impact 

statement. The Responsible Official will consider comments, 

responses, the disclosure of environmental consequences, and 

applicable laws, regulations, and policies in making the decision and 

will state that rationale in the Record of Decision. 

Proposed Action (Alternative 2) 

The proposed action, as published in the Federal Register, provides for 

multiple timber sale opportunities and would result in the production 

of approximately 40 million board feet (MMBF) of timber from 

approximately 2,025 acres of forested land. Up to 11.1 miles of 
Summary 

ii  Summary Central Kupreanof Timber Harvest FEIS

National Forest System (NFS) roads and 7.0 miles of temporary roads 

may be necessary for timber harvest. Through two field seasons and 

the interdisciplinary process, the proposed action has been adjusted to 

respond to on the ground conditions and resource concerns while 

remaining within the scope of the original proposed action. The 

Proposed Action for this project still provides for multiple timber sale 

opportunities and will result in the production of approximately 46.8 

MMBF (about 39.4 MMBF of sawlog and 7.4 MMBF of utility) from 

2,506 acres of forested land. Up to 7.3 miles of new NFS and up to 3.9 

miles of temporary road would be constructed for timber harvest. A 

range of alternatives, responsive to significant issues, has been 

developed and includes a no action alternative. 

The interdisciplinary team has identified several projects within the 

project area that could serve as stewardship opportunities along side 

the timber harvest proposal. These projects consist of: 

 Recreation- maintain hiking trails in the area and perform 

annual cabin maintenance for the cabin located in Big John 

Bay. 

 Silviculture and Wildlife- precommercially thin 325 acres of 

second growth. 

 Transportation- perform maintenance on 94 miles of open road. 

Maintenance would include blading, brushing, and clearing 

culverts. 

 Fisheries/Hydrology- any fisheries or hydrology projects are 

tied to the analysis and decisions to be made with the PRD 

ATM EA. 

 Invasive Plants- handpulling a small population of spotted 

knapweed, with the possible inclusion of other weed 

populations if they were discovered. 

 Microsales- timber sales consisting of dead or down timber 

which has been proposed by a prospective purchaser, and the 

District Ranger agrees to offer for bidding using an informal 

advertisement and short bid form. The maximum size of a 

Microsale would be 50 MBF. 

These projects will be analyzed as common to all action alternatives. 

A complete description of the projects can be found in Chapter 2 

(pages 7 and 8), and map of these projects is also provided in Chapter 

2 (Figure 2-5). 
Summary 

Central Kupreanof Timber Harvest FEIS Summary iii

The Purpose of the Central Kupreanof Timber 

Harvest Project is to: 

 Manage the timber resource for production of sawtimber and 

other wood products from suitable lands made available for 

timber harvest on an even-flow, long-term sustained yield 

basis, and in an economically efficient manner. 

 Seek to provide a timber supply sufficient to meet the annual 

market demand for Tongass National Forest timber and the 

market demand for the planning cycle. 

 Provide for a diversity of opportunities for resource uses that 

contribute to the local and regional economies of Southeast 

Alaska. 

Appendix A of this document provides information on how this 

project relates to the overall Tongass National Forest timber sale 

program, and why the project is being scheduled at this time. 

Decisions to be Made 

Based on the environmental analysis in this EIS, the Forest Supervisor 

will decide whether and how to implement activities within the Central 

Kupreanof Project Area in accordance with Forest Plan goals, 

objectives, and desired conditions. The decision may include the 

following: 

 The location, amount, and method of timber harvest, road 

construction, marine access facilities, and silvicultural 

practices. 

 Road management objectives for constructed, reconstructed 

and existing roads associated with the timber sale. 

 Any necessary project-specific mitigation design, mitigation 

measures and monitoring requirements. 

 Whether to implement the Projects Common to all Action 

Alternatives, including a Microsale program along existing 

NFS Roads 6030, 6040, 6314, 6314S, 6326, 6328, 6334, 6336, 

6339, and 6367. 

 A determination of whether there may be a possibility of a 

significant change in subsistence uses and access. 
Summary 

iv  Summary Central Kupreanof Timber Harvest FEIS

Significant Issues 

Significant issues are used to formulate and design alternatives, 

prescribe mitigation measures, and analyze significant effects. 

Significant issues for the Central Kupreanof Timber Harvest have been 

identified through public and internal scoping. Similar issues are 

combined where appropriate. Issues can arise from a variety of 

sources, including: 

 Issues, concerns, and opportunities identified in the Forest 

Plan, 

 Issues identified for similar projects (past actions) 

 Current internal issues, 

 Changes in public uses, attitudes, values, or perceptions, 

 Issues raised by the public during scoping, and 

 Comments from other government agencies. 

Measures of the significance of an issue are based on the extent of the 

geographic distribution, the duration of the related effects, or the 

intensity of interest or resource conflict surrounding the issue. For an 

issue to be considered significant at the project level, it must be 

relevant to the specific project so that it can be appropriately addressed 

at the project level. Some issues have already been resolved through 

national level direction or analyzed at the Forest Plan level. 

Once a significant issue is identified, measures are developed to 

analyze how each alternative responds to the issue. Measures are 

chosen that are quantitative (where possible), predictable, responsive 

to the issue, and linked to cause and effect relationships. These 

measures describe how the alternative affects the resource(s) at the 

heart of the issue. Monitoring and mitigation of the anticipated 

environmental effects of the project are also designed to be responsive 

to significant issues. 

These issues are addressed through the proposed action and the 

alternatives. 

Issue statement: Optimizing volume and net return on timber harvest 

will provide for flexibility, in both the long and short term, for offering 

economically viable timber sales. 

This issue relates to the viability of the local economies, both on 

Kupreanof Island and within Southeast Alaska. It concerns proposed 

timber sales, the potential employment and revenues generated by the 

project, and the ability of smaller companies to compete for timber 

sales in the project area. It also relates to the availability of a timber 

supply and overall ability to respond to ever-changing future markets. 

This issue addresses both maximizing timber harvest and “best” 

economics. While looking at financial efficiency analysis is one tool to 

Issue 1 – Timber 

Supply and Sale 

Economics 
Summary 

Central Kupreanof Timber Harvest FEIS Summary v

gauge economics, a greater number of units/larger volume available 

allows for greater diversity and flexibility in responding to future 

market demands and to appropriately package potential sales. Also, 

with the 2008 Forest Plan decision and implementation of the adaptive 

management strategy, timber economics must consider maximizing 

opportunities in the Phase 1 land base. 

Units of Measure 

The unit of measure to compare alternatives will include timber 

volume measured in million board feet (MMBF), logging costs per 

thousand board feet (MBF), indicated bid in dollars per MBF, 

employment in number of direct job years, direct income based on 

projected employment, and logging systems by harvest method (acres). 

The unit of measure will also include a qualitative discussion of an 

alternative’s ability to provide for greater diversity and flexibility in 

responding to future market demands and packaging a variety of 

potential sales. 

Issue statement: Timber harvest and building roads in inventoried 

roadless areas will reduce roadless acres within the project area and 

may affect roadless values. 

This issue relates to timber harvest and the related construction of new 

roads to facilitate timber harvest in inventoried roadless areas. 

Additional roads and harvest would result in reducing acres of roadless 

area in the project area, and could affect roadless values as identified 

in the 2003 Forest Plan SEIS. Nationally, inventoried roadless areas 

are considered to have valuable qualities. Several comments were 

received from the public concerning management of roadless in the 

project area. Three of the four inventoried roadless areas within the 

project area may be directly affected by proposed activities. 

Unit of Measure 

Comparison of alternatives will include acres of inventoried roadless 

areas affected, percent of inventoried roadless areas affected, and the 

effects to the roadless values of each inventoried roadless area as 

identified in the 2003 Forest Plan SEIS. 

Issue statement: Road building, reconstruction and closures 

associated with the timber sale may change access within the project 

area. 

The construction and use of forest roads is the focus of much concern 

on both a national and local scale. Comments ranged from requesting 

no more new roads and closure of most existing roads to requests to 

increase access by new roads and opening more existing roads. 

Decisions made from the analysis in this EIS will include proposed 

road construction in each alternative (new construction and 

reconstruction), use of existing NFS roads, and the status of these 

roads after timber harvest. 

Issue 2- 

Inventoried 

Roadless Areas 

Issue 3- Road 

Management/ 

Access 
Summary 

vi  Summary Central Kupreanof Timber Harvest FEIS

Roads influence wildlife populations, water quality, subsistence use, 

and the type of recreational opportunities available. Concerns were 

also expressed over the ability to maintain open roads. The District 

will look at road management objectives across the district, including 

the entire Kake Road System during the Petersburg Ranger District 

Access and Travel Management Environmental Assessment (PRD 

ATM EA). Recommendations for roads not associated with the 

proposed activities have been carried forward and analyzed through 

the District’s ATM by 2009. 

Units of Measure 

Comparison of alternatives will include miles of road (NFS and 

temporary) constructed, miles of reconstructed road, miles of road to 

be left open, miles of road to be closed associated with timber harvest 

activities, miles of new NFS and temporary road to be constructed in 

inventoried roadless areas, cost of maintenance for open roads, 

reconstruction, and new (NFS and temporary) road construction. 

Changes Made Between Draft and Final 

EIS

 Stream and crossing information on the Road Cards in 

Appendix B were corrected with field data or gaps identified 

and criteria disclosed. A correction from 61 red fish crossings 

to 54 crossing occurs in the FEIS due to more recent road 

maintenance information. Also, based on available stream 

information, short span log stringer or modular bridges were 

recommended to reduce effects on some stream channels 

(including Class III streams). Prior to actual construction of 

roads and stream crossings, final locations, structure types and 

design will be completed. All applicable Forest Plan Standards 

and Guidelines, Forest Service manual and handbooks, best 

management practices and the MOUs with Alaska Department 

of Fish and Game (when applicable) will be incorporated 

during design, construction and maintenance of roads. 

 In response to concerns about the red crossings within the 

project area, an upstream assessment of fish habitat was 

completed and is included in the FEIS Aquatics section. 

Consequently, the number of red fish crossings was updated. 

This analysis supports the original DEIS analysis. 

 Field methods were better documented for several resources 

including aquatics and transportation. 

 A more detailed discussion of effects to stream flows is also 

included in the FEIS. 
Summary 

Central Kupreanof Timber Harvest FEIS Summary vii

 Road densities were calculated at multiple scales and included 

in the analysis. 

 In document discussions, corrections were made to the road 

numbers and miles of currently open NFS roads that would be 

closed with this project. Road cards, maps and related road 

numbers were correct in the DEIS. 

 The timber sale economics and supply analysis was updated 

due to the use of NEAT_R version 2.15 as well as a better 

description of the small sales available and greater flexibility in 

the larger volume alternatives. 

 The wildlife section was updated to include a more complete 

discussion of the rationale for choosing POG as the unit of 

measure and method of analysis. 

 The Subsistence section was updated to include better 

information on use areas, preferences, access, and use of 

multiple subsistence resources. 

 The cumulative effects analysis for POG within multiple 

WAAs was updated to exclude the Threemile Timber Harvest 

units as the decision for this project was vacated. 

 Updates to the Region 10 Sensitive Species List (2009) were 

noted in the sensitive plants section. However, the Central 

Kupreanof project is exempt from applying the 2009 revisions 

due to the project’s advanced stage when the list was approved 

and signed. The difference would be fewer effects to sensitive 

species in the area with the revisions since the two known 

species were removed from the list and none of the new species 

were found in the project area. 

 The Yellow-billed loon was added as a Federal Candidate 

Species; the Black oystercatcher and Aleutian Tern were added 

to the Sensitive Species list, and evaluated in the analysis for 

the FEIS. 

 Biological Evaluations have been published in this FEIS in 

Appendix E. 

 The total acres affected for Rocky Pass IRA was corrected. 

 On May 28, 2009, the USDA Secretary reserved decision 

making authority over the construction and reconstruction of 

roads and the cutting, sale or removal of timber in Inventoried 

Roadless Areas. This project will be sent to the Secretary of 

Agriculture for review. 

 The acres of detrimental soil conditions caused by temporary 

road construction were underestimated for all action 

alternatives. The increase, however, did not change the 

percentage of the harvest area affected. 
Summary 

viii  Summary Central Kupreanof Timber Harvest FEIS

 The miles of reconstructed, temporary and system roads 

crossing wetlands were underestimated for all action 

alternatives, as well as the existing condition of system roads 

crossing wetlands. The underestimation was by a factor of 

three due to a unit conversion error. This does not change the 

conclusion regarding the cumulative effects of roads crossing 

wetlands. 

 The Southeast Alaska Conservation Council (SEACC) 

submitted an alternative for consideration after the 45 day 

comment period for the DEIS was over. The alternative was 

considered but not carried forward (see page 2-11 for more 

discussion). 

 Additional information and minor corrections were added, 

where appropriate, as requested through comments on the 

DEIS. 

Alternatives Considered in Detail 

The No-Action Alternative (Alternative 1), Proposed Action 

(Alternative 2) and two other action alternatives (Alternatives 3 and 4) 

are considered in detail in this chapter. Alternatives 3 and 4 provide 

alternate means of satisfying the Purpose and Need for this project 

than does the Proposed Action. They respond differently to the 

significant issues that are discussed in this chapter. Maps of all 

alternatives considered in detail are provided at the end of Chapter 2. 

The map for Alternative 1, the No-action Alternative, represents the 

current condition of the project area (See Figures 2-1 through 2-4, at 

the end of this chapter, for maps of each alternative. Larger-scale 

maps of the alternatives are contained in the project record.) 

This alternative represents the existing condition against which the 

other alternatives are compared. 

Alternative 1 proposes no new timber harvest or road construction in 

the Central Kupreanof project area at this time. It does not preclude 

future timber harvest or other activities from this area. The Council on 

Environmental Quality (CEQ) regulations (40 CFR 1502.14d) requires 

that a “No Action” alternative be analyzed in every EIS. 

Alternative 2 is the Proposed Action and was designed to meet the 

Purpose and Need for this project, and to address concerns related to 

timber economics and deer habitat. It would offer up to 46.8 MMBF 

(sawlog and utility) of timber from 2,506 acres. It would consist of 

2,031 acres (81%) that would be clearcut (CC), 33 acres (1%) that 

would be clearcut with reserves (CCR), and 442 acres (18%) that 

would be uneven-aged management. There would be 7.3 miles of new 

Alternative 1 

(Figure 2-1) 

Alternative 2 

(Figure 2-2) 
Summary 

Central Kupreanof Timber Harvest FEIS Summary ix

NFS roads constructed, 2.9 miles of reconstructed road, and 3.9 miles 

of temporary road construction to access timber. 

Alternative 3 would provide the largest amount of volume of all the 

alternatives. It proposes harvesting 70.2 MMBF (sawlog and utility) 

from 3,647 acres. It would consist of 3,127 acres (86%) that would be 

clearcut (CC), and 520 acres (14%) that would be uneven-aged 

management. This alternative proposes helicopter yarding for those 

units where access by road construction is not feasible. Ground based 

systems and associated road construction are analyzed for this 

alternative. There would be 25.1 miles of new NFS roads constructed, 

9.1 miles of reconstructed road and 6.1 miles of temporary road 

constructed. 

This alternative would respond to maximizing timber harvest 

opportunity while meeting Forest Plan Standards and Guidelines. It 

addresses the timber economics issue by maximizing the proposed 

volume available and would allow the Forest Service the flexibility to 

respond to current and future market demands. 

Alternative 4 was developed in response to public concerns about the 

impacts of increased access, timber harvest, and road building on 

inventoried roadless area characteristics. This alternative offers the 

lowest amount of volume at 28.2 MMBF (sawlog and utility) from 

1,327 acres. All units would be clearcut (CC). There would be no 

new NFS road construction; 2.6 miles of road would be reconstructed 

and 2.2 miles of temporary road construction. 

Alternative 4 addresses all of the significant issues to some extent. It 

does not propose harvest and road building within the boundary of any 

Inventoried Roadless Area, although there would be effects to the zone 

of influence. Harvest would be limited to units in close proximity to 

existing roads. No new NFS roads and 2.2 miles of temporary road 

are proposed, which addresses concerns related to increased access. 

Less road building results in shorter haul distances which also satisfies 

timber economics concerns related to today’s market, but does not take 

into account the need for flexibility in the long term. 

Design Criteria Common to All Action 

Alternatives 

All alternatives are consistent with the 2008 Tongass Land and 

Resource Management Plan (Forest Plan). All applicable Forest Plan 

Standards and Guidelines have been incorporated into the design of the 

proposed units and alternatives. While some alternatives have been 

designed to provide a greater measure of protection than is required by 

the Forest Plan for some resources, such as additional consideration 

for potential wildlife travel corridors, all alternatives were designed to 

Alternative 3 

(Figure 2-3) 

Alternative 4 

(Figure 2-4) 
Summary 

x  Summary Central Kupreanof Timber Harvest FEIS

meet Forest Plan Standards and Guidelines for these and all other 

resources. Additional direction comes from applicable laws and Forest 

Service manuals and handbooks. A complete collection of sitespecific descriptions and resource considerations for each potential 

harvest unit (unit and road cards) were published in Appendix B of the 

DEIS. In this FEIS road cards can be found in Appendix B, and the 

unit cards associated with the selected alternative are located in 

Appendix 2 of the ROD. These cards serve as the prescription or 

design narrative for the project as well as detail design elements for the 

construction and reconstruction needed for existing National Forest 

System roads. 

Temporary (or NFS) roads were proposed in all units where shovelyarding distances exceeded 500 feet to provide a surface for log 

hauling. Temporary road locations on the maps are estimated. 

Temporary road locations are subject to approval by the Forest 

Service. Temporary road decommissioning will be part of the timber 

sale contract. 

Road closures will occur up to ten years after the completion of timber 

harvest. Road closure, storage and decommissioning are described in 

the Road Management/Access section in Chapter 3 and in the Glossary 

of Chapter 4. 

Existing rock quarries may be expanded or new rock quarries may be 

developed to support new road construction and maintenance. Quarry 

sites would be developed within 500 feet of a road and avoid Class I 

and Class II stream buffers, old-growth habitat reserves, eagle and 

goshawk nest tree buffers, and non-development LUDs. With either 

the expansion of an existing quarry or the development of a new site, 

the area footprint would not exceed five acres. 

Prior to quarry development a Site Development Plan will be reviewed 

and approved by resource specialists and the District Ranger. 

No land camp is proposed in the project area for any of the 

alternatives. The town of Kake or a floating camp could be used 

during harvest activities. Appropriate permits would need to be 

acquired by the operator for use of a floating camp. 

Stewardship Contracting 

In developing the projects common to all action alternatives, the 

District considered the potential of using stewardship contracting with 

proposed timber harvest activities. The District worked with Kake to 

identify projects where existing equipment and infrastructure could be 

used to accomplish the work. Funding for project contracting may 

come from a combination of timber receipts and other appropriated 

dollars. The receipts from the value of the timber could be used to 

Roads 

Rock Quarries 

Logging Camp 
Summary 

Central Kupreanof Timber Harvest FEIS Summary xi

finance the contractual requirements, and a priority listing of the 

project area activities could be included in the contract. These projects 

would either be accomplished as part of the contract or independently. 

There would be a list of mandatory projects to be completed with 

timber receipts, combine with the possibility of using other 

appropriated dollars available at the time to maximize the number of 

project completed. 

Projects Common to all Action Alternatives 

The following projects were identified by the Interdisciplinary Team 

as possible stewardship opportunities within the project area. These 

projects are not design criteria or mitigation measures to reduce the 

effects of the alternatives, but could be used to improve or enhance 

resources or to complete obligations within the project area. These 

projects are common to all action alternatives and are suitable for 

potential stewardship contracting opportunities. 

See Figure 2-5 for more information regarding Projects Common to 

All Action Alternatives. 

During this project, the Roads Analysis Process (RAP) was updated 

and recommendations for road management objectives for the entire 

Kake road system were made. Recommendations for roads not 

associated with the proposed timber harvest activities have been 

incorporated into the Petersburg Ranger District Access Travel and 

Management Plan Environmental Assessment (EA). Roads identified 

for closure include roads with red fish crossings. Ultimate closure of 

those roads will depend on the decision made from that EA (expected 

in 2009). Implementation of road closures would result in the removal 

of culverts that do not meet fish passage standards and could be 

accomplished through stewardship contracts associated with an action 

alternative. 

Maintain the four recreational hiking trails in the area: Cathedral Falls 

(0.5 mi.), Goose Lake (0.75 mi.), Hamilton Creek (1.0 mi.), and Big 

John Bay (1.75 mi.). The total length of all trails combined is about 

four miles. The work could include annual brushing, condition 

surveys and replacement of gravel as needed. Structure work on the 

trails could also be included depending on the extent and difficulty of 

the work. Gravel for trail maintenance in the past has been obtained 

locally in Kake. 

Conduct annual maintenance for the Big John Bay Cabin including 

preparing it for occupancy in the spring and winterizing it at the end of 

the season. In addition, deferred maintenance and repairs could also 

be considered for this project. The cabin can be accessed by hiking the 

1.75-mile trail off Road 45001or by boating to Big John Bay. 

Fisheries/ 

Hydrology 

Recreation 
Summary 

xii  Summary Central Kupreanof Timber Harvest FEIS

Hand-pull a small population of spotted knapweed located on the 6337 

Road. Work could involve up to a half-day of work annually for at 

least five years and possibly monitoring and/or hand-pulling beyond 

that depending on how well the plants respond to hand-pulling. Proper 

disposal of the pulled weeds would be specified as part of the project 

design, most likely burning in a controlled manner. Other roadside 

weed populations could also be included, if new populations are 

discovered. 

Currently there are 325 acres of precommercial thinning to accomplish 

in second growth stands that could potentially be done under a 

stewardship contract on the Kake road system. These stands are 

approximately 25 years old. Thinning prescriptions would use 

traditional thinning methods, and may vary to include spacing from 14 

x 14 to 18 x 18 feet. Thinning in these stands would also benefit 

wildlife as it would provide cover and allow side lighting to reach the 

forest floor. (See Figure 2-5) 

There are approximately 114 miles of Forest Service System roads in 

the Kake road system, which encompasses the Central Kupreanof EIS 

project area. Of those 114 miles of roads there are approximately 94 

miles of open roads that need maintenance to remain open. This 

maintenance generally includes brush cutting, blading of the road 

surface, ditching and cleaning of culverts to keep proper drainage. Of 

the 94 miles of open road there are approximately 38 miles of mainline 

roads (6040, 6328, 6314, 6314S) that take first priority for 

maintenance. 

Petersburg Ranger District historically has approximately $70,000 per 

year to spend on road maintenance in Kake. On the average it costs 

$2,000 per mile to maintain roads, which equates to 35 miles of road 

per year that can be done in Kake. Generally, two thirds of the 

mainline roads are done and the remaining portion is spent on selected 

side roads. 

A Microsale is a timber sale consisting of dead or down timber which 

has been proposed by a prospective purchaser, and the District Ranger 

agrees to offer for bidding using an informal advertisement and short 

bid form. The maximum size of a Microsale would be 50 MBF. 

Microsales are generally associated with a small number of trees. Dead 

or down trees within a distance of approximately 200 feet from one of 

the listed roads, and are harvestable under Forest Plan (2008) 

Standards and Guidelines, may be eligible as a Microsale opportunity 

within the project area. 

On site evaluation will be conducted when trees have been identified 

for Microsale opportunities. For all action alternatives, Microsales 

authorized by the District Ranger would be allowed to occur along 

NFS roads 6040, 6314, 6314S, 6326, 6328, 6334, 6336, 6339 and 

6367. 

Invasive Plants 

Silviculture/ 

Wildlife 

Transportation 

Microsales 
Summary 

Central Kupreanof Timber Harvest FEIS Summary xiii
Central Kupreanof Timber Harvest FEIS Contents i

 

Table of Contents 

Chapter 1- Purpose and Need 

Introduction..................................................................1-1 

Purpose and Need............................................................1-2 

Proposed Action (Alternative 2)...........................................1-2 

The Decision Making Process.............................................1-4 

Decisions to be Made.......................................................1-4 

Description of the Project Area............................................1-5 

Public Involvement.........................................................1-15 

Consultation with Federally Recognized Tribal Governments and 

Tribal Corporations.........................................................1-17 

ANILCA Section 810 Subsistence Hearings...........................1-17 

Significant Issues...........................................................1-18 

Comments on Other Resources..........................................1-20 

Federal and State Permits, Licenses and Certifications...............1-22 

Applicable Laws and Executive Orders.................................1-23 

Chapter 2- Alternatives 

Introduction ........................................................................................ 2-1 

Development of the Proposed Action ................................................ 2-2 

Development of Alternatives ............................................................. 2-2 

Changes Made Between Draft and Final EIS .................................... 2-3 

Alternatives Considered in Detail ...................................................... 2-5 

Identification of the Preferred Alternative ......................................... 2-6 

Design Criteria Common to all Action Alternatives .......................... 2-6 

Mitigation Measures .......................................................................... 2-7 

Stewardship Contracting .................................................................... 2-8 

Projects Common to all Action Alternatives ..................................... 2-8 

Alternatives Considered but Eliminated from Detailed Study ........ 2-10 

Monitoring ...................................................................................... .2-13 

Comparison of Alternatives ......................................................... ...2-15 
Contents 

ii  Contents Central Kupreanof Timber Harvest FEIS 

Chapter 3- Environment and Effects 

Introduction ........................................................................................ 3-1

Timber Supply/Sale Economics ....................................................... 3-10

Inventoried Roadless Areas ............................................................. 3-25

Road Management/Access ............................................................... 3-41

Botany .............................................................................................. 3-58

Wildlife ............................................................................................ 3-72

Subsistence ....................................................................................... 3-99

Hydrology/Fisheries ....................................................................... 3-108

Timber and Vegetation .................................................................. 3-140

Soils and Geology .......................................................................... 3-157

Wetlands ........................................................................................ 3-169

Scenery ........................................................................................... 3-180

Unroaded Areas ............................................................................. 3-193

Recreation ...................................................................................... 3-194

Heritage Resources ........................................................................ 3-207

Chapter 4- References and Lists 

Glossary ...............................................................4-1 

List of Preparers............................................................4-33 

List of Recipients...........................................................4-35 

References ..............................................................4-39 

Index .......................................................................4-52 

List of Tables 

Table 2-1. Comparison of Alternatives by Issues and Effects_2-18 

Table 3-1. Forest Products Industry Employment in Southeast Alaska 

2002 through 20074 _____________________________________ 3-12

Table 3-2. Existing and Proposed Miles by Alternative within the 

Project Area __________________________________________ 3-14

Table 3-3. Yarding System and Harvest Method (Acres) _______ 3-15

Table 3-4. Timber Financial Efficiency Analysis _____________ 3-16

Table 3-5. Estimated Volume in MMBF ____________________ 3-17

Table 3-6. Timber Financial Efficiency Analysis (if public work funds 

cover NFS road construction costs). ________________________ 3-19

Table 3-7. Estimated Project Employment and Income in Alaska 3-20

Table 3-8. Comparison of Alternatives _____________________ 3-23

Table 3-9. 2008 Forest Plan Development and Non-development 

LUD allocation for project area Inventoried Roadless Area _____ 3-27
Contents 

Central Kupreanof Timber Harvest FEIS Summary iii

Table 3-10. North Kupreanof Inventoried Roadless 

Area(99,566)__________________________________________3-34

Table 3-11. South Kupreanof Inventoried Roadless Area (213,122 

acres) __________________________________________3-34

Table 3-12. Rocky Pass Inventoried Roadless Area __________ 3-35

Table 3-13. Miles of Road by Maintenance Levels ___________ 3-44

Table 3-14. Proposed New Road Miles in the Central Kupreanof 

Timber Harvest Project Area______________________________3-49

Table 3-15. Existing and Proposed Open Road Miles within the 

Central Kupreanof Timber Harvest Project Are_______________3-54

Table 3-16. Planned Road Construction Miles and Cost by 

Alternative __________________________________________3-55

Table 3-17. Determinations for Sensitive Plant Species by 

Alternative. __________________________________________3-63

Table 3-18. High priority Invasive Plants on the Kake Road System

 __________________________________________3-67

Table 3-19. Species Screen Analysis ______________________ 3-73

Table 3-20. Reduction of Productive Old-Growth Habitat _____ 3-88

Table 3-21. Road Densities _____________________________ 3-91

Table 3-22. Cumulative Reduction of POG within the Biogeographic 

Province and WAA _____________________________________ 3-95

Table 3-23. Summary of Timber Harvest Acres in Project Area 

Watersheds (not including road clearings) __________________ 3-112

Table 3-24. Percent of High and Very High Hazard MMI Soil Types 

and Landslide Summary for Project Area Watersheds1 ________ 3-113

Table 3-25. Density of Roads and Streams in Project Area 

Watersheds _________________________________________3-115

Table 3-26. Summary of Upstream Habitat Impacted by Red Fish 

Crossings _________________________________________3-116

Table 3-27. Stream Classes and Lake/Pond Habitat within Project 

Area Watersheds ______________________________________ 3-118

Table 3-28. Anadromous Fish Presence in Project Watersheds _ 3-119

Table 3-29. Number of Class I and II Crossings on Anadromous and 

Resident Fish Streams __________________________________ 3-121

Table 3-30. Summary of Proposed Timber Harvest by 

Alternative___________________________________________ 3-127

Table 3-31. 30-year Cumulative Harvest Percentage by Alternative1

 _________________________________________3-128

Table 3-32. Proposed clearcut acreage1 in Alternative 2 on High 

(MMI-3) or Very High (MMI-4) Hazard Soils _______________ 3-129

Table 3-33. Road Related Changes Proposed in Alternative 2 _ 3-130

Table 3-34. Proposed Clearcut Acreage1 in Alternative 3 on High 

(MMI-3) or Very High (MMI-4) Hazard Soils _______________ 3-132

Table 3-35. Road-Related Changes Proposed in Alternative 3 _ 3-133

Table 3-36. Proposed Clearcut Acreage1 in Alternative 4 on High 

(MMI-3) or Very High (MMI-4) Hazard Soils _______________ 3-134
Contents 

iv  Contents Central Kupreanof Timber Harvest FEIS 

Table 3-37. Road-Related Changes Proposed in Alternative 4 _ 3-135

Table 3-38. Land Classification Acres (National Forest Land) Within 

the Project Area_______________________________________ 3-142

Table 3-39. Acres of Suitable and Non-suitable Timber Harvested in 

the Central Kupreanof Timber Harvest Project Area by Decade _ 3-146

Table 3-40. Volume Strata on Suitable Forest Acres in the Central 

Kupreanof Project Area ________________________________ 3-147

Table 3-41. Acres of Silviculture System and Regeneration Method 

Chosen for the Central Kupreanof Units by Alternative _______ 3-150

Table 3-42. Previous and Proposed Timber Harvest for Each 

Alternative _________________________________________3-155

Table 3-43. Acres1 of MMI in Proposed Units by Alternative _ 3-160

Table 3-44. Comparison of Landslides within the Central Kupreanof 

Project Area that are associated with Harvested Areas and those that 

Occurred Naturally ____________________________________ 3-161

Table 3-45. Estimated Acres of Detrimental Soil Conditions within 

the Proposed Harvest Units as a result of Project Implementation

 _________________________________________3-163

Table 3-46. Miles of Proposed NFS and Temporary Road by 

Alternative and MMI Class within the Central Kupreanof Project Area

 _________________________________________3-163

Table 3-47. Cumulative Effects - Summary of Existing Soil 

Disturbance within the Central Kupreanof Project Area and 

Disturbance that May Result from Project Implementation _____ 3-167

Table 3-48. Wetland Habitat Types in the Central Kupreanof Project 

Area. _________________________________________3-171

Table 3-49. Wetland Acres Previously Harvested and those Proposed 

for Harvest within the Central Kupreanof Project Area ________ 3-172

Table 3-50. Miles of Road Crossing Wetlands within the Project 

Area _________________________________________3-173

Table 3-51. Past, Proposed and Future Foreseeable Acres of 

Wetlands lost to Road Construction1. ______________________ 3-174

Table 3-52. Project Area Visibility from Visual Priority Travel 

Routes or Use Areas ___________________________________ 3-182

Table 3-53. Project Area Acres by Scenic Integrity Objective _ 3-183

Table 3-54. Project Area Acres by Existing Scenic Integrity __ 3-184

Table 3-55. Acres of Harvest in Distance Zones1 by Alternative

 _________________________________________3-186

Table 3-56. Acres of Past and Proposed Cumulative Visual 

Disturbance _________________________________________3-191

Table 3-57. Existing Recreation Opportunity Spectrum (ROS) 

Classes in the Central Kupreanof Project Area _______________ 3-195

Table 3-58. Recreation Opportunity Spectrum (ROS) Class Acres in 

the Project Area_______________________________________ 3-200

Table 3-59. Recreation Opportunity Spectrum (ROS) Percentages in 

the Project Area_______________________________________ 3-201
Contents 

Central Kupreanof Timber Harvest FEIS Summary v

List of Figures 

Figure 1-1. Figure Vicinity Map ................................................... 1-6 

Figure 1-2. Land Use Designations on Kupreanof Island ...... ...1-13 

Figure 2-1. Figure Alternative 1 Map ......................................... 2-23 

Figure 2-2. Figure Alternative 2 Map ......................................... 2-25 

Figure 2-3. Figure Alternative 3 Map ......................................... 2-27 

Figure 2-4. Figure Alternative 4 Map ......................................... 2-29 

Figure 2-5. Projects Common to all Action Alternatives ........... 2-31 

Figure 3-1. Roadless Map.............................................3-39 

Figure 3-2. Vegetation map of Kupreanof Island ....................... 3-83 

Figure 3-3. Project-area watersheds and streams ..................... 3-109 

Figure B-1. Road Management Objectives...........................B-1 

 

Appendices 

Appendix A- Reason for Scheduling the Environmental Analysis of 

the Central Kupreanof Timber Harvest..................................A-1 

Appendix B- Activity Cards...............................................B-1 

Appendix C- Catalog of Events...........................................C-1 

Appendix D- Agency Response to Public Comments on the Central 

Kupreanof Timber Harvest DEIS.........................................D-1 

Appendix E- Biological Evaluations for Plants and Wildlife.........E-1 
 

Chapter 1 

Purpose and Need 
Chapter 1 

Table of Contents 

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

Purpose and Need ................................................................................. 2 

Proposed Action (Alternative 2) ........................................................... 2 

The Decision Making Process .............................................................. 4 

Decisions to be Made ............................................................................ 4 

Description of the Project Area ............................................................. 5 

Public Involvement ............................................................................. 15 

Consultation with Federally Recognized Tribal Governments and 

Tribal Corporations ............................................................................. 17 

ANILCA Section 810 Subsistence Hearings ...................................... 17 

Significant Issues ................................................................................ 18 

Comments on Other Resources ........................................................... 20 

Federal and State Permits, Licenses and Certifications ...................... 22 

Applicable Laws and Executive Orders .............................................. 23 
Central Kupreanof Timber Harvest FEIS Chapter 1 1 

Chapter 1 

Purpose and Need 

Introduction 

The Central Kupreanof Timber Harvest project area is located on the 

western portion of Kupreanof Island, on the Petersburg Ranger District 

of the Tongass National Forest, Alaska Region (Region 10) of the 

Forest Service, an agency of the U.S. Department of Agriculture (see 

Vicinity Map, Figure 1-1). 

This chapter discusses the background of the Central Kupreanof 

Timber Harvest. The actions analyzed in this FEIS are designed to 

implement the direction contained in the 2008 Tongass Land and 

Resource Management Plan (Forest Plan). It includes the steps taken 

to identify environmental issues and public concerns related to 

implementation of the project. 

Document Structure 

The Forest Service has prepared this Environmental Impact Statement 

(EIS) in compliance with the National Environmental Policy Act 

(NEPA) and other relevant Federal and State laws and regulations. 

This Environmental Impact Statement discloses the direct, indirect, 

and cumulative environmental impacts that would result from the 

proposed action and alternatives. The document is organized into four 

chapters: 

Chapter 1. Purpose and Need: The chapter includes information on 

the history of the project proposal, the purpose of and need for the 

project, and the agency’s proposal for achieving that purpose and need. 

This section also details how the Forest Service informed the public of 

the proposal and how the public responded. 

Chapter 2. Alternatives: This chapter provides a more detailed 

description of the agency’s proposed action as well as alternative 

methods for achieving the stated purpose. These alternatives were 

developed based on significant issues raised by the public and other 

agencies. This discussion also includes mitigation measures. Finally, 
1 Purpose and Need 

2  Chapter 1 Central Kupreanof Timber Harvest FEIS 

this chapter provides a summary table of the environmental 

consequences associated with each alternative. 

Chapter 3. Affected Environment and Environmental Effects: This 

chapter describes the environmental effects of implementing the 

proposed action and other alternatives. 

Chapter 4. References and Lists: This chapter provides a glossary, 

references, a list of preparers consulted during the development of the 

environmental impact statement, a list of FEIS recipients and an index 

that provides page numbers by document topic. 

Appendices: The appendices provide more detailed information to 

support the analyses presented in the environmental impact statement. 

Additional documentation, including more detailed analyses of 

project-area resources, may be found in the project record located at 

the Petersburg Ranger District. 

Purpose and Need 

The purpose and need for the proposed action responds to the goals 

and objectives identified by the Tongass Land and Resource 

Management Plan, and helps move the area toward the desired 

conditions as described in the Forest Plan. The Forest Supervisor is 

the Responsible Official for this action and will decide whether or not 

to harvest timber from the Central Kupreanof Timber Harvest area, 

and if so, how this timber will be harvested. The decision will be 

based on the information that is disclosed in the environmental impact 

statement. The Responsible Official will consider comments, 

responses, the disclosure of environmental consequences, and 

applicable laws, regulations, and policies in making the decision and 

will state that rationale in the Record of Decision. 

Proposed Action (Alternative 2) 

The proposed action, as published in the Federal Register, provides for 

multiple timber sale opportunities and would result in the production 

of approximately 40 million board feet (MMBF) of timber from 

approximately 2,025 acres of forested land. Up to 11.1 miles of 

National Forest System (NFS) roads and 7.0 miles of temporary roads 

may be necessary for timber harvest. Through two field seasons and 

the interdisciplinary process, the proposed action has been adjusted to 

respond to on the ground conditions and resource concerns while 

remaining within the scope of the original proposed action. The 

Proposed Action for this project still provides for multiple timber sale 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 3 

opportunities and will result in the production of approximately 46.8 

MMBF (about 39.4 MMBF of sawlog and 7.4 MMBF of utility) from 

2,506 acres of forested land. Up to 7.3 miles of new NFS and up to 3.9 

miles of temporary road would be constructed for timber harvest. A 

range of alternatives, responsive to significant issues, has been 

developed and includes a no action alternative. 

The interdisciplinary team has identified several projects within the 

project area that could serve as stewardship opportunities along side 

the timber harvest proposal. These projects consist of: 

 Recreation- maintain hiking trails in the area and perform 

annual cabin maintenance for the cabin located in Big John 

Bay. 

 Silviculture and Wildlife- precommercially thin 325 acres of 

second growth. 

 Transportation- perform maintenance on 94 miles of open road. 

Maintenance would include blading, brushing, and clearing 

culverts. 

 Fisheries/Hydrology- any fisheries or hydrology projects are 

tied to the analysis and decisions to be made with the PRD 

ATM EA. 

 Invasive Plants- handpulling a small population of spotted 

knapweed, with the possible inclusion of other weed 

populations if they were discovered. 

 Microsales- timber sales consisting of dead or down timber 

which has been proposed by a prospective purchaser, and the 

District Ranger agrees to offer for bidding using an informal 

advertisement and short bid form. The maximum size of a 

Microsale would be 50 MBF. 

These projects will be analyzed as common to all action alternatives. 

A complete description of the projects can be found in Chapter 2 

(pages 7 and 8), and map of these projects is also provided in Chapter 

2 (Figure 2-5). 

 

The Purpose of the Central Kupreanof Timber 

Harvest project is to: 

 Manage the timber resource for production of sawtimber and 

other wood products from suitable lands made available for 

timber harvest on an even-flow, long-term sustained yield 

basis, and in an economically efficient manner. 
1 Purpose and Need 

4  Chapter 1 Central Kupreanof Timber Harvest FEIS 

 Seek to provide a timber supply sufficient to meet the annual 

market demand for Tongass National Forest timber and the 

market demand for the planning cycle. 

 Provide for a diversity of opportunities for resource uses that 

contribute to the local and regional economies of Southeast 

Alaska. 

Appendix A of this document provides information on how this 

project relates to the overall Tongass National Forest timber sale 

program, and why the project is being scheduled at this time. 

The Decision Making Process 

National Forest planning takes place at several levels. Decisionmaking begins with long-range planning at the national level, 

continuing down through the regional and forest levels to the project 

level. The Central Kupreanof project is part of this hierarchical 

planning process. This EIS is a project-level analysis; its scope is 

confined to issues associated with the Central Kupreanof project area. 

This EIS does not attempt to address decisions made at higher levels. 

It does, however, implement direction provided at those higher levels. 

Decisions to be Made 

Based on the environmental analysis in this EIS, the Forest Supervisor 

will decide whether and how to implement activities within the Central 

Kupreanof Project Area in accordance with Forest Plan goals, 

objectives, and desired conditions. The decision may include the 

following: 

 The location, amount, and method of timber harvest, road 

construction, marine access facilities, and silvicultural 

practices. 

 Road management objectives for constructed, reconstructed 

and existing roads associated with the timber sale. 

 Any necessary project-specific mitigation design, mitigation 

measures and monitoring requirements. 

 Whether to implement the Projects Common to all Action 

Alternatives, including a Microsale program along existing 

NFS Roads 6030, 6040, 6314, 6314S, 6326, 6328, 6334, 6336, 

6339, and 6367. 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 5 

 A determination of whether there may be a possibility of a 

significant change in subsistence uses and access. 

Description of the Project Area 

Central Kupreanof is located on the Petersburg Ranger District of the 

Tongass National Forest. The project area is on Kupreanof Island, 

approximately 30 air miles northwest of Petersburg. The northern end 

of the project area begins about 9 miles southeast of the Community of 

Kake and will utilize the Kake road system. It includes approximately 

152,517 acres, and its boundaries follow the boundary of value 

comparison units (VCUs) 429, 438, 426, 436, and 427.1. 

The project area contains portions of the Castle, Rocky Pass, North 

Kupreanof, and South Kupreanof Inventoried Roadless Areas. 

Approximately 123,297 acres of inventoried roadless area are included 

within the project area boundary. 

Past, Recent, Current and Future Management 

Activities in the Central Kupreanof Area 

Listed below is a short summary of past, current and future 

management activities within, or adjacent to, the Central Kupreanof 

project area. For a complete listing of all projects up to the summer of 

2009 see Appendix C in this document. 

Past Management Activities 

Timber harvest has previously occurred on about 4,615 acres within 

the project area. Harvest in the area began in 1967. The most recent 

timber harvest took place in 2002. 

There are approximately 79 miles of existing road in the project area. 

Currently 64 miles of road are open to motorized vehicles. Road 

maintenance and use of existing rock sources are ongoing. 

The Upper Keku fishpass is within the project area. This structure was 

completed in 1985 to provide fish passage for Steelhead trout and 

Coho salmon. The Keku fishpass is upstream from the Irish Creek fish 

pass. 

 As of the summer of 2009 there have been 1,110 acres of 

precommercial thinning completed within the project area. 

Managed Stands 

Road 

Management 

Fishpasses 

Thinning 
Legend

Project Area Boundary

Non-National Forest

Salt Water

Central Kupreanof

Figure 1-1

Vicinity Map

0 4 8 2 12 16

Miles ±

c:/workspace/ckupre/plots/deis/fig1_1_vicinity.mxd 09-20-08 EP

Kake

Kupreanof Island

Kuiu Island

Mitkof

Island

Petersburg

Prince of Wales

Island

Zarembo

Island

F R E D E R I C K S O U N D

S U M N E R S T R A I T

Hamilton LTF
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 7 

Recent and Current Management Activities 

The Kupreanof Island Analysis (September 2000) looked at current 

conditions on Kupreanof Island, effects of management activities 

island-wide, future desired conditions and possible future projects. 

On the Lindenburg Peninsula of Kupreanof Island, timber harvest 

activities have been taking place since 1997. The remaining units in 

the South Lindenburg and Finger Point Timber Sales were harvested 

beginning in the summer of 2006 and continued through the summer 

of 2008. The Tonka Timber Sale is currently in the planning process 

with a DEIS scheduled to be published in the fall of 2009. The road 

system for this area does not connect to the proposed project area. 

In October of 2006, the Scott Peak Project Area Record of Decision 

approved the harvest of approximately 8.3 million board feet 

(MMBF). Located in the northeast corner of Kupreanof Island, on the 

opposite side of Duncan Canal, the road system for this area does not 

connect to the proposed project area. 

In the foreseeable future, there may be harvest of remaining timber 

units from the Bohemia and Todahl Backline sales. These units are 

also located in the northeast corner of Kupreanof Island, west of 

Portage Bay. 

The Central Kupreanof Timber Harvest EIS and the Petersburg Ranger 

District Access and Travel Management Plan Environmental 

Assessment (PRD ATM EA) have been analyzed concurrently since 

2006. The public scoping comments for both projects have been 

considered in the analysis for both projects. The Petersburg Ranger 

District ATM project considers the access management objectives for 

the existing National Forest System (NFS) roads for the entire 

Petersburg Ranger District. The Central Kupreanof project considers 

the road management recommendations for the existing National 

Forest System roads and proposed NFS roads, needed to access timber 

for the Central Kupreanof project area, as described in Chapter 3. The 

Central Kupreanof project also analyzes the temporary roads needed 

for timber access. 

The Central Kupreanof project is not dependent on the outcome of the 

decision for the PRD ATM EA. Currently the road management 

objectives for the existing NFS roads within the Central Kupreanof 

project area are the same for both projects, and have been analyzed 

that way. 

A decision for the Central Kupreanof project is expected to occur prior 

to the decision on the PRD ATM EA. If so, the decision on the road 

management objectives for the existing roads will be incorporated into 

the decision for the PRD ATM EA. If the decision for the Central 

Petersburg 

Ranger District 

ATM EA 
1 Purpose and Need 

8  Chapter 1 Central Kupreanof Timber Harvest FEIS 

Kupreanof project happens to occur after the decision for the PRD 

ATM, then the decision on the existing NFS roads within the Central 

Kupreanof project area will incorporate the decision for the PRD 

ATM. 

Future Management Activities 

The Forest Plan identified two potential power transmission corridors 

that would link the city of Kake to the Tyee transmission line that 

currently serves Petersburg and Wrangell. The Kake – Petersburg 

Intertie Study (KPTL) Final Report, which was prepared for the 

Southeast Conference, was completed in July 2005. 

There are two to three small timber sales associated with the 6367 

Small Timber Sale CE, consisting of approximately 60 total acres of 

partial harvest on Forest System lands, just north of the project area. 

This will likely occur in 2008 through 2010. Microsales may occur in 

the project area or adjacent to the project area on Forest System lands. 

There are units in this area that will be suitable for pre-commercial 

thinning in the future. Nothing specific is planned at this time. Other 

than the proposed project, there are no ongoing or planned large scale 

timber sales within the Central Kupreanof project area at this time. 

Road maintenance within the project area is ongoing. 

The Federal Highway Kake to Seal Point Access Project is ongoing 

with field investigation to support bridge replacements and road 

construction. There was an Environmental Assessment completed for 

this project in August of 2002. 

Relationship to the Forest Plan 

Chapter 2 of the Forest Plan discusses the Forest-wide multiple use 

goals and objectives for the Tongass National Forest. The concept of 

multiple use is applied at the Forest level. Not every acre or every 

management prescription will achieve all goals for all resources. The 

goals are reached at the Forest level by providing a mosaic of land and 

resource conditions based on the 19 Land Use Designations described 

in Chapter 3 of the Forest Plan. Chapter 4 of the Forest Plan contains 

the Standards and Guidelines that guide the protection or management 

of each resource. Standards and Guidelines were designed so that all 

activities are integrated to meet land allocation objectives. 

Many of the Standards and Guidelines applicable to the activities 

proposed in the Central Kupreanof Project Area are listed under 

“Design Criteria” in Chapter 2 of this EIS, and on the Unit and Road 

Cards in Appendix B. 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 9 

Forest Plan Land Use Designations (LUDs) 

The Forest Plan provides land and resource management direction for 

the Tongass National Forest, by designating areas appropriate for 

various activities through the use of Land Use Designations (LUDs), 

seven of which occur in this project area. 

Each LUD provides for a unique combination of activities, practices, 

and uses. Areas of the Forest are allocated to land use designations for 

different uses. Each LUD has a management prescription. Each 

prescription includes goals, objectives, and a desired condition, as well 

as management practices, and Standards and Guidelines by resource. 

A brief description of the primary focus of each LUD as it relates to 

the Central Kupreanof project is listed below. Each LUD provides for 

a variety of resource uses to varying degrees. Each management 

prescription is much more complex and the full description of these 

management prescriptions are in the Forest Plan, Chapter 3. 

The amended Forest Plan improves the network of small Old-growth 

Reserves (OGRs) through work completed by an interagency team. 

Biologists from the State of Alaska, U.S. Fish and Wildlife Service 

(USFWS), and the Forest Service reviewed nearly 300 small Oldgrowth Reserves identified in the 1997 Forest Plan and recommended 

reconfigurations for many of them. The amended Forest Plan finalized 

the location of the majority of the small OGRs; therefore, project-level 

reviews are not necessary, except as outlined in the Forest plan, 

Appendix K. No additional review was necessary for the small Oldgrowth Reserves within the Central Kupreanof project area. 

The Central Kupreanof Project Area includes seven of these land use 

designations - Timber Production, Old-growth Habitat, Semi-remote 

Recreation, Modified Landscape, Special Interest Area, Remote 

Recreation and Wilderness. The locations of each land use 

designation on Kupreanof Island, including the Central Kupreanof 

Project Area, are shown on Figure 1-2. 

The Timber Production LUD makes up approximately 72% of the 

National Forest System lands in the project area. The focus of the 

Timber Production LUD is to emphasize sustained, long-term timber 

production. Timber harvest activities are located and designed to meet 

timber objectives. See pages 3-116 through 3-121 of the Forest Plan 

for an expanded description of this LUD. 

Approximately 12% of the National Forest System lands in the project 

area are allocated to the Old-growth Habitat LUD (Table 1-1) in the 

Forest Plan. The focus of this LUD as related to the Central 

Kupreanof project is to maintain areas of old-growth forests and their 

associated natural ecological processes to provide habitat for oldTimber 

Production LUD 

Old-growth 

Habitat LUD 
1 Purpose and Need 

10  Chapter 1 Central Kupreanof Timber Harvest FEIS 

growth associated resources. See pages 3-57 through 3-62 of the 

Forest Plan for an expanded description of this LUD. 

Approximately 10% of the National Forest System lands in the project 

area are allocated to the Semi-remote-Recreation (Table 1-1) in the 

Forest Plan. The goal of this LUD is to provide natural or naturalappearing setting for semi-primitive types of recreation and tourism. 

See pages 3-63 through 3-68 in the Forest Plan for an expanded 

description of this LUD. 

Approximately 5% of the National Forest System lands in the project 

area are allocated to the Modified Landscape LUD (Table 1-1) in the 

Forest Plan. Management within this LUD focuses on sustained, longterm timber production while minimizing the visibility of development 

in the foreground distance zone. This recognizes the scenic values of 

forested lands as viewed from identified Visual Priority Travel Routes 

and Use Areas (Forest Plan, Appendix F) and provides for modifying 

timber harvest practices accordingly by reducing the effects to scenery. 

See pages 3-109 through 3-115 in the Forest Plan for an expanded 

description of this LUD. 

Less than 1% of the National Forest System lands in the project area 

are allocated to the Remote Recreation LUD. This LUD is managed to 

provide extensive, unmodified natural setting for recreation and 

tourism. See pages 3-45 through 3-50 in the Forest Plan for an 

expanded description of this LUD. 

Less than 1% of the National Forest System lands in the project area 

are allocated to the Special Interest Area LUD. The Hamilton River 

Red Cedar Special Use area is the only special use area in this project 

and provides the people of Kake a place to harvest redcedar for 

cultural use. See pages 3-40 through 3-44 in the Forest Plan for an 

expanded description of this LUD. 

Less than 1% of the National Forest System lands in the project area 

are allocated to the Wilderness LUD. Wilderness LUDs are managed 

to ensure that Wilderness ecosystems are mostly free of the effects of 

civilization. See pages 3-7 through 3-25 in the Forest Plan for an 

expanded description of this LUD. 

Semi-remote 

Recreation LUD 

Modified 

Landscape LUD 

Remote 

Recreation LUD 

Special Interest 

Area 

Wilderness 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 11 

Table 1-1. 

Forest Plan Land Use Designations within the Central 

Kupreanof Project Area1 

Land Use Designation Kupreanof 

Island 

Central 

Kupreanof 

Project Area

Non-development LUDs2 

Special Interest Area (Hamilton 

River Red Cedar Area) 84 acres 84 acres 

Remote Recreation 18,943 acres 24 acres 

Old-growth Habitat 102,341 acres 18,990 acres

Semi-remote Recreation 84,430 acres 16,116 acres

Wilderness 44,000 12 acres 

Total acres 249,798 acres 35,226 acres

Development LUDs 

Modified Landscape 48,880 acres 7,666 acres 

Timber Production 307,648 acres 109,601 acres

Total acres 356,528 acres 117,267 acres

Non-National Forest System Land 58,470 acres 0 acres 

1

Total LUD acres vary from total project area acres due to slivers. 

2

Non-development LUDs generally do not permit timber harvest or road 

construction. Development LUDs allow these activities under certain conditions. 

Timber Sale Program Adaptive Management 

Strategy 

In an effort to balance competing demands for timber production and 

preservation of undeveloped areas, the Timber Sale Program Adaptive 

Management Strategy was approved in the Record of Decision for the 

2008 Forest Plan. Under this strategy, the operation of the timber sale 

program will be implemented in three phases, as determined by actual 

timber harvest levels. 

Phase 1 includes most of the roaded portion of the suitable land base, 

along with most of the lower value inventoried roadless areas. The 

moderate and higher value roadless areas are excluded. The Phase 1 

portion of the land base could sustain a level of timber harvest of about 

Phase 1 
1 Purpose and Need 

12  Chapter 1 Central Kupreanof Timber Harvest FEIS 

150 MMBF. The scheduled timber sale program will generally be 

confined to this land base until such time as the level of timber harvest 

reaches at least 100 MMBF for two consecutive years. Personal use of 

timber, Microsales, salvage sales, small commercial timber sales 

generally less than one MMBF, young-growth management projects, 

and the roads associated with these activities, would be allowed in 

development LUDs outside of the Phase 1 portion of the suitable land 

base. 

The Central Kupreanof project area is contained entirely within 

suitable lands identified as Phase 1. 

Phase 2 includes Phase 1 lands as explained above and most of the 

moderate value roadless areas. The Phase 2 portion of the suitable 

land base could sustain a level of timber harvest of about 200 MMBF. 

The scheduled timber sale program will generally be confined to this 

land base until such time as the level of timber harvest reaches at least 

150 MMBF for two consecutive years. Personal use of timber, micro 

sales, salvage sales, small commercial timber sales generally less than 

one MMBF, young-growth management projects, and the roads 

associated with these activities, would be allowed in development 

LUDs outside of the Phase 2 portion of the suitable land base. 

Phase 3 includes the remaining suitable land base including all of the 

Phase 1 and 2 lands and the higher value Inventoried Roadless Areas 

within development LUDs. 

2008 Forest Plan 

The 2008 Forest Plan improves the network of small old-growth 

reserves through work completed by an interagency team. Biologists 

from the State of Alaska, U.S. Fish and Wildlife Service (FWS), and 

the Forest Service reviewed nearly 300 small old-growth reserves 

identified in the 1997 Forest Plan and recommended reconfiguration 

for many of them. The amended Forest Plan finalized the location of 

the majority of the small OGRs. No review is necessary for the small 

old-growth reserves within the Central Kupreanof project area. 

The 2008 Forest Plan approved expansion of Geologic Special Interest 

Areas to protect nearly 47,000 acres of newly identified karst lands 

that are most vulnerable to disturbance from development. No 

Geological Special Interest Areas were identified in the Central 

Kupreanof project area. 

Phase 2 

Phase 3 
4360

4350

4380

4280

4290

4271 4400

4411

4410

4260

4420

4430

4240

Duncan

Canal

Rocky Pass

Legend

Modified Landscape

Old-growth Reserve

Remote Recreation

Special Interest Area

Semi-Remote Recreation

Timber

Wilderness

Salt Water

Project Area Boundary

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 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 15 

Public Involvement 

Public involvement is a key component of the planning process. The 

Council on Environmental Quality (CEQ) defines scoping as “an early 

and open process for determining the scope of issues to be addressed 

and for identifying the significant issues related to a proposed action” 

(40 CFR 1501.7). Among other things, the scoping process is used to 

invite public participation, to help identify public issues, and to obtain 

public comment at various stages of the environmental analysis 

process. Scoping begins early and is a process that continues until a 

decision is made. Comments received at other levels of the planning 

process, such as for the Forest Plan and the landscape level analysis, 

were also considered. The following paragraphs describe the public 

involvement activities that have occurred for the Project Area analysis. 

Public scoping began in October 2006, and was repeated in January of 

2008. Each time a newsletter identifying the Project Area and 

requesting information on site-specific concerns was mailed to 

approximately 260 people and agencies who: requested to be on the 

project mailing list, previously expressed interest in timber sale 

proposals, and either own property or conduct business near the 

Project Area, and local, state and federal agencies and federally 

recognized tribal governments. 

The project mailing list is frequently updated to accommodate requests 

for additions, deletions, and address changes. 

The Forest Service received 35 comments in response to these 

mailings. While some comments supported the proposed timber sale, 

most expressed concerns about additional road construction, 

uneconomic timber harvest, disturbance to wildlife, access to 

subsistence activities, clearcutting as a harvest method, and the 

cumulative effects of additional harvest on previously harvested 

watersheds. 

Open houses that included information about the Central Kupreanof 

Timber Harvest project were held on May 5, 2008 in Petersburg and 

July 7, 2008 in Kake. The open house, in Petersburg was advertised in 

the Petersburg Pilot, the local weekly newspaper in Petersburg, and on 

KFSK Public Radio in Petersburg. Flyers were posted on bulletin 

boards throughout Petersburg. The open house in Kake was also 

advertised by flyers posted in Kake as well as announcements 

broadcasted across the local CB channel. 

A Notice of Intent to Prepare an Environmental Impact Statement was 

published in the Federal Register on December 27, 2006. 

Public Mailing 

Open Houses 

Notice of Intent 
1 Purpose and Need 

16  Chapter 1 Central Kupreanof Timber Harvest FEIS 

After the Draft EIS was made available to the public, the 

Environmental Protection Agency published the Notice of Availability 

of the Draft EIS in the Federal Register on December19, 2008. 

Notices were also published in the Ketchikan Daily News on 

December 23, 2008, and in the Petersburg Pilot on December 25, 

2008. The 45 day public comment period for the Draft EIS ended on 

February 2, 2009. A total of 13 comments to the DEIS were received. 

Central concerns included stream crossings, the wildlife habitat 

analysis, market demand, range of alternatives and silvicultural 

prescriptions and practices. 

Following the public comment period for the Draft EIS, the comments 

received were reviewed and included in the analysis for the Final EIS. 

Comment letters and comment responses are located in Appendix D of 

this document. 

The Forest Service is committed to working closely with other 

agencies at all stages of planning. The agency is responsible for 

coordinating reviews of the project by several other agencies. In some 

cases, the reviews are required because another agency has authority to 

issue permits for certain proposed activities. In other cases, the 

reviews allow interaction with other agencies with responsibilities for 

certain environmental conditions, like clean water or healthy wildlife 

populations. This interagency cooperation helps identify the means to 

avoid or mitigate possible harmful environmental effects. In many 

cases, an ongoing professional dialogue is maintained with these 

agencies throughout the planning process. 

The following are agencies that have been consulted about this project: 

 Alaska Department of Fish and Game 

 Alaska Department of Environmental Conservation 

 Alaska Office of History and Archaeology 

 Alaska Department of Natural Resources 

 U.S. Environmental Protection Agency 

 National Marine Fisheries Service 

 U.S. Army Corps of Engineers 

 U.S. Fish and Wildlife Service 

Between the Draft and Final EISs for the Central Kupreanof project 

specialists worked with the State to resolve project level concerns 

identified in the State’s comment letter. 

The Draft to Final 

EIS- Comments 

and Availability 

Consultation 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 17 

Consultation with Federally Recognized 

Tribal Governments and Tribal Corporations 

Consultation with federally recognized tribal governments included 

government-to-government and staff level communications. 

Throughout the span of the Central Kupreanof Timber Harvest the 

District Ranger and archaeologists communicated with the Organized 

Village of Kake, Petersburg Indian Association, Wrangell Cooperative 

Association, Sealaska Corporation, Tlingit/Haida Central Council, and 

Kake Tribal Corporation. Archaeologists on the Petersburg Ranger 

District work regularly with the Organized Village of Kake (OVK) on 

a number of issues and provide frequent updates detailing Forest 

Service projects. Archaeologists met with representatives from OVK 

to discuss archaeological work in the Central Kupreanof area and 

present information regarding the proposed timber harvest in the 

project area. The District Ranger has also discussed, with OVK 

potential project opportunities associated with this project. In a 

meeting in May of 2008 OVK indicated they were interested in 

discussing further stewardship contract opportunities, particularly 

roadwork opportunities and invasive plant treatments. 

The District Ranger met again with the Organized Village of Kake on 

March 25, 2009 to discuss concerns in the Central Kupreanof DEIS, 

including red stream crossings and benefits of the proposed project to 

the community of Kake. The council was concerned Kake would see 

no benefits from this project and would rather see the trees left 

standing for subsistence use. 

Regular consultation will continue throughout the planning of this 

project and beyond. 

ANILCA Section 810 Subsistence Hearings 

In accordance with ANILCA Section 810, subsistence meetings were 

held for the Central Kupreanof project. Legal notices of the 

subsistence meetings were published in the newspaper of record, The 

Ketchikan Daily News, and the Juneau Empire on January 29, 2009 as 

well as in the local paper, The Petersburg Pilot on February 5, 2009. 

On March 17, 2009 a federal subsistence hearing was held in Kake, 

Alaska. Twelve people signed in and eight people testified. Concerns 

included the project would not benefit the residents of Kake and 

therefore leaving the forest standing would be more beneficial in terms 

of subsistence uses. 
1 Purpose and Need 

18  Chapter 1 Central Kupreanof Timber Harvest FEIS 

On March 25, 2009 a federal subsistence hearing was held in 

Petersburg, Alaska. Six people signed in and four people testified. 

Those testifying felt this project would change their subsistence use of 

the area and were concerned a restriction on the use of deer would 

occur. 

Written copies of testimonies received at both meetings are located in 

the project record. 

Significant Issues 

Significant issues are used to formulate and design alternatives, 

prescribe mitigation measures, and analyze significant effects. 

Significant issues for the Central Kupreanof Timber Harvest have been 

identified through public and internal scoping. Similar issues are 

combined where appropriate. Issues can arise from a variety of 

sources, including: 

 Issues, concerns, and opportunities identified in the Forest 

Plan, 

 Issues identified for similar projects (past actions) 

 Current internal issues, 

 Changes in public uses, attitudes, values, or perceptions, 

 Issues raised by the public during scoping, and 

 Comments from other government agencies. 

Measures of the significance of an issue are based on the extent of the 

geographic distribution, the duration of the related effects, or the 

intensity of interest or resource conflict surrounding the issue. For an 

issue to be considered significant at the project level, it must be 

relevant to the specific project so that it can be appropriately addressed 

at the project level. Some issues have already been resolved through 

national level direction or analyzed at the Forest Plan level. 

Once a significant issue is identified, measures are developed to 

analyze how each alternative responds to the issue. Measures are 

chosen that are quantitative (where possible), predictable, responsive 

to the issue, and linked to cause and effect relationships. These 

measures describe how the alternative affects the resource(s) at the 

heart of the issue. Monitoring and mitigation of the anticipated 

environmental effects of the project are also designed to be responsive 

to significant issues. 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 19 

These issues are addressed through the proposed action and the 

alternatives. 

Issue statement: Optimizing volume and net return on timber harvest 

will provide for flexibility, in both the long and short term, for offering 

economically viable timber sales. 

This issue relates to the viability of the local economies, both on 

Kupreanof Island and within Southeast Alaska. It concerns proposed 

timber sales, the potential employment and revenues generated by the 

project, and the ability of smaller companies to compete for timber 

sales in the project area. It also relates to the availability of a timber 

supply and overall ability to respond to ever-changing future markets. 

This issue addresses both maximizing timber harvest and “best” 

economics. While looking at financial efficiency analysis is one tool to 

gauge economics, a greater number of units/larger volume available 

allows for greater diversity and flexibility in responding to future 

market demands and to appropriately package potential sales. Also, 

with the 2008 Forest Plan decision and implementation of the adaptive 

management strategy, timber economics must consider maximizing 

opportunities in the Phase 1 land base. 

Units of Measure 

The unit of measure to compare alternatives will include timber 

volume measured in million board feet (MMBF), logging costs per 

thousand board feet (MBF), indicated bid in dollars per MBF, 

employment in number of direct job years, direct income based on 

projected employment, and logging systems by harvest method (acres). 

The unit of measure will also include a qualitative discussion of an 

alternative’s ability to provide for greater diversity and flexibility in 

responding to future market demands and packaging a variety of 

potential sales. 

Issue statement: Timber harvest and building roads in inventoried 

roadless areas will reduce roadless acres within the project area and 

may affect roadless values. 

This issue relates to timber harvest and the related construction of new 

roads to facilitate timber harvest in inventoried roadless areas. 

Additional roads and harvest would result in reducing acres of roadless 

area in the project area, and could affect roadless values as identified 

in the 2003 Forest Plan SEIS. Nationally, inventoried roadless areas 

are considered to have valuable qualities. Several comments were 

received from the public concerning management of roadless in the 

project area. Three of the four inventoried roadless areas within the 

project area may be directly affected by proposed activities. 

Issue 1 – Timber 

Supply and Sale 

Economics 

Issue 2- 

Inventoried 

Roadless Areas 
1 Purpose and Need 

20  Chapter 1 Central Kupreanof Timber Harvest FEIS 

Unit of Measure 

Comparison of alternatives will include acres of inventoried roadless 

areas affected, percent of inventoried roadless areas affected, and the 

effects to the roadless values of each inventoried roadless area as 

identified in the 2003 Forest Plan SEIS. 

Issue statement: Road building, reconstruction and closures 

associated with the timber sale may change access within the project 

area. 

The construction and use of forest roads is the focus of much concern 

on both a national and local scale. Comments ranged from requesting 

no more new roads and closure of most existing roads to requests to 

increase access by new roads and opening more existing roads. 

Decisions made from the analysis in this EIS will include proposed 

road construction in each alternative (new construction and 

reconstruction), use of existing NFS roads, and the status of these 

roads after timber harvest. 

Roads influence wildlife populations, water quality, subsistence use, 

and the type of recreational opportunities available. Concerns were 

also expressed over the ability to maintain open roads. The District 

will look at road management objectives across the district, including 

the entire Kake Road System during the Petersburg Ranger District 

Access and Travel Management Environmental Assessment (PRD 

ATM EA). Recommendations for roads not associated with the 

proposed activities have been carried forward and analyzed through 

the District’s ATM by 2009. 

Units of Measure 

Comparison of alternatives will include miles of road (NFS and 

temporary) constructed, miles of reconstructed road, miles of road to 

be left open, miles of road to be closed associated with timber harvest 

activities, miles of new NFS and temporary road to be constructed in 

inventoried roadless areas, cost of maintenance for open roads, 

reconstruction, and new (NFS and temporary) road construction. 

Comments on Other Resources 

Each comment received during scoping was considered a potential 

issue. Some concerns and suggestions brought up by the public were 

considered but determined not to be alternative-driving issues. Some 

of these issues are already addressed through other processes or in the 

Forest Plan, through protection via Forest Plan Standards and 

Guidelines or through LUD designations (see Design Criteria 

Common to All Action Alternatives in Chapter 2 and unit cards in 

Issue 3- Road 

Management/ 

Access 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 21 

Appendix B), or their resolution is beyond the scope of this project. 

Where possible, suggestions about the Central Kupreanof Timber 

Harvest project were incorporated into the design of the Proposed 

Action and alternatives (see Chapter 2 of this FEIS). Some concerns 

and suggestions for the analysis of the timber sales were considered 

but eliminated from detailed analysis for the reasons listed below. 

Issues considered further but eliminated from detailed analysis are 

discussed in Chapter 2 of this FEIS under the heading- Alternatives 

Considered but Eliminated from Detailed Analysis. 

The following issues were considered but determined not to be 

alternative driving issues. The rationale for why these issues were 

determined to be non-significant is included below. As needed, 

resource effects related to these concerns are discussed in Chapter 3. 

Comments expressed concerns about the impacts of harvest and road 

building in the headwaters of the Castle River watershed; and of 

timber harvest and road building on fisheries and hydrological 

functions in general. Ultimately, proposed harvest units and road 

building would affect less than one percent (0.3%) of the headwaters 

of this watershed. 

Particular concerns were expressed about cumulative effects of such 

proposed activities in project area watersheds. Currently, there are no 

watersheds that require a watershed analysis as described in Appendix 

C of the Forest Plan. In fact, very little harvest has taken place in any 

watershed within the project area (Hamilton has had the most past 

harvest with 5.1% affected). Also, the project unit pool is spread out 

across the project area and doesn’t propose any concentration of 

harvest in any one watershed. 

Impacts to recreation opportunities are expected to be minimal with 

the proposed action and therefore recreation is not a significant issue. 

Local residents have expressed concern for the possible effects timber 

harvest may have on wildlife and, in particular, on deer habitat. An 

alternative was looked at that responded to deer habitat concerns but 

eliminated from further study because estimated effects on deer habitat 

within the project area were minimal. 

Design elements of the deer habitat alternative were brought forward 

into the proposed action. Specifically, units in areas of concentrated 

past and proposed harvest were dropped or prescribed with 50 percent 

retention to facilitate potential travel corridors. Also, units were 

dropped to promote additional connectivity between small old growth 

reserves. In response to the reduction of volume, additional units with 

no deer habitat or wildlife issues were added to the proposed action. 

Fisheries/ 

Hydrology/ 

Watersheds 

Recreation 

Wildlife 
1 Purpose and Need 

22  Chapter 1 Central Kupreanof Timber Harvest FEIS 

This issue is addressed in the Forest Plan and through the No Action 

Alternative. The majority of the Project Area is allocated to the 

Timber Production LUD, where timber harvest is permitted. 

Current levels of timber harvest on the Tongass are not expected to 

have an adverse affect on the quantity or composition of cedar (or any 

species) in the future. In many cases where single tree selection or 

two-aged management is applied, the amount of residual cedar left is 

proportional to the amount prior to harvest. Since both cedars are 

shade intolerant, overstory removal of hemlock could release cedar if 

advanced regeneration is present. Silvicultural treatments in young 

growth stands, such as precommercial thinning, pruning, and 

commercial thinning, typically emphasize release of cedars to maintain 

species composition and because they are valuable crop trees for future 

harvest. 

Initial field surveys show plants are not a significant issue. Rare and 

sensitive species will be considered and applicable Forest Plan 

direction applied to their protection. 

Socioeconomics is addressed through the Forest Plan and therefore is 

not a significant issue. Further, there are no permitted outfitter/guides 

within the project area and there hasn’t been for several years. 

Recreation, scenery, and subsistence concerns are routinely analyzed 

for projects. 

Subsistence was considered as an issue for this project. Upon further 

review of the field data and public comments, the concern with 

subsistence pointed more to hunter access and both increased and 

decreased access associated with the proposed road building and 

closures. Access has been identified as a Significant Issue. The use of 

the PRD ATM process will address access for the larger Kake road 

system by 2009. 

Federal and State Permits, Licenses and 

Certifications 

Prior to implementation of the proposed timber sale, various permits 

need to be obtained from other Federal and State agencies. Some 

permits are already in place for the Central Kupreanof project; others 

would have to be obtained. 

No wetlands permits are necessary from the U.S. Army Corps of 

Engineers because roads built in wetlands are for silvicultural purposes 

and will follow the 33CFR 323 guidelines to avoid and minimize 

impacts to wetlands. 

No Timber 

Harvest 

Cedar 

Composition 

Plants 

Socioeconomics 

Subsistence 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 23 

A storm water discharge permit would be acquired by the timber sale 

contractor. A permit for Alaska Pollutant Discharge Elimination 

System (Section 402 of the Clean Water Act) is held by the US Forest 

Service. 

Permits will be needed from the Corps of Engineers and the State of 

Alaska if large amounts of fuel are stored in the project area for 

helicopter yarding. The timber sale contractor would acquire these 

permits. 

Applicable Laws and Executive Orders 

Shown below is a partial list of Federal laws and executive orders 

pertaining to project-specific planning and environmental analysis on 

Federal lands. While most pertain to all Federal lands, some of the 

laws are specific to Alaska. Disclosures and findings required by these 

laws and orders are contained in Chapter 3 of this FEIS. 

 Alaska Native Claims Settlement Act (ANCSA) of 1971 

 Alaska National Interest Lands Conservation Act (ANILCA) of 

1980 

 American Indian Religious Freedom Act of 1978 

 Archeological Resource Protection Act of 1980 

 Bald and Golden Eagle Protection Act of 1940 (as amended) 

 Cave Resource Protection Act of 1988 

 Clean Air Act of 1970 (as amended) 

 Clean Water Act of 1977 (as amended) 

 Coastal Zone Management Act of 1972 (as amended) 

 Endangered Species Act (ESA) of 1973 (as amended) 

 Executive Order 11593 (cultural resources) 

 Executive Order 11988 (floodplains) 

 Executive Order 11990 (wetlands) 

 Executive Order 12898 (environmental justice) 

 Executive Order 12962 (aquatic systems and recreational 

fisheries) 

 Executive Order 13007 (Indian sacred sites) 
1 Purpose and Need 

24  Chapter 1 Central Kupreanof Timber Harvest FEIS 

 Executive Order 13112 (Invasive plant species) 

 Executive Order 13175 (government-to-government 

consultation) 

 Executive Order 13443 (hunting heritage and wildlife 

conservation) 

 Forest and Rangeland Renewable Resources Planning Act 

(RPA) of 1974 (as amended) 

 Magnuson-Stevens Fishery Conservation and Management Act 

of 1996 

 Marine Mammal Protection Act of 1972 

 Migratory Bird Treaty Act of 1918 (amended 1936 and 1972) 

 Multiple-Use Sustained-Yield Act of 1960 

 Native American Graves Protection and Repatriation Act 

(NAGPRA) of 1990 

 National Environmental Policy Act (NEPA) of 1969 (as 

amended) 

 National Forest Management Act (NFMA) of 1976 (as 

amended) 

 National Historic Preservation Act of 1966 (as amended) 

 National Transportation Policy (2001) 

 Organic Act of 1897 

 Rivers and Harbors Act of 1899 

 Tongass Timber Reform Act (TTRA) of 1990 

 Wild and Scenic Rivers Act of 1968, amended 1986 

Under the Coastal Zone Management Act (CZMA), coastal states may 

develop coastal management plans, subject to approval by the 

Secretary of Commerce. Upon approval, Federal agency activities that 

affect any land or water use or any natural resource of the state's 

coastal zone must be consistent, to the maximum extent practicable, 

with the enforceable policies of the state's coastal management plan. 

The Alaska Coastal Management Plan (ACMP) has been approved by 

the Secretary of Commerce. If a Federal agency determines that an 

activity in Alaska has coastal effects, it must evaluate the activity for 

consistency with the applicable enforceable policies of the ACMP, and 

submit a consistency determination to the State for review. To make 

the process more efficient, categories of activities may be evaluated 

State of Alaska 
 Purpose and Need 1

Central Kupreanof Timber Harvest FEIS Chapter 1 25 

and reviewed together under what is called a "general consistency 

determination" (GCD). Upon approval of a GCD, activities within that 

category do not require an individual consistency determination or 

review. The Forest Service has developed a GCD for timber harvest 

activities conducted on the Tongass National Forest, and the State of 

Alaska has agreed that Tongass timber harvest activities are consistent 

to the maximum extent practicable with the enforceable policies of the 

ACMP. The timber harvest activities, including associated use and 

construction of roads and use of the Little Hamilton permitted LTF, 

proposed in the Central Kupreanof Timber Harvest EIS fall within the 

scope of the GCD. 

Due to limits on the types of activities that qualify for a GCD, and 

provisions of the Alaska Forest Resources and Practices Act (FRPA), 

certain activities are outside the scope of the GCD and will continue to 

require individual ACMP consistency review. The GCD does not 

apply to any activity that requires a State or Federal authorization 

under any authority other than FRPA. Nor does it apply to any activity 

related to the planning, construction modification, or removal of any 

structure or facility intended for use by the general public. 

Specifically, it does not apply to logging camps or construction of log 

transfer facilities that require State or Federal permits, or to 

construction or reconstruction of roads that require such non FRPA 

permits. Any Tongass timber sale that involves activities not covered 

by the scope of the GCD continues to require an individual 

consistency determination if those activities have reasonably 

foreseeable effects on coastal uses or resources, but the scope of that 

determination and consistency review will be limited to those portions 

of the project not covered by the GCD. 

The Projects Common to all Action Alternatives are considered 

outside the scope of the GCD. However, in consultation with the State 

it has been determined these activities, except the potential removal or 

fixing of red fish crossings, do not affect the coastal zone and do not 

require any individual ACMP consistency determination or review. 

Implementation of potential red fish crossing work is dependent upon 

road management decisions made during the PRD ATM process, and 

will go through its own ACMP review and consistency determination. 
1 Purpose and Need 

26  Chapter 1 Central Kupreanof Timber Harvest FEIS 

Availability of the Project Record 

An important consideration in preparation of this FEIS has been 

reduction of paperwork as specified in 40 CFR 1500.4. In general, the 

objective of the EIS is to furnish enough site-specific information to 

demonstrate a reasoned consideration of the environmental impacts of 

the alternatives and how these impacts can be mitigated. The project 

record contains supporting material that documents the NEPA process 

and analysis from the beginning of the project to the publication of the 

Final EIS. The project record is located at the Petersburg Ranger 

District office in Petersburg, Alaska. Reference documents, such as the 

Forest Plan and the Tongass Timber Reform Act, are available for 

review at public libraries and Forest Service offices throughout 

Southeast Alaska, including the Petersburg Ranger District. The Forest 

Plan is available on CD-ROM and on the Internet 

(http://www.fs.fed.us/r10/tongass/). 
 

Chapter 2 

Alternatives 
Chapter 2 

Table of Contents

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

Development of the Proposed Action ................................................... 2 

Development of Alternatives ................................................................ 2 

Changes Made Between Draft and Final EIS ....................................... 3 

Alternatives Considered in Detail ......................................................... 5 

Identification of the Preferred Alternative ............................................ 6 

Design Criteria Common to all Action Alternatives ............................. 6 

Mitigation Measures ............................................................................. 7 

Stewardship Contracting ....................................................................... 8 

Projects Common to all Action Alternatives ........................................ 8 

Alternatives Considered but Eliminated from Detailed Study ........... 10 

Monitoring .......................................................................................... 13 

Comparison of Alternatives ................................................................ 15 
Central Kupreanof Timber Harvest FEIS Chapter 2 1

Chapter 2

Alternatives 

Introduction 

This chapter describes and compares the alternatives considered by the 

Forest Service for the Central Kupreanof Timber Harvest project to 

meet the Purpose and Need and to respond to the Significant Issues as 

described in Chapter 1. It includes a description and map of each 

alternative. The following topics are discussed: 

 The development of the Proposed Action and alternatives, 

 A description and map of each alternative considered in detail, 

 An overview of design elements 

 A comparison of the alternatives focusing on the evaluation 

criteria for the Significant Issues, 

 Alternatives eliminated from detailed study, and 

 Mitigation, other proposed projects, and monitoring 

This chapter presents the alternatives in comparative form to inform 

the public and other agencies, and to provide a basis for a decision by 

the responsible official (40 CFR 1502.14). For a complete discussion 

of the effects used to compare alternatives, consult Chapter 3, 

“Affected Environment and Environmental Consequences.” 

A Logging System and Transportation Analysis (LSTA) was 

developed to include all suitable commercial forest land as identified 

by the National Forest Management Act and the Forest Plan. From 

that LSTA, potential timber harvest units were identified. These units 

were field-verified to ensure their suitability, to identify any concerns, 

and to determine which silvicultural prescriptions would be feasible. 

In response to the Significant Issues and comments received during 

scoping, a No-action alternative, the Proposed Action, and two other 

action alternatives were developed. Other alternatives were 

considered but dropped from detailed analysis. The development of 

the alternatives led to deferring several potential timber harvest units 

from further consideration at this time. 
2 Alternatives 

2  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Development of the Proposed Action 

The initial unit pool was designed to harvest approximately 40 MMBF 

(estimated from sawlog volume). Preliminary field exams revealed 

much lower volume than expected. Possible units were added to the 

unit pool and a second public involvement letter went out recognizing 

the project could harvest up to 80 MMBF through the development of 

alternatives. 

Units that did not meet Forest Plan Standards and Guidelines (when all 

the Best Management Practices, project design and mitigations were 

included) were eliminated from the unit pool. The proposed action 

was adjusted to include the remaining second round units and better 

respond to timber economic concerns while remaining within the 

scope of the original proposed action. 

During the development of alternatives, a preliminary deer habitat 

alternative was developed. In comparison, there were few differences 

between this alternative and the proposed action. Design elements of 

the deer habitat alternative were brought forward into the proposed 

action and the deer habitat alternative eliminated from further study. 

Specifically, units in acres of concentrated past and proposed harvest 

were dropped or prescribed with 50 percent retention to facilitate 

potential travel corridors. Also, units were dropped to promote 

additional connectivity between small old growth reserves. In 

response to the reduction of volume, additional units with no deer 

habitat or wildlife issues were added to the proposed action. 

Development of Alternatives 

A group of resource specialists, making up the Interdisciplinary Team 

(IDT), considered varied alternatives to the Proposed Action to 

provide a reasonable range of options for meeting the purpose of this 

project. Alternatives were designed to address the issues identified 

during scoping (See Chapter 1). They were also designed to meet 

Forest Plan Standards and Guidelines (2008 Forest Plan) and 

applicable laws. Each action alternative represents a site-specific 

proposal developed through intensive interdisciplinary evaluation and 

field verification. Within the range of options they provide, the 

decision maker can consider various combinations of alternatives in 

determining the Selected Alternative. 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 3

Changes Made Between Draft and Final 

EIS

 Stream and crossing information on the Road Cards in 

Appendix B were corrected with field data or gaps identified 

and criteria disclosed. A correction from 61 red fish crossings 

to 54 crossing occurs in the FEIS due to more recent road 

maintenance information. Also, based on available stream 

information, short span log stringer or modular bridges were 

recommended to reduce effects on some stream channels 

(including Class III streams). Prior to actual construction of 

roads and stream crossings, final locations, structure types and 

design will be completed. All applicable Forest Plan Standards 

and Guidelines, Forest Service manual and handbooks, best 

management practices and the MOUs with Alaska Department 

of Fish and Game (when applicable) will be incorporated 

during design, construction and maintenance of roads. 

 In response to concerns about the red crossings within the 

project area, an upstream assessment of fish habitat was 

completed and is included in the FEIS Aquatics section. 

Consequently, the number of red fish crossings was updated. 

This analysis supports the original DEIS analysis. 

 Field methods were better documented for several resources 

including aquatics and transportation. 

 A more detailed discussion of effects to stream flows is also 

included in the FEIS. 

 Road densities were calculated at multiple scales and included 

in the analysis. 

 In document discussions, corrections were made to the road 

numbers and miles of currently open NFS roads that would be 

closed with this project. Road cards, maps and related road 

numbers were correct in the DEIS. 

 The timber sale economics and supply analysis was updated 

due to the use of NEAT_R version 2.15 as well as a better 

description of the small sales available and greater flexibility in 

the larger volume alternatives. 

 The wildlife section was updated to include a more complete 

discussion of the rationale for choosing POG as the unit of 

measure and method of analysis. 

 The Subsistence section was updated to include better 

information on use areas, preferences, access, and use of 

multiple subsistence resources. 
2 Alternatives 

4  Chapter 2 Central Kupreanof Timber Harvest FEIS 

 The cumulative effects analysis for POG within multiple 

WAAs was updated to exclude the Threemile Timber Harvest 

units as the decision for this project was vacated. 

 Updates to the Region 10 Sensitive Species List (2009) were 

noted in the sensitive plants section. However, the Central 

Kupreanof project is exempt from applying the 2009 revisions 

due to the project’s advanced stage when the list was approved 

and signed. The difference would be fewer effects to sensitive 

species in the area with the revisions since the two known 

species were removed from the list and none of the new species 

were found in the project area. 

 The Yellow-billed loon was added as a Federal Candidate 

Species; the Black oystercatcher and Aleutian Tern were added 

to the Sensitive Species list, and evaluated in the analysis for 

the FEIS. 

 Biological Evaluations have been published in this FEIS in 

Appendix E. 

 The total acres affected for Rocky Pass IRA was corrected. 

 On May 28, 2009, the USDA Secretary reserved decision 

making authority over the construction and reconstruction of 

roads and the cutting, sale or removal of timber in Inventoried 

Roadless Areas. This project will be sent to the Secretary of 

Agriculture for review. 

 The acres of detrimental soil conditions caused by temporary 

road construction were underestimated for all action 

alternatives. The increase, however, did not change the 

percentage of the harvest area affected. 

 The miles of reconstructed, temporary and system roads 

crossing wetlands were underestimated for all action 

alternatives, as well as the existing condition of system roads 

crossing wetlands. The underestimation was by a factor of 

three due to a unit conversion error. This does not change the 

conclusion regarding the cumulative effects of roads crossing 

wetlands. 

 The Southeast Alaska Conservation Council (SEACC) 

submitted an alternative for consideration after the 45 day 

comment period for the DEIS was over. The alternative was 

considered but not carried forward (see page 2-11 for more 

discussion). 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 5

 Additional information and minor corrections were added, 

where appropriate, as requested through comments on the 

DEIS. 

Alternatives Considered in Detail 

The No-Action Alternative (Alternative 1), Proposed Action 

(Alternative 2) and two other action alternatives (Alternatives 3 and 4) 

are considered in detail in this chapter. Alternatives 3 and 4 provide 

alternate means of satisfying the Purpose and Need for this project 

than does the Proposed Action. They respond differently to the 

significant issues that are discussed in this chapter. Maps of all 

alternatives considered in detail are provided at the end of Chapter 2. 

The map for Alternative 1, the No-action Alternative, represents the 

current condition of the project area (See Figures 2-1 through 2-4, at 

the end of this chapter, for maps of each alternative. Larger-scale 

maps of the alternatives are contained in the project record.) 

This alternative represents the existing condition against which the 

other alternatives are compared. 

Alternative 1 proposes no new timber harvest or road construction in 

the Central Kupreanof project area at this time. It does not preclude 

future timber harvest or other activities from this area. The Council on 

Environmental Quality (CEQ) regulations (40 CFR 1502.14d) requires 

that a “No Action” alternative be analyzed in every EIS. 

Alternative 2 is the Proposed Action and was designed to meet the 

Purpose and Need for this project, and to address concerns related to 

timber economics and deer habitat. It would offer up to 46.8 MMBF 

(sawlog and utility) of timber from 2,506 acres. It would consist of 

2,031 acres (81%) that would be clearcut (CC), 33 acres (1%) that 

would be clearcut with reserves (CCR), and 442 acres (18%) that 

would be uneven-aged management. There would be 7.3 miles of new 

NFS roads constructed, 2.9 miles of reconstructed road, and 3.9 miles 

of temporary road construction to access timber. 

Alternative 3 would provide the largest amount of volume of all the 

alternatives. It proposes harvesting 70.2 MMBF (sawlog and utility) 

from 3,647 acres. It would consist of 3,127 acres (86%) that would be 

clearcut (CC), and 520 acres (14%) that would be uneven-aged 

management. This alternative proposes helicopter yarding for those 

units where access by road construction is not feasible. Ground based 

systems and associated road construction are analyzed for this 

alternative. There would be 25.1 miles of new NFS roads constructed, 

9.1 miles of reconstructed road and 6.1 miles of temporary road 

constructed. 

Alternative 1 

(Figure 2-1) 

Alternative 2 

(Figure 2-2) 

Alternative 3 

(Figure 2-3) 
2 Alternatives 

6  Chapter 2 Central Kupreanof Timber Harvest FEIS 

This alternative would respond to maximizing timber harvest 

opportunity while meeting Forest Plan Standards and Guidelines. It 

addresses the timber economics issue by maximizing the proposed 

volume available and would allow the Forest Service the flexibility to 

respond to current and future market demands. 

Alternative 4 was developed in response to public concerns about the 

impacts of increased access, timber harvest, and road building on 

inventoried roadless area characteristics. This alternative offers the 

lowest amount of volume at 28.2 MMBF (sawlog and utility) from 

1,327 acres. All units would be clearcut (CC). There would be no 

new NFS road construction; 2.6 miles of road would be reconstructed 

and 2.2 miles of temporary road construction. 

Alternative 4 addresses all of the significant issues to some extent. It 

does not propose harvest and road building within the boundary of any 

Inventoried Roadless Area, although there would be effects to the zone 

of influence. Harvest would be limited to units in close proximity to 

existing roads. No new NFS roads and 2.2 miles of temporary road 

are proposed, which addresses concerns related to increased access. 

Less road building results in shorter haul distances which also satisfies 

timber economics concerns related to today’s market, but does not take 

into account the need for flexibility in the long term. 

Identification of the Preferred Alternative 

In the DEIS, alternative 3 was identified by the interdisciplinary team 

as the Preferred Alternative and approved by the Forest Supervisor. 

This was based on the environmental analysis and public and agency 

comments received to date at that time. The Responsible Official may 

select this alternative, another alternative, or a modification of one of 

the alternatives. 

Design Criteria Common to all Action 

Alternatives 

All alternatives are consistent with the 2008 Tongass Land and 

Resource Management Plan (Forest Plan). All applicable Forest Plan 

Standards and Guidelines have been incorporated into the design of the 

proposed units and alternatives. While some alternatives have been 

designed to provide a greater measure of protection than is required by 

the Forest Plan for some resources, such as additional consideration 

for potential wildlife travel corridors, all alternatives were designed to 

meet Forest Plan Standards and Guidelines for these and all other 

Alternative 4 

(Figure 2-4) 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 7

resources. Additional direction comes from applicable laws and Forest 

Service manuals and handbooks. A complete collection of sitespecific descriptions and resource considerations for each potential 

harvest unit (unit and road cards) were published in Appendix B of the 

DEIS. In this FEIS road cards can be found in Appendix B, and the 

unit cards associated with the selected alternative are located in 

Appendix 2 of the ROD. These cards serve as the prescription or 

design narrative for the project as well as detail design elements for the 

construction and reconstruction needed for existing National Forest 

System roads. 

Temporary (or NFS) roads were proposed in all units where shovelyarding distances exceeded 500 feet to provide a surface for log 

hauling. Temporary road locations on the maps are estimated. 

Temporary road locations are subject to approval by the Forest 

Service. Temporary road decommissioning will be part of the timber 

sale contract. 

Road closures will occur up to ten years after the completion of timber 

harvest. Road closure, storage and decommissioning are described in 

the Road Management/Access section in Chapter 3 and in the Glossary 

of Chapter 4. 

Existing rock quarries may be expanded or new rock quarries may be 

developed to support new road construction and maintenance. Quarry 

sites would be developed within 500 feet of a road and avoid Class I 

and Class II stream buffers, old-growth habitat reserves, eagle and 

goshawk nest tree buffers, and non-development LUDs. With either 

the expansion of an existing quarry or the development of a new site, 

the area footprint would not exceed five acres. 

Prior to quarry development a Site Development Plan will be reviewed 

and approved by resource specialists and the District Ranger. 

No land camp is proposed in the project area for any of the 

alternatives. The town of Kake or a floating camp could be used 

during harvest activities. Appropriate permits would need to be 

acquired by the operator for use of a floating camp. 

Mitigation Measures 

The analysis documented in this EIS discloses the possible adverse 

effects that may occur from implementing the actions proposed under 

each alternative. Many of these effects are reduced or avoided by 

using Forest Plan direction, including management prescriptions, 

Standards and Guidelines, and Best Management Practices (BMPs), 

which meet the requirements of the Clean Water Act. All unit-specific 

and/or alternative-specific mitigation is identified in Appendix B. 

Roads 

Rock Quarries 

Logging Camp 
2 Alternatives 

8  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Stewardship Contracting 

In developing the projects common to all action alternatives, the 

District considered the potential of using stewardship contracting with 

proposed timber harvest activities. The District worked with Kake to 

identify projects where existing equipment and infrastructure could be 

used to accomplish the work. Funding for project contracting may 

come from a combination of timber receipts and other appropriated 

dollars. The receipts from the value of the timber could be used to 

finance the contractual requirements, and a priority listing of the 

project area activities could be included in the contract. These projects 

would either be accomplished as part of the contract or independently. 

There would be a list of mandatory projects to be completed with 

timber receipts, combine with the possibility of using other 

appropriated dollars available at the time to maximize the number of 

project completed. 

Projects Common to all Action Alternatives 

The following projects were identified by the Interdisciplinary Team 

as possible stewardship opportunities within the project area. These 

projects are not design criteria or mitigation measures to reduce the 

effects of the alternatives, but could be used to improve or enhance 

resources or to complete obligations within the project area. These 

projects are common to all action alternatives and are suitable for 

potential stewardship contracting opportunities. 

See Figure 2-5 for more information regarding Projects Common to 

All Action Alternatives. 

During this project, the Roads Analysis Process (RAP) was updated 

and recommendations for road management objectives for the entire 

Kake road system were made. Recommendations for roads not 

associated with the proposed timber harvest activities have been 

incorporated into the Petersburg Ranger District Access Travel and 

Management Plan Environmental Assessment (EA). Roads identified 

for closure include roads with red fish crossings. Ultimate closure of 

those roads will depend on the decision made from that EA (expected 

in 2009). Implementation of road closures would result in the removal 

of culverts that do not meet fish passage standards and could be 

accomplished through stewardship contracts associated with an action 

alternative. 

Maintain the four recreational hiking trails in the area: Cathedral Falls 

(0.5 mi.), Goose Lake (0.75 mi.), Hamilton Creek (1.0 mi.), and Big 

John Bay (1.75 mi.). The total length of all trails combined is about 

Fisheries/ 

Hydrology 

Recreation 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 9

four miles. The work could include annual brushing, condition 

surveys and replacement of gravel as needed. Structure work on the 

trails could also be included depending on the extent and difficulty of 

the work. Gravel for trail maintenance in the past has been obtained 

locally in Kake. 

Conduct annual maintenance for the Big John Bay Cabin including 

preparing it for occupancy in the spring and winterizing it at the end of 

the season. In addition, deferred maintenance and repairs could also 

be considered for this project. The cabin can be accessed by hiking the 

1.75-mile trail off Road 45001or by boating to Big John Bay. 

Hand-pull a small population of spotted knapweed located on the 6337 

Road. Work could involve up to a half-day of work annually for at 

least five years and possibly monitoring and/or hand-pulling beyond 

that depending on how well the plants respond to hand-pulling. Proper 

disposal of the pulled weeds would be specified as part of the project 

design, most likely burning in a controlled manner. Other roadside 

weed populations could also be included, if new populations are 

discovered. 

Currently there are 325 acres of precommercial thinning to accomplish 

in second growth stands that could potentially be done under a 

stewardship contract on the Kake road system. These stands are 

approximately 25 years old. Thinning prescriptions would use 

traditional thinning methods, and may vary to include spacing from 14 

x 14 to 18 x 18 feet. Thinning in these stands would also benefit 

wildlife as it would provide cover and allow side lighting to reach the 

forest floor. (See Figure 2-5) 

There are approximately 114 miles of Forest Service System roads in 

the Kake road system, which encompasses the Central Kupreanof EIS 

project area. Of those 114 miles of roads there are approximately 94 

miles of open roads that need maintenance to remain open. This 

maintenance generally includes brush cutting, blading of the road 

surface, ditching and cleaning of culverts to keep proper drainage. Of 

the 94 miles of open road there are approximately 38 miles of mainline 

roads (6040, 6328, 6314, 6314S) that take first priority for 

maintenance. 

Petersburg Ranger District historically has approximately $70,000 per 

year to spend on road maintenance in Kake. On the average it costs 

$2,000 per mile to maintain roads, which equates to 35 miles of road 

per year that can be done in Kake. Generally, two thirds of the 

mainline roads are done and the remaining portion is spent on selected 

side roads. 

A Microsale is a timber sale consisting of dead or down timber which 

has been proposed by a prospective purchaser, and the District Ranger 

agrees to offer for bidding using an informal advertisement and short 

bid form. The maximum size of a Microsale would be 50 MBF. 

Invasive Plants 

Silviculture/ 

Wildlife 

Transportation 

Microsales 
2 Alternatives 

10  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Microsales are generally associated with a small number of trees. Dead 

or down trees within a distance of approximately 200 feet from one of 

the listed roads, and are harvestable under Forest Plan (2008) 

Standards and Guidelines, may be eligible as a Microsale opportunity 

within the project area. 

On site evaluation will be conducted when trees have been identified 

for Microsale opportunities. For all action alternatives, Microsales 

authorized by the District Ranger would be allowed to occur along 

NFS roads 6040, 6314, 6314S, 6326, 6328, 6334, 6336, 6339 and 

6367. 

Alternatives Considered but Eliminated from 

Detailed Study 

Individual resources were considered in identifying significant issues. 

Chapter 1 “Other Issues and Concerns” explains how these resources 

were considered and the rationale for eliminating them as issues that 

would drive alternatives. Several alternatives were considered during 

the planning process, but have not been included in this EIS for 

detailed study. These are described briefly below, along with the 

reasons for not considering them further. 

A few alternatives that addressed subsistence and deer habitat were 

developed. During the first round of alternative development using the 

original unit pool, the team discussed subsistence and deer habitat as a 

potential significant issue. Many comments indicated subsistence use, 

access, and deer were concerns. Units were rated using deer winter 

range data, the highest rated units being removed from the alternative, 

or prescribed for 50 percent retention. Potential travel corridors were 

also considered. This alternative was eliminated from further 

consideration when additional units were added to the unit pool. 

Two more alternatives around deer habitat were developed once the 

unit pool was finalized. Again higher rated units for deer habitat and 

units within potential travel corridors were avoided or prescribed 

retention. One alternative applied these elements to the proposed 

action; the other alternative applied these elements to the entire unit 

pool. Elements of the first alternative were incorporated into the 

proposed action and therefore this alternative was eliminated from 

further study. The later alternative was eliminated from further 

consideration because deer habitat was considered in the design of the 

proposed action. 

Subsistence/ 

Deer Habitat 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 11

An alternative for timber supply and sale economics was developed 

from the first unit pool. This alternative concentrated on the least 

amount of road building and the best economics of “today” as 

identified by the financial efficiency analysis. This alternative was 

eliminated from further study since elements of this alternative were 

ultimately incorporated into the development of Alternative 4. 

While carried forward as a Significant Issue, several preliminary 

alternatives were developed to respond to Inventoried Roadless Area 

concerns. 

Using the initial unit pool, an alternative was developed that avoided 

Inventoried Roadless Areas completely, at times cutting settings and 

units in half. The alternative proposed only to build roads and harvest 

units that were within the 600-foot buffer of existing units and 1,200-

foot buffer of existing roads. The volume estimated was about 18 

MMBF. It estimated no new miles of system road and 13 miles of 

temporary roads. It was eliminated due to low volume, high costs, and 

effects to future timber management opportunities; it did not meet the 

purpose and need. 

A second alternative was developed at this time that minimally 

impacted Inventoried Roadless Areas (approximately 565 acres would 

have been affected). Existing unit boundaries were considered as well 

as those in close proximity to roaded areas. The alternative proposed 

to build road and harvest units that were within the 600-foot buffer of 

existing units and 1200 foot buffer of existing roads, and some units 

that were not more than 1500 feet outside the buffers. It offered about 

30 MMBF with approximately 12-19 miles of new road. It was 

eventually eliminated from further study when the unit pool changed. 

Alternative 4 was developed to addresses the issue of Inventoried 

Roadless Areas. 

An alternative designed to supply small mills would not meet the need 

to provide an economics reliable supply of timber to a forest products 

industry which includes processing facilities and timber sale 

purchasers of varying size and capacity. Such an alternative would not 

meet the need to provide an adequate supply for the larger mills of 

Southeast Alaska industry. Each action alternative in the Central 

Kupreanof project includes many harvest units suitable for small 

timber sale offerings. The timber volume in any action alternatives 

could be separated administratively into timber sales of varying size 

and complexity. Please see the “Opportunities for Small Sales” 

section in Chapter 3. 

SEACC submitted a proposal called the “Community Alternative” in 

May 2008. At this point, the IDT was responding to comments to the 

DEIS made during the 45-day comment period and finalizing resource 

reports for the FEIS. SEACC acknowledged the timing of their 

submittal could problematic for inclusion in the FEIS. 

Timber Supply 

and Sale 

Economics 

Inventoried 

Roadless Areas 

Microsale and 

Small Sale 

Community 

Alternative 
2 Alternatives 

12  Chapter 2 Central Kupreanof Timber Harvest FEIS 

The Community Alternative was based on the Alternative 4 in the 

DEIS and in brief review, compared similar to most resource effects 

disclosed for Alt 4. The unit and roads in this alternative are the same 

as Alternative 4: however, the silvicultural prescriptions for several 

units were modified to retain more stand structure. The Community 

Alternative would allow about 20 million board feet of timber to be 

harvested on 1,326 acres but would ration this timber volume out at 

200 mbf per year to support local mills in Kake. In addition, younggrowth management would occur on an equal amount of acres. For 

access to this timber, 2.2 miles of temporary roads would be 

constructed but no National Forest System roads. 

In addition to timber harvest, this alternative includes the following 

stewardship projects: 

 Replacement of all red fish crossings within the project area 

 Decommission roads 45808 and 45906 after thinning 

 Road maintenance, repair, and decommissioning 

 Thinning and capture of thinning product with fish waste for 

fertilizer 

 Production of blueberries in gapped stands 

The Community Alternative was considered but eliminated from 

detailed study and inclusion in the FEIS. When the Community 

Alternative was compared to those alternatives that were already 

analyzed, the Community Alternative was found to be very similar in 

many ways to Alternative 4. Furthermore, some of the proposed 

measures to reduce impacts on deer habitat were considered in 

Alternative 2. It therefore does not respond any differently to Issues 2 

and 3 (Inventoried Roadless Areas and Road Management/Access) as 

Alternative 4 does. 

Regarding Issue 1, the Community Alternative improved timber 

economics by adding or increasing retaining more stand structure in 

harvest units. The financial efficiency analysis used information from 

recent bids on microsales and small sales. As stated in the SEACC 

letter, most of this data on microsales came from Prince of Wales 

(POW) Island, involved no road construction (even temporary road 

construction), and eliminated barging costs. Also, the timber on POW 

is generally of higher quality than in the Central Kupreanof project 

area. The Central Kupreanof project used NEAT-R, which is based on 

the Residual Value method and uses cost collection data. Therefore, it 

is hard to compare alternatives; however, the Forest Supervisor can 

consider retaining more stand structure in making his decision, as 

uneven-aged management is considered in Alternatives 2 & 3. 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 13

In addition, the Community Alternative uses an implementation 

strategy that would limit annual harvest. While the Forest Supervisor 

could consider such an implementation strategy in making his 

decision, the tradeoffs would also need to be considered. The Forest 

Supervisor must consider a volume that is large enough to amortize the 

cost of mobilization and offer a potential for profit to purchasers. By 

limiting yearly harvest, non-local or larger operators in Southeast 

would likely be excluded from this project area’s timber supply. He 

would also need to consider the concerns of small mill owners who 

have discussed the difficulties of harvesting, processing materials and 

marketing products from the small sales purchased. 

Many of the Community Alternative specific design elements are 

addressed through Projects Common to All Alternatives in this 

document, like fisheries/hydrology projects, invasive species, wildlife 

thinning, and road maintenance. Other parts are included in the 

Petersburg Ranger District’s ATM EA, the District’s programmatic 

thinning schedules and road maintenance schedules, special uses, 

and/or the Forest’s prioritization for the replacement/repair/removal of 

red fish crossings, as disclosed for all alternatives in the both the DEIS 

and FEIS. 

Because the Community Alternative was so similar to Alternative 4 

and did not respond differently to the Significant Issues (was within 

the range of effects disclosed in the FEIS alternatives, including 

projects common to all alternatives), this alternative was considered 

but eliminated from further consideration. SEACC’s letter and 

alternative proposal are located in the project record. 

Monitoring 

Monitoring is a tool which involves gathering data and information 

and observing the results of management activities as a basis for 

evaluation. Monitoring activities can be divided into project-specific 

monitoring and Forest Plan monitoring. The National Forest 

Management Act requires national forests to monitor and evaluate 

their forest plans (36 CFR 219.110). Chapter 6 of the Forest Plan 

includes the monitoring activities to be conducted as part of the Forest 

Plan implementation. 

Forest Plan monitoring items are either contingent on management 

activities, such as those associated with this project, or are based on 

the condition of the Tongass National Forest as a whole. Much of the 

monitoring at the Forest Plan level consists of annually surveying a 

representative sample of harvest units or roads. 
2 Alternatives 

14  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Implementation monitoring is conducted at the project level. The 

selected management activities need to be consistent with the design 

criteria used to analyze the environmental effects during the planning 

stage. 

The IDT prepared unit and road cards to provide site-specific analysis 

and guidance for unit layout, road location during timber harvest, and 

road construction and road reconditioning needs. Unit cards include a 

unit map and a narrative explaining resource concerns and how the 

concerns could be addressed in the design of each unit. Road 

Management Objectives were developed for each NFS road (Road 

Cards, Appendix B). 

Staff members who prepare timber sale contracts are required to 

confirm and certify that the contract is in agreement with the decision 

document. This certification verifies that items such as maps, number 

of acres, location of units, harvest methods, and stand numbers are 

consistent. The certification also ensures that all mitigation measures 

identified in the EIS relation to timber sale contract requirements are 

included in the contract. 

Implementation monitoring continues through harvest and contract 

inspections. As a routine part of project implementation, sale 

administrators and road inspectors monitor harvest and construction 

activities. Through provisions contained in the timber sale contract or 

other contracts, contract administrators and inspectors ensure that the 

prescriptions contained on the unit and road cards are implemented. 

Sale administrators and road contract inspectors have the authority to 

initiate action to repair resource damage and suspend operations until 

problems have been corrected. This process ensures that project 

elements and Forest Plan Standards and Guidelines are implemented 

as designed. The Contract Administrators monitor all units and roads 

for implementation of the appropriate BMPs. 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 15

Comparison of Alternatives 

This section compares outputs, objectives and effects of the 

alternatives in terms of the Significant Issues for the Central 

Kupreanof Timber Harvest project. The discussions of effects are 

summarized from Chapter 3, which should be consulted for a full 

understanding of these and other environmental consequences. Table 

2-2 below provides an overview comparison of information from the 

alternative descriptions and Chapter 3 relevant to the issues. This 

information will be used in the discussions that follow. 

Optimizing volume and net return on timber harvest will provide for 

flexibility, in both the long and short term, for offering economically 

viable timber sales. 

While Alternative 3 proposes the greatest amount of NFS road and 

temporary road construction, it provides the Forest Service the most 

flexibility in sale packaging and the greatest ability to respond to 

future market conditions. It proposes the most volume at 

approximately 70 MMBF. 

Estimated logging and transportation costs would be $410 per MBF 

with road costs estimated to be $48 per MBF. The indicated bid is 

($129.16) per MBF. Between 234 and 332 direct annualized jobs 

would be supported in Alaska, providing an estimated $9.1 to $12.5 

million in direct income. 

Alternative 4 was developed in response to public concerns about the 

impacts of increased access, timber harvest, and road building on 

roadless area characteristics. Although this alternative proposes the 

lowest volume and the lowest flexibility in sale packaging, it has the 

highest indicated bid under current market conditions. It proposes 

only harvesting stands accessible from the existing road system or 

temporary roads and avoids building new National Forest System 

roads and helicopter yarding. Alternative 4 proposes the least amount 

of volume (28.2 MMBF) of all of the action alternatives. 

Estimated logging and transportation costs would be $353 per MBF 

with road costs estimated to be $17.00 per MBF. The indicated bid is 

($85.45) per MBF. Between 94 and 143 direct annualized jobs would 

be supported in Alaska, providing an estimated $3.6 to 5.0 million in 

direct income. 

Alternative 2 provides less flexibility than Alternative 3, but still 

provides more flexibility than Alternative 4. It builds the greatest 

amount of road after Alternative 3, and offers the second highest 

amount of volume with 46.8 MMBF. The estimated logging and 

transportation costs would be $374 per MBF with road costs estimated 

to be $18 per MBF. The indicated bid is ($86.42) per MBF. Between 

156 and 221 direct annualized jobs would be supported in Alaska, 

providing an estimated $6.1 to 8.3 million in direct income. 

Issue 1- Timber 

Supply/ Sale 

Economics 
2 Alternatives 

16  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Alternative 1 proposes no timber harvest. Timber needed to meet the 

estimated demand would have to be harvested from other areas on the 

Tongass National Forest. Jobs supported by this project and 

manufacturing would not be supported by this project. 

Timber harvest and building roads in inventoried roadless areas would 

reduce roadless acres within the project area and may affect roadless 

values. 

In all action alternatives, the roadless values would either remain 

unchanged or be minimally influenced by the proposed activities. 

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

Pass, and Castle Inventoried roadless areas would remain greater than 

5,000 acres in size and eligible for Wilderness consideration in 

subsequent forest planning. In all alternatives the Castle Roadless 

Area would be unaffected by timber harvest, road construction, 

buffers, or other associated activities. 

No changes to inventoried roadless acres or character would occur as a 

result of Alternative 1. 

Alternatives 2 and 3 include timber harvest within the boundaries of 

the North Kupreanof, South Kupreanof, and Rocky Pass Inventoried 

Roadless Areas. The predominant effect would be to the South 

Kupreanof Inventoried Roadless Area with approximately 341 acres of 

timber harvest and one mile of new NFS road in Alternative 2 and 

1,184 acres and 15 miles of road construction in Alternative 3. In 

comparison, the North Kupreanof Inventoried Roadless Area acres of 

harvest would vary from 90 acres in Alternative 2 to 152 acres in 

Alternative 3. No new roads are proposed within the North Kupreanof 

or Rocky Pass Inventoried Roadless Areas. Both Alternative 2 and 3 

propose three acres of timber harvest within the Rocky Pass 

Inventoried Roadless Area. 

Of the three action alternatives, Alternative 3 affects the most total 

inventoried roadless acres. Up to 5,273 acres would be treated as 

developed in the South Kupreanof Inventoried Roadless Area. The 

affected acres represent about two percent of the South Kupreanof 

Inventoried Roadless Area. 

Alternative 4 avoids timber harvest and road building within the 

boundary of inventoried roadless areas. However, the application of 

the 600 feet and 1,200 feet around harvest units and roads would 

overlap into the inventoried roadless area boundaries. Alternative 4 

affects the least total roadless acres of any action alternative. 

Issue 2- 

Inventoried 

Roadless Areas 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 17

Road building, reconstruction and closures associated with the timber 

sale may change access within the project area. 

Construction of new roads and closure of existing roads would affect 

motorized access. The proposed roads in each alternative are necessary 

to meet the purpose and need of the project because they provide 

access to the timber and provide transportation for timber to be hauled 

to a processing facility. Each alternative requires a different level of 

road construction thus having different levels of effects. 

Alternative 1 does not propose any new road construction. Under this 

alternative, current management plans would continue to guide the 

management of NFS roads. All system roads would be managed as 

directed by the Forest Plan, road management objectives, and previous 

NEPA decisions. Access would not increase or decrease for 

recreational or subsistence activities and maintenance would continue 

to be ongoing. 

Alternative 3 (construction of 25.1 miles new NFS road) would have 

the greatest increase for motorized public access to the area. 

Alternative 2 (construction of 7.3 miles new NFS road) would also 

increase motorized public access. Alternative 4 (no new NFS road 

construction) would not increase motorized public access. Any 

increase in new access will occur during the timber sale and for up to 

ten years after timber harvest completion. However, motorized access 

would then decrease as roads are closed and placed in intermittent 

service. Closed roads would still provide a long term increase for nonmotorized access. Alternative 2 and 3, by creating additional 

infrastructure, would enhance opportunities for future timber harvest. 

Alternative 3 reconstructs 9.1 miles of existing NFS road, Alternative 

2 reconstructs 3.9 miles of existing NFS road, and Alternative 4 

reconstructs 2.2 miles of existing NFS road. This reconstruction 

would increase current access. All reconstructed roads would be 

managed as a maintenance level 2, open to motorized vehicle traffic, 

during timber sale activities and up to ten years thereafter. However, 

motorized access would again decrease as these roads are closed and 

placed into intermittent service. 

Alternatives 3 and 4 close the most existing NFS roads (about 2.0 

miles) while Alternative 2 closes only slightly less miles at 1.1 miles 

of road. This will reduce motorized access and place roads in a 

condition that requires minimum maintenance to protect the 

environment and preserve them for future use. 

Issue 3- Road 

ManagementAccess 
2 Alternatives 

18  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Table 2-1. Comparison of Alternatives by Issues and Effects 

(Numbers may not add up to the totals shown due to rounding) 

Alt 1 Alt 2 Alt 3 Alt 4 

Issue 1- Timber Supply/Sale Economics 

Indicated Bid Value $/MBF 1 0 ($86.42)1 ($129.16) ($85.45) 

Logging/Transportation Cost $/MBF 0 $374.00 $410.00 $353.00 

Road Costs $/MBF 0 $18.00 $48.00 $17.00 

Temporary Road Miles 0 3.9 6.1 2.2 

NFS Road Miles 0 7.3 25.1 0 

Helicopter Sawlog Volume (MMBF) 0 3.0 3.4 0 

Ground Based Sawlog Volume (MMBF) 0 36.4 55.6 23.6 

Total Volume (sawlog and utility) 

(MMBF) 0 46.8 70.2 28.2 

Direct Jobs2 0 156-221 234-332 94-133 

Economic Flexibility Ranking N/A 2 1 3 

Issue 2- Inventoried Roadless Areas 

Acres of Timber Harvest within 

Inventoried Roadless Areas 0 434 1,339 0 

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

Miles of Temporary Roads within 

Inventoried Roadless Areas 

(decommissioned after harvest) 

0 0 2 0 

Total Acres Affected Including Buffers 

(600’ for harvest units, 1200’ for roads)3 0 1,255 5,709 140 

Percent of Inventoried Roadless Area 

Affected (includes Rocky Pass IRA, 

North Kupreanof IRA, and South 

Kupreanof IRA acres) 

0 0.3 1.5 <0.1 

1 Numbers in () indicate negative values

2 These jobs are shown as a range to account for export if approved by the Regional Forester (Based on number of job years. 

See Table 3-7). 

3 Helicopter units are not buffered.
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 19

Alt 1 Alt 2 Alt 3 Alt 4 

Issue 3- Road Management/Access 

Miles of Open Existing NFS Road before 

Harvest 64 64 64 64 

Miles of Proposed New NFS Road to be 

Constructed 0 7.3 25.1 0 

Miles of Proposed New Temporary Road 0 3.9 6.1 2.2 

Miles of NFS and Temporary Road to be 

Constructed in Inventoried Roadless 

Areas 

0 1 15 0 

Total Miles of Road Remaining Open 

after Implementation of each Alternative 64 62.3 62.3 62.3 

Miles of Existing NFS Road to be Closed 

after Harvest 0 1.69 1.69 1.69 

Miles of Reconstructed Existing Closed 

Road to Remain Open after Harvest 0 2.9 9.1 2.6 

Miles of Road to be Left Open for up to 

Ten Years after Harvest 64 74.2 98.2 66.6 

Total Road Cost for all New Temporary, 

New NFS, and Reconstructed Road 

within the Project Area4

$0 $2,039,000 $6,017,000 $416,000

Other Environmental Considerations 

Effects on Wildlife 

Acres of POG Harvested 0 2,427 3,568 1,261 

Percent Change from Current Condition 

(2008) within Project Area (57,628 acres 

of POG) 

0 4.2% 6.2% 2.2% 

Percent Change from Current Condition 

(2008) within Multiple WAAs (269,593 

Acres of POG) 

0 0.9% 1.3% 0.5% 

Percent Change from Current Condition 

(2008) within Biogeographic Province 

(307,710 acres of POG)

0 0.8% 1.2% 0.4% 

4 Includes maintenance costs
2 Alternatives 

20  Chapter 2 Central Kupreanof Timber Harvest FEIS 

Alt 1 Alt 2 Alt 3 Alt 4 

Percent Cumulative Reduction From 

Historic/Original Condition 

Biogeographic Province (431,217 acres of

POG) -29% -29.8% -30.2% -29.4% 

Percent Cumulative Reduction From 

Historic/Original Condition WAA (359,445 

acres of POG) 

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

Effects on Timber and Vegetation 

Total Acres Even-aged Management 

(Clearcut) 0 2,031 3,127 1,327 

Total Acres Two-aged Management 

(Clearcut with Reserves) 

0 33 0 0 

Total Acres Uneven-aged Management 

(Single-tree Selection) 0 442 520 0 

Total Acres of Harvest by all Silviculture 

Systems 0 2,506 3,647 1,327 

Effects on Soils 

Total Acres Soil Disturbance 42 167 299 93 

Acres of Very High Risk Hazard (MMI-4) 

Soils within Units 0 10 17 0 

Effects on Wetlands 

Total Miles of Road (Reconstructed, 

Temporary and NFS) Crossing Wetlands 0 2.83 7.06 1.17 

Effects on Heritage Resources None 

Effects on Scenery 

Percent of Past and Proposed Visual Disturbance by Viewshed 

Hamilton 5% 7% 7% 6% 

Big John Bay 15% 22% 23% 20% 

Rocky Pass 2% 3% 3% 2% 
Alternatives 2

Central Kupreanof Timber Harvest FEIS Chapter 2 21

Alt 1 Alt 2 Alt 3 Alt 4 

Upper Castle 2% 2% 4% 2% 

Upper Duncan 1% 2% 4% 1% 

Effects on Recreation No Significant Effects 

Effects on Hydrology/Fisheries 

30 year Cumulative Harvest Percentage by Alternative 

(Assuming a 2009 implementation date and that all proposed acres are harvested)

Hamilton Creek 1.9%5 5.3% 5.4% 4.6% 

McNaughton Point 2.9% 13.8% 14.5% 11.9% 

Big John Creek 4.5% 6.8% 7.1% 5.8% 

West Duncan Canal 0.4% 1.3% 2.5% 0.6% 

Keku Creek 0.2% 0.4% 0.4% 0.2% 

Castle River 1.3% 1.5% 2.7% 1.5% 

Tunehean Creek 1.2% 1.9% 1.9% 1.5% 

Total Number of Proposed Stream Crossings by Alternative 

Hamilton Creek 0 22 31 2 

McNaughton Point 0 14 14 1 

Big John Creek 0 6 13 1 

West Duncan Canal 0 5 43 0 

Keku Creek 0 4 4 0 

Castle River 0 4 29 4 

Tunehean Creek 0 4 5 0 

Total 0 59 139 8 

Total Number of New Class I Crossings 0 4 4 0 

Total Number of New Class II 

Crossings 0 5 12 4 

Effects on Sensitive Plants No 

Effects 

May impact individuals but is not 

likely to lead to a Federal listing 

Effects on Subsistence No Significant Effects 

5 Values indicated under Alternative 1 reflect cumulative percentages in 2009 assuming no timber harvest.
2 Alternatives 

22  Chapter 2 Central Kupreanof Timber Harvest FEIS 
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c:/workspace/ckupre/plots/deis/fig2_1_alt1.mxd 09-20-08 EP

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Central Kupreanof Timber Harvest

Figure 2-1

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c:/workspace/ckupre/plots/deis/fig2_2_alt2.mxd 09-20-08 EP

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Figure 2-2

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Figure 2-3

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Figure 2-4

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Legend

Pre-commercial/Wildlife Treatment

Non-national Forest

Trails

Existing Open Roads

Closed Road

Project Area Boundary

Stream Class I

#* Cabins

!( Red Pipes

!. Invasive Plant ±

0 1 2 4

Miles

Kake

Seal Point

Little Hamilton 

LTF

Big John

Bay

R

ocky

Pass

#* Devil's Elbow

Cabin

F r e d e r i c k S o u n d

Portage

Bay

Duncan Canal

Towers Arm

#* West Point

Cabin

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Salt Chuck 

East Cabin

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Castle Flats

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Lakes

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(Jamaica Lake)

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K u i u I s l a n d K u i u I s l a n d

K u p r e a n o f I s l a n d K u p r e a n o f I s l a n d

Goose Lake

Trail

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Hamilton CreekTrail

Central Kupreanof Timber Harvest

Figure 2-5

Projects Common to all Action Alternatives

Keku

Strait

Port

Camden

Threemile Arm

Keku Strait
Chapter 3 

Environment and 

Effects 
Chapter 3 

Table of Contents 

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

Timber Supply/Sale Economics .......................................................... 10

Inventoried Roadless Areas ................................................................ 25

Road Management/Access .................................................................. 41

Botany ................................................................................................. 58

Wildlife ............................................................................................... 72

Subsistence .......................................................................................... 99

Hydrology/Fisheries .......................................................................... 108

Timber and Vegetation ..................................................................... 140

Soils and Geology ............................................................................. 157

Wetlands ........................................................................................... 169

Scenery .............................................................................................. 180

Unroaded Areas ................................................................................ 193

Recreation ......................................................................................... 194

Heritage Resources ........................................................................... 207
 

Central Kupreanof Timber Harvest FEIS Chapter 3 1 

Chapter 3 

Environment and 

Effects 

Introduction 

This chapter provides information concerning the existing 

environment of the Central Kupreanof Timber Harvest (Project Area), 

and potential environmental consequences of the proposed action and 

alternatives to it. It also presents the scientific and analytical basis for 

the comparison of alternatives presented in Chapter 2. Each resource 

potentially affected by the proposed action or alternatives is described 

by its current condition and uses. 

Following each resource description is a discussion of the potential 

environmental effects to the resource associated with the 

implementation of environmental effects to the resource associated 

with the implementation of each alternative. All significant or 

potentially significant effects, including direct, indirect and cumulative 

effects, are disclosed. Effects are quantified where possible, and 

qualitative discussions are also included. The means by which 

potential adverse effects will be reduced or mitigated are described in 

Appendix B (see also the unit cards in the DEIS and road cards in 

Appendix B of this FEIS). 

The discussions of resources and potential effects take advantage of 

existing information included in the Forest Plan Final EIS, other 

project EISs, project specific resource reports and related information, 

and other sources as indicated. Where applicable, such information is 

briefly summarized and includes all project-specific information, 

including resource reports and other results of field investigations. 

The record also contains information resulting from public 

involvement efforts. The project record is located at the Petersburg 

Ranger District Office in Petersburg, Alaska, and is available for 

review Monday through Friday, from 8 am to 4:30 pm, except 

holidays. 
3 Environment and Effects 

2  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Ecological and Administrative Land 

Divisions 

The land area of the Tongass National Forest has been divided in 

several different ways to describe the different resources and allow 

analysis of how they may be affected by Forest Plan and project-level 

decisions. These divisions vary by resource since the relationship of 

each resource to geographic conditions and zones also varies. The 

allocation of Forest Plan land use designations (LUDs) is one such 

division. Other divisions important for the present effects analysis are 

described briefly here. 

The project area is identified by the Interdisciplinary Team (IDT) to 

define the boundary of the area in which the project will occur. For 

the Central Kupreanof Timber Harvest, the area includes Value 

Comparison Units 4260, 4271, 4380, 4290, and 4360. 

These are distinct geographic areas, each encompassing a drainage 

basin containing one or more large stream systems. The boundaries 

usually follow major watershed divides. Chapter 1 includes a map 

showing the VCUs location (See Figure 1-2). 

These are land divisions that correspond to the “Minor Harvest Areas” 

used by the Alaska Department of Fish and Game to report community 

harvests of selected wildlife species. Approximately 190 apply to the 

Tongass National Forest. The project area includes portions of WAAs 

5130, 5131, 5132, and 5133. 

Watershed refers to the area that contributes water to a drainage or 

stream, or to that portion of a landscape in which all surface water 

drains to a common point. Watersheds can range from tens of acres 

that drain a single small intermittent stream to many thousands of 

acres for a stream that drains hundreds of connected intermittent and 

perennial streams. Seven watersheds were analyzed in the Central 

Kupreanof project area. 

Inventoried roadless areas are undeveloped areas typically exceeding 

5,000 acres that met the minimum criteria for wilderness consideration 

under the Wilderness Act and that were inventoried during the Forest 

Service’s Roadless Area Review and Evaluation (Rare II) process, 

subsequent assessments, or forest planning. The Central Kupreanof 

project falls within four Inventoried Roadless Areas: North Kupreanof, 

South Kupreanof, Castle, and Rocky Pass. 

This designation refers to 21 ecological subdivisions of Southeast 

Alaska that are identified by generally distinct ecological, 

physiogeographic, and biogeographic features. Plant and animal 

species composition, climate, and geology within each province are 

Project Area 

Value 

Comparison Units 

(VCUs) 

Wildlife Analysis 

Areas (WAAs) 

Watershed 

Inventoried 

Roadless Area 

Biogeographic 

Province 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 3 

generally more similar within than among adjacent provinces. 

Historical events (such as glaciers and uplifting) are important to the 

nature of the province and to the barriers that distinguish each 

province. Central Kupreanof project area is part of the 

Kupreanof/Mitkof Islands Biogeographic Province. 

Analyzing Effects

Environmental consequences are the effects of implementing an 

alternative on the physical, biological, social and economic 

environment. The Council on Environmental Quality (CEQ) 

regulations implementing the National Environmental Policy Act 

(NEPA) includes a number of specific categories to use for the 

analysis of environmental consequences. Several are applicable to the 

analysis of the proposed project and alternatives, and form the basis of 

much of the analysis that follows. 

Direct environmental effects are those occurring at the same time and 

place as the initial cause or action. Indirect effects are those that occur 

later in time or are spatially removed from the activity. Cumulative 

effects result from incremental effects of actions, when added to other 

past, present, and reasonably foreseeable future actions, regardless of 

what agency or person undertakes such other actions. Cumulative 

effects can result from individually minor, but collectively significant, 

actions taking place over a period of time. 

An analysis of cumulative effects must also include “reasonably 

foreseeable future actions” (40 CFR 1508.7) This can include 

National Forest System timber sales and other management activities 

as well as land management activities of other landowners on nearby 

lands. Reasonably foreseeable future actions are those that are 

currently planned. 

Implementation of any action alternative would cause some adverse 

environmental effects that cannot be effectively mitigated or avoided. 

Unavoidable adverse effects often result from managing the land for 

one resource at the expense of the use or condition of other resources. 

Many adverse effects can be reduced, mitigated or avoided by limiting 

the extent or duration of effects. 

The interdisciplinary procedure used to identify specific harvest units 

and roads was designed to eliminate or lessen significant adverse 

consequences. The application of Forest Plan Standards and 

Guidelines, Best Management Practices, project-specific mitigation 

measures, and monitoring are all intended to further limit the extent, 

severity, and duration of potential effects. Such measures are 

discussed throughout this chapter. Regardless of the use of these 

Direct, Indirect 

and Cumulative 

Effects 

Reasonably 

Foreseeable 

Future Actions 

Unavoidable 

Adverse Effects 
3 Environment and Effects 

4  Chapter 3 Central Kupreanof Timber Harvest FEIS 

measures, some adverse effects will occur. The purpose of this 

chapter is to fully disclose these effects. 

Short-term uses, and their effects, are those that occur annually or 

within the first few years of project implementation. Long-term 

productivity refers to the capability of the land and resources to 

continue producing goods and services long after the project has been 

implemented. Under the Multiple-Use Sustained-Yield Act, and the 

National Forest Management Act, all renewable resources are to be 

managed in such a way that they are available for future generations. 

The harvesting and use of standing timber can be considered a shortterm use of a renewable resource. As a renewable resource, trees can 

be reestablished and grown again if the long-term productivity of the 

land is maintained. 

This long-term productivity is maintained through-out the application 

of the resource protection measures described in Chapter 2, in 

particular, those applying to the soil and water reserves. These 

protection measures are also discussed throughout this chapter, in 

particular for soils, water quality, biodiversity and economics. 

Irreversible commitments describe a loss of future options. Irreversible 

applies primarily to the effects of use of nonrenewable resources such 

as minerals or cultural resources, or to those factors, such as soil 

productivity, that are renewable only over long periods of time. Once 

these resources are gone, they cannot be replaced. 

 Irretrievable commitments apply to the loss of production, harvest or 

use of natural resources. For example, some or all of the timber 

production from an area is lost irretrievably while an area is serving as 

a winter sports site. The production lost is irretrievable, but the action 

is not irreversible. If the use changes, it is possible to resume timber 

production. 

Where they occur related to the Central Kupreanof Timber Harvest 

(Project Area), irreversible or irretrievable commitments are identified; 

those commitments are summarized here. Roads built on wetlands are 

an irreversible and irretrievable commitment of wetlands. Loss of 

timber productivity in areas proposed for new NFS road construction 

is considered an irretrievable commitment. 

Much of the Tongass National Forest resource data resides in an 

electronic database formatted for a geographic information system 

(GIS). The Forest uses GIS software to assist in the analyses of these 

data. GIS data is available in tabular (numerical) format, and as plots 

displaying data in map format. For this FEIS, all the maps, and most of 

the numerical analyses, are based on GIS resource data supported by 

field inventories. 

Short-term Use 

and Long-term 

Productivity 

Irreversible and 

Irretrievable 

Commitments 

Available 

Information 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 5 

There is incomplete knowledge about many of the relationships and 

conditions of wildlife, fish, forests, climate change, jobs and 

communities. The ecology, inventory and management of a large 

forest area is a complex and developing science. The biology of 

wildlife species prompts questions about population dynamics and 

habitat relationships. The interaction of resource supply, the economy, 

and communities is the subject matter of an inexact science. However, 

the basic data and central relationships are sufficiently well established 

in the respective sciences for the deciding official to make a reasoned 

choice between the alternatives, and to adequately assess and disclose 

the possible adverse environmental consequences. 

Community Profiles 

The potential impact to nearby communities with processing facilities 

that may utilize the timber will depend on many elements associated 

with the competitiveness and efficiency of individual operations. Such 

factors are dependent upon private business decisions as well as 

market conditions for forest products. The Forest Service cannot 

predict which firms will successfully bid for a timber sale, thus 

potential community benefits relating to jobs and incomes associated 

with a sale will not be predicted specifically, but in a regional 

summary. 

Kake is the nearest community to the Project Area and is the most 

likely to be affected socially and economically by the project in terms 

of subsistence, recreation, tourism, and general local use of the area. 

Other nearby communities include Petersburg and Wrangell. The 

information gathered for the community profiles came from the Alaska 

Department of Commerce Community and Economic Development 

web page (Alaska Community Database (ADCCED) 2007). 

Data collected at the census area level may not reflect specific 

community trends in Kake but is useful in subdividing the region into 

smaller study areas. Where it is possible, community-level data has 

been displayed. 

Kake is a Tlingit village and was the first Alaska Native village to 

organize under federal law in the early 1900s. The Organized Village 

of Kake (OVK), a federally recognized tribe, is located in the 

community and has a tribal membership of 480. Traditional customs 

are very important to the community. Kake residents are dependent 

upon subsistence opportunities as economic supplements. 

The population of Kake grew steadily over the last century until 2000 

when the population began to decline. In 1990 and 2000, the 

population of Kake was reportedly 700 and 710, respectively. By 

2003 the population had fallen to 682, and by 2007 the population was 

Kake 
3 Environment and Effects 

6  Chapter 3 Central Kupreanof Timber Harvest FEIS 

estimated to be 536, which is a 16 percent decline in six years. 

According to residents of Kake the latest population estimate was 519 

people. The population of the community is nearly 75 percent 

American Indian (Alaska Native) with the remaining residents mostly 

White American. 

In Kake, the city, school district, Organized Village of Kake (OVK) 

and Southeast Alaska Regional Health Consortium (SEARHC) are the 

largest employers. Approximately 32 percent of the employed 

population of Kake work for a government entity, about 60 percent are 

privately employed, and the remaining are sole proprietors. Fishing 

contributes considerably to the economy. Sixty-seven residents hold 

commercial fishing permits. The non-profit Gunnuk Creek Hatchery 

has assisted in sustaining the salmon fishery. 

Kake’s economy was hit hard after 2003 when two of their major 

employers, Kake Tribal Logging and Timber and Kake Foods, 

virtually eliminated their workforce. Kake Tribal reduced its number 

of jobs by 97 percent while Kake Foods reduced it employment by 90 

percent. Kake has since been deemed a “distressed community” by the 

Denali Commission. According to the commission, a distressed 

community is one that meets the following criteria: 

 Per capita market income not greater than 67 percent of the 

U.S. average: and 

 Poverty rate at 150 percent of the U.S. average or greater: and 

 Three-year unemployment rate at 150 percent of the U.S. 

average or greater; or 

 Twice the U.S. poverty rate and either (1) or (3) above. 

Based on the 2003 data, the Denali Commission estimates Kake’s 

average market income as below the threshold level and estimates that 

more than 70 percent of residents aged 16 and over earn less than the 

threshold. Recreation and tourism opportunities are increasing in 

some parts of the region but it appears some further development and 

infrastructure is needed to strengthen these sectors and increase higher 

wage employment. Kake is currently pursuing tourism income and 

opportunities, but has not experienced the increase in tourism that 

larger communities in the region have. 

The City of Kupreanof is located on the east side of Kupreanof Island 

across the Wrangell Narrows from Petersburg. It was incorporated as 

a second class city in 1975. The population was estimated to be 27 

people in 2008. 

Petersburg is situated on the northwest shore of Mitkof Island at the 

north end of Wrangell Narrows approximately 20 miles southeast of 

Other 

Communities 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 7 

the Project Area. The 2007 population estimate for Petersburg was 

3,072. 

Wrangell is on the northern tip of Wrangell Island, approximately 60 

mile southeast of the Project Area. The 2007 population estimate was 

2,062. The community began as an important Tlingit village primarily 

because of its proximity to the Stikine River. Today timber, fishing 

and fish processing are the main components of Wrangell’s economy, 

and tourism has been a growing economic sector in recent years. 

Environmental Justice/Civil Rights 

A specific consideration of equity and fairness in resource decisionmaking is encompassed in the issue of environmental justice and civil 

rights. As required by law and Title XI, all federal actions will 

consider potentially disproportionate effects on minority or lowincome communities. Environmental justice issues regarding road 

development and timber harvest are considered by decision-makers. 

Disproportional potential impacts or changes to low-income or 

minority communities in the Project Area due to the proposed action 

should be considered. Where possible, measures should be taken to 

avoid impact to these communities or mitigate the adverse effects. 

Kake, though not in the project area, is adjacent to the project area and 

has a long history of local use. Kake’s population is about 75 percent 

Native and has been considered in the analysis of the proposed 

alternatives for disproportional impacts. The Organized Village of 

Kake was consulted and encouraged to comment at any point in the 

process to ensure their concerns would be addressed. Public meetings 

were also held in Kake to assist people in understanding the 

alternatives and how issues were addressed. These meetings also gave 

the public opportunities to highlight other issues and concerns they 

had. The Heritage Resource Report for the Central Kupreanof FEIS 

discusses the cultural environment of the area and addresses our 

responsibilities according to historic preservation laws and regulations. 

There are no known historic properties (cultural resources) within the 

area of potential effect. Native traditional values were considered, 

particularly those associated with subsistence use of the project area. 

Native populations should not be disproportionately impacted under 

any alternative. 
3 Environment and Effects 

8  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Other Resources 

Several resources and uses of the project area are likely to remain 

unaffected by the proposed action or alternatives. Resources or uses 

for which no measurable effects were identified are discussed briefly 

here. 

All of the action alternatives would have limited, short-term effects on 

ambient air quality. Such effects, in the form of vehicle emissions and 

dust, are likely to be indistinguishable from other local sources of 

airborne particulates, including other motor vehicle emissions, dust 

from road construction and motor vehicle traffic, residential and 

commercial heating sources, marine traffic, and emissions from 

burning at sawmills. The action alternatives could result in supplies of 

raw wood products to local mills. It is the responsibility of the mill 

owner or sort yard operator to ensure that mill emissions are within 

legal limits. 

Forest-wide analysis conducted for the 2008 Forest Plan discusses the 

risk of possible effects and the considerable uncertainty concerning 

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

uncertainty regarding the effects of climate change on the resources of 

the Tongass National Forest. There is a risk that climate change may 

result in increased blowdown, increased tree mortality from insects 

and disease, increased fire frequency and severity, adverse effects on 

air quality, changes to vegetation, streams, fish and wildlife habitat, 

and subsistence and recreation uses of the National Forest. The 2008 

Forest Plan FEIS contains considerable information on potential 

climate change effects on resources such as yellow-cedar, hydrology, 

fisheries, plants, and forest health. In this context, climate change is 

not essential to a reasoned choice among the alternatives considered in 

the Central Kupreanof project analysis. The Tongass National Forest 

will continue to monitor potential effects of climate change through 

the existing Forest Plan monitoring programs, and other studies that 

are happening regionally and nationally. Any need for a different 

course of action that might affect the Central Kupreanof project will be 

addressed through existing planning procedures to determine whether 

changes in the Central Kupreanof project management are warranted. 

Air Quality 

Climate Change 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 9 

Under the Alaska Statehood Act of 1959, the State of Alaska is 

entitled to a certain amount of Federal land. The State was also 

allowed to identify for selection more acreage than would ultimately 

be conveyed to State ownership. There are no State-selected lands 

within the project area. Other legislation granted Alaska Native 

corporations similar selection rights. The CEQ regulation 

implementing NEPA require a determination of possible conflicts 

between the proposed action and the objectives of Federal, State, and 

local land use plans, policies, and controls for the area. 

Land Status 
3 Environment and Effects 

10  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Issue 1- 

Timber Supply/Sale 

Economics 

Optimizing volume and net return on timber harvest will provide for 

flexibility, in both the long and short term, for offering economically 

viable timber sales. 

Timber harvest economics is an issue involving the ability of 

Southeast Alaska’s timber purchasers to make a profit and stay in 

business. Loss of this business would negatively impact the ability to 

maintain the economic health of local communities. Timber purchasers 

and affected communities are concerned about the quantity, quality, 

reliability, and profitability of the timber offered for sale from the 

Tongass National Forest. If proposed timber harvest is not designed to 

be economically viable across fluctuating market conditions, there is a 

concern that the forest products industry in Southeast Alaska may not 

remain viable. 

Comments received during the scoping period, and after the DEIS was 

published, offered suggestions for improving overall timber harvest 

economics on the Tongass National Forest and for the Central 

Kupreanof project. Suggestions included: stop building roads; all roads 

required for the sale should be temporary roads; build new roads to 

provide for long-term timber management; volumes should be large 

enough to amortize the cost of mobilization; and consider small sales 

and Microsales. 

There are many factors that can increase the cost of timber harvesting, 

such as logging systems, setting size, silvicultural prescriptions, 

haul/tow distances, and miles of road construction, re-construction, 

and maintenance. These costs may carry significant economic risk for 

potential purchasers as well as the ability of the Forest Service to offer 

timber sales. The value of the timber offered must be sufficient to 

cover this cost and offer a potential for profit to purchasers. 

Because the value of timber fluctuates with market demand, volume 

made available with the Central Kupreanof project will allow the 

Forest Service to respond to these conditions by providing sale 

packaging flexibility to offer the most economically viable timber 

sales. The Central Kupreanof project will also provide an opportunity 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 11 

for timber purchasers to respond to market conditions by having 

sufficient volume under contract. 

Measurement: 

The unit of measures to compare alternatives will include 

 Total volume (sawlog and utility) measured in million board 

feet (MMBF), 

 Logging costs per thousand board feet (MBF), 

 Indicated bid - dollars per MBF 

 Employment in number of direct jobs 

 Direct income based on projected employment and 

 Logging systems by harvest method (acres). 

The NEPA Economic Analysis Tool Residual value (NEAT_R) is the 

Forest Service, Alaska Region, financial efficiency and economic 

analysis program for use in timber planning. The NEAT_R model 

runs are one tool to gauge current economics for an alternative, but it 

does not provide a complete picture. A greater number of units, and 

the more volume made available, allows greater diversity and 

flexibility, as well as the ability to respond to future market conditions. 

The following discussion and analysis of timber sale economics is 

based on referenced sources including NEAT_R version 2.15 ( R10 

Supplement FSH 2409.18 and NEAT_R User’s Guide, 2008). More 

information about NEAT_R and the methodology is located in the 

project record. 

Timber Supply and Economics-Affected 

Environment 

About 70,000 people live in towns, communities, and villages located 

on islands and coastal lands of Southeast Alaska (ADCCED, 2007). 

The Southeast Alaska region accounts for about 12 percent of the 

State's population and 6 percent of the land base. Federal lands 

comprise about 95 percent of Southeast Alaska, 80 percent within the 

Tongass National Forest. Southeast Alaska communities, which are 

within or adjacent to the Tongass National Forest, are largely 

dependent on the Forest to provide natural resources for employment. 

This includes commercial fishing, timber harvest and processing, 

tourism, and mining. The forest is also needed for recreation and 

subsistence use. 

Employment in 

Southeast Alaska 
3 Environment and Effects 

12  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Forest Products Employment 

The forest products industry has been an important part of the 

economy of Southeast Alaska since settlement, with sharp growth in 

the 1950s due to the start of the pulp mills. Employment declined 

considerably in 1997 primarily due to the closure of the Ketchikan 

Pulp Company pulp mill. Recent forest products employment data are 

presented in Table 3-1. 

Table 3-1. Forest Products Industry Employment in Southeast 

Alaska 2002 through 20074

Year1 Tongass 

Logging2 

Tongass 

Sawmill

TongassRelated 

Employment3 

Other 

Sawmill

Other 

Logging 

Total 

Industry 

Employment

2002 63 1104

 173 40 299 512 

2003 108 91 199 64 298 561 

2004 82 95 177 53 220 450 

2005 88 96 184 52 263 499 

2006 81 77 158 46 217 421 

2007 44 70 114 63 225 402 

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

Parrent 2006 and 2007, and Kilborn 2008. Data on file with: Regional Economist, 

Ecosystems Planning, USDA Forest Service, PO Box 21628, Juneau, AK 99802-

1628. 

1

 Reported in calendar years. 

2

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

total timber harvest in Southeast Alaska. 

3

 Through 2001, assumes all sawmill and pulp mill employment is dependent upon Tongass 

National Forest timber supply. From 2002 to 2005, this assumption no longer held. Data 

from Kilborn et al. (2004), Brackley et al. (2006b), Parrrent 2006 and 2007, and Kilborn 2008 

show that Federal timber supplied 73 percent of the wood sawn in Southeast Alaska mills in 

2002, 59 percent in 2003, 64 percent in 2004, 65 percent in 2005, and 62 percent in 2006, and 

53% in 2007. Tongass National Forest sawmill employment from 2002 through 2007 is 

estimated based on sawmill employment numbers and the ratio of sources of wood (Federal 

versus the total) reported by Kilborn et al. (2004), Brackley et al.(2006b), Parrent 2006 and 

2007, and Kilborn 2008. 

4

 Beginning in 2001, employment estimates are being published under a new classification 

system. The Standard Industrial Classification (SIC) system has been replaced by the North 

American Industrial (NAI) Classification system. “Sawmill” in this table is reported by the 

Alaska Department of Labor as “wood manufacturing” which in the NAI system includes 

sawmills, wood preservation, veneer, plywood, engineered wood, and other wood products. In 

Southeast Alaska, this category is assumed to represent only sawmill employment. Beginning 

in 2001, sawmill employment figures are adjusted based on regional mill studies, which take 

into account self-employed mill owners. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 13 

Past, Current and Reasonably 

Foreseeable Future Timber Harvest in the 

Project Area 

Considerable timber harvest has occurred in VCUs 4250 and 4271 and 

on private Native Corporation lands to the north. Past timber 

management activities in the Central Kupreanof project area began in 

1975 using clearcut cable yarding. Larger-scale clearcut logging 

began in 1979 and continued through 2003 resulting in approximately 

4,600 acres of clearcut harvest on National Forest System lands. For 

more detailed information regarding past harvest in the project area, 

refer to the Catalog of Events, in Appendix C. Currently, no largescale harvest is occurring on either private or NFS lands. Two to three 

small sales associated with the 6367 Small Timber Sale CE, consisting 

of approximately 60 total acres of clearcut with reserves on NFS lands, 

just north of the project area, will likely occur in 2009 through 2012. 

Microsales associated with the Kake I Microsale CE (2008), may 

occur along NFS road 6040 in the project area. In following years, 

Microsales may also occur along open NFS roads or NFS roads 

adjacent to the project area depending on demand. 

Timber Supply and Market Demand 

Determining market demand is a complex process. Detailed 

explanations of the rationale for considering timber harvest in the 

Central Kupreanof project area and market demand for wood products 

is located in Appendix A of this document. The 2008 Forest Plan 

amendment FEIS, Volume 1, and Appendix G, describes the latest 

timber demand analyses and projections. 

There are several factors that enhance the economic potential of the 

Central Kupreanof project area, and may in turn affect the timber 

supply to the forest products industry. These factors include an 

existing road system, Log Transfer Facility (LTF) infrastructure and 

feasibility of cost-effective logging systems. The amount of timber 

volume will have an effect on employment as shown in Table 3-7 

which displays the support to direct employment that will result from 

logging and milling the volume in the timber sale. 

The Central Kupreanof project will use the existing road system and 

the existing Little Hamilton LTF. Approximately 79 miles of NFS 

roads exist in the project area. All the action alternatives will require 

additional road segments to access timber. In some cases these new 

roads will shorten helicopter yarding distances. Table 3-2 shows the 

amount of existing and proposed roads by alternative within the 

Timber Sale 

Economics 

Road Access and 

Log Transfer 

Facility 
3 Environment and Effects 

14  Chapter 3 Central Kupreanof Timber Harvest FEIS 

project area. More information about roads and the LTF is found in the 

Transportation section and resource report. 

Table 3-2. Existing and Proposed Miles by Alternative within 

the Project Area 

Miles by Alternative 

1 2 3 4 

Existing NFS Road 79 79 79 79 

Proposed NFS Road 0 7.3 25.1 0 

Proposed NFS Road Reconstruction 0 2.9 9.1 2.6 

Proposed Temporary Road 0 3.9 6.1 2.2 

Source: Tongass GIS 2008 

Generally, the less complex a silvicultural prescription the more cost 

efficient it is to implement. Even-aged management using the clearcut 

prescription usually results in less cost associated with logging 

because it is more efficient due to increased production and the ability 

to use less expensive equipment. 

All action alternatives propose primarily even-aged clearcut 

prescriptions. Alternatives 2 and 3 include uneven-aged single tree 

selection prescriptions where helicopter yarding is proposed. 

Alternative 2 includes a minor amount of two-aged, clearcut with 

reserves prescription. See the Silviculture and Vegetation section and 

resource report for more information. 

The single tree selection prescription is only used in conjunction with 

helicopter yarding for this project. Single tree selection will allow the 

harvest of individual trees. Helicopter yarding also addresses resource 

concerns related to Forest Plan Standards and Guidelines, and allows 

access to areas that are considered otherwise inaccessible for typical 

road construction. 

Effects on Timber Economics 

The action alternatives include the use of ground-based cable and 

shovel yarding systems, and helicopter yarding systems. Table 3-3 

displays the acres by yarding system for each alternative. 

Cable yarding systems are best suited for steep slopes and are most 

efficient using the clearcut harvest method. The average cost of cable 

yarding for all alternatives in this analysis is $211 per MBF. 

Silvicultural 

Prescriptions 

Logging Systems 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 15 

Shovel yarding is the least costly yarding method used in this analysis. 

Shovel yarding is best suited for slopes less than 30 percent. Normal 

yarding distance is less than 400-500 feet. Depending on slope and 

ground conditions, longer distances are possible. Shovel yarding does 

provide some flexibility in the selection of trees to be harvested. This 

makes shovel yarding more suitable for partial harvest prescriptions 

than cable yarding systems. The average cost of shovel yarding for all 

alternatives in this analysis is $164 per MBF. 

Helicopter yarding is the most expensive yarding method. Yarding 

distance, turn time (the time it takes the helicopter to make a round trip 

from landing to the unit and return), weight of each turn and the value 

of timber yarded influence the economic viability of helicopter 

yarding. Helicopter yarding is used where roads are not constructed to 

access the timber harvest units. Helicopter yarding works well for a 

variety of prescriptions; however, it is commonly used with partial 

harvest prescriptions. The average cost of helicopter yarding for all 

alternatives in this analysis is $356 per MBF. 

Table 3-3. Yarding System and Harvest Method (Acres) 

Yarding System - Harvest Method 

Alternatives 

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

Cable - Clearcut 0 981 1,638 567 

Cable - Clearcut with 10% 

Retention 0 90 90 26 

Shovel - Clearcut 0 934 1,373 721 

Shovel - Clearcut with 10% 

Retention 0 26 26 13 

Shovel - Clearcut with Reserves 

(50% Retention) 0 33 0 0 

Helicopter - Single Tree Selection 

(60% Retention) 0 442 520 0 

Source: Tongass GIS 2008 

The Central Kupreanof project alternatives were evaluated using 

NEAT_R Version 2.15 based on an appraisal point of Wrangell (FSH 

2409.18, 45.11). The results are displayed in Table 3-4. The values 

used reflect data updated for the 3rd Quarter 2007 and incorporate cost 

estimates updated in June, 2008 and the Limited Interstate Shipping 

Policy (Regional Forester 2400 memo, March 14, 2007). 

Logging costs evaluated in the NEAT_R financial efficiency analysis 

included truck hauling of logs to the Little Hamilton LTF, and barging 
3 Environment and Effects 

16  Chapter 3 Central Kupreanof Timber Harvest FEIS 

to the Silver Bay Mill in Wrangell which is the closest appraisal point. 

On average, barging costs were estimated to be $80 per MBF. 

One method to compare the effects of the different alternatives is 

through a financial efficiency analysis which is a comparison of those 

costs and benefits that can be quantified in terms of actual dollars 

spent or received within the project area. This type of analysis does 

not account for non-market benefits, opportunity costs, individual 

values, or other values, benefits, and costs that are not easily 

quantifiable. This is not to imply that such values are not significant 

or important, but to recognize that non-market values are difficult to 

represent by appropriate dollar figures. Therefore, financial efficiency 

should not be viewed as a complete answer but as one tool decision 

makers can use to gain information about resources, alternatives, and 

trade-offs between costs and benefits. Although individual harvest 

units may or may not be economical to harvest by themselves, the 

management of less productive land, or land containing a high 

percentage of defective timber will help to increase future timber 

yields. The harvest of units with higher value can help compensate for 

less economical harvest units. 

Table 3-4. Timber Financial Efficiency Analysis 

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

Volume - Sawlog (MBF) 

 Sitka Spruce 0 7,051 10,425 3,960 

 Hemlock 0 26,487 40,057 16,449 

 Western redcedar 0 125 191 79 

 Alaska Yellow-Cedar 0 5,733 8,400 3,119 

Total Sawlog Volume 

(MBF) 0 39,396 59,073 23,606 

 

Pond Log Value $/MBF1 $0 $287 $281 $268 

Stump to Mill Cost $/MBF $0 $374 $410 $353 

Indicated Value2 

($ millions) $0 ($3.4) ($7.6) ($2.0) 

Indicated Rate $/MBF $0.00 ($86.42) ($129.16) ($85.46) 

Source: NEAT_R Version 2.15 (June, 2008 output) 

1

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

2

 ( ) indicates negative value 

NEAT_R Version 2.15 (incorporates the Limited Interstate Shipping Policy) 

Timber Financial 

Efficiency 

Analysis 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 17 

 

The harvest volumes, indicated value, costs and net stumpage values 

used in this document are current estimates and useful for comparing 

relative differences between alternatives and are not meant to reflect 

absolute values. Merchantable timber within units and any road rightof-way located on National Forest System lands will be cruised to 

determine the quantity, quality and value of timber for the contract 

under which that volume of timber is offered. The final sale appraisal 

will include current quarter selling values, current cost information and 

a normal profit and risk allowance to determine the minimum 

advertised stumpage value at the time of offering. Sales with volumes 

under 250 MBF do not require an appraisal and can be advertised 

using established standard rates. 

The difference in indicated bid rates among the action alternatives can 

be attributed to multiple factors, including: 

 Differences in species composition, volume per acre harvested, 

and timber quality 

 Difference in harvest prescriptions 

 Proportion of cable, shovel and helicopter yarding systems 

 Amount of road construction and reconstruction 

 Differences in haul distances 

Total unit net volumes by alternative were calculated using NEAT_R 

Version 2.15 and based upon average per acre volume for the high, 

medium and low volume strata. Volume strata averages are based on 

2006 and 2007 stand exam data. Volumes for the alternatives are 

displayed in million board feet (MMBF) in Table 3-5. 

Table 3-5. Estimated Volume in MMBF 

Estimated Volume 

Alternatives 

1 2 3 4 

Sawlog 0 39.4 59.1 23.6 

Utility 0 7.4 11.2 4.5 

Total 0 46.8 70.2 28.2 

Source: NEAT_R Version 2.15 June, 2008 output 

Timber Volume 

Calculations 
3 Environment and Effects 

18  Chapter 3 Central Kupreanof Timber Harvest FEIS 

There are many factors that can increase the cost of timber harvest. 

These costs may carry significant economic risk for potential 

purchasers as well as the ability of the Forest Service to offer timber 

sales. Road construction, helicopter yarding, silvicultural prescriptions 

other than clearcutting, setting size and other factors may increase 

costs. Those increased costs will then affect the timber value for the 

alternatives. The value of the timber offered must be sufficient to 

cover this cost and offer a potential for profit to purchasers. Because 

markets fluctuate, volume made available with the Central Kupreanof 

project should allow the Forest Service to respond to these conditions 

when packaging timber sales. Alternative design and volume levels 

affect sale packaging flexibility for offering the most economically 

viable timber sales. Also, the larger the timber sale volume, the greater 

the ability an operator has to respond to market conditions with the 

volume they have under contract. 

The costs used in the current NEAT_R model incorporate the same 

costs used in the Alaska Region’s appraisal program. Those costs 

reflect actual cost data collected from timber sale purchasers in 

Southeast Alaska, as well as production studies. At times, certain 

situations and sales may have higher or lower costs than the regional 

averages, based on site specific circumstances. 

For example, in the Central Kupreanof project area, local estimates for 

logging costs may be lower for felling and bucking, shovel yarding, 

and hauling, while cable yarding costs may be estimated to be higher. 

Some of the reasons why local costs may be lower include: a nearby 

town (Kake) with an experienced and available workforce, a well 

developed Log Transfer Facility (LTF), and an existing road system. 

Utility volume could be left in the woods under the optional removal 

contract provision. Additionally, in some years, public works funds 

are available to pay for all, or a portion of, NFS road construction or 

reconstruction costs in a timber sale for roads that will be used in the 

long-term administration of the national forest. Table 3-6 displays the 

stump to mill costs, indicated value and the advertised rate for each 

alternative if public work funds paid for all NFS roads construction or 

reconstruction costs. 

Opportunities to 

Improve 

Economics 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 19 

Table 3-6. Timber Financial Efficiency Analysis (if public work 

funds cover NFS road construction costs). 

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

Stump to Mill Cost $/MBF $0 $368 $375 $348 

Indicated Value 

 ($ millions) $0 ($3.3) ($5.8) ($1.9) 

Indicated Rate $/MBF $0 ($80.56) ($94.52) ($80.51)

Source: NEAT-R version 2.15 June, 2008 output 

The mix of species harvested may also enhance the economic potential 

of the Central Kupreanof project area and may in turn affect the timber 

supply to the forest products industry. The amount of timber volume 

will have an effect on employment as shown in Table 3-7, which 

displays estimated direct employment that will result from logging and 

milling the volume in the timber sale. 

Five individuals from Kake with small sawmills have contacted the 

Forest Service and expressed interest in purchasing small sales from 

the project area. The timber volume associated with the smaller units 

along the existing road system may be considered for small sale 

opportunities. Each of the three action alternatives include these small 

units and provide for numerous small sale opportunities from the 

project area. This may have a slight positive effect to the overall 

economics of the project as volume from small sales would likely be 

processed locally. Local processing avoids the cost of barging the 

timber to a larger mill, thus reducing logging costs and increasing the 

indicated bid amount for the volume harvested through small sales. 

Potential small sales however, would not change the project’s 

estimated total volume, number of jobs, direct income, or logging 

systems by harvest method. Alternatives 2 and 3 would enhance 

opportunities as these alternatives propose new road access through 

suitable timber lands. This would open additional areas for future 

small sale projects currently not feasible for small operators; however, 

this future opportunity would have no effect on the timber economics 

for the Central Kupreanof Timber Harvest Project. 

Individuals from Kake have expressed interest in the Tongass 

Microsale program. For all action alternatives, Microsales would be 

allowed to occur along existing NFS roads 6040, 6314, 6314S, 6326, 

6328, 6334, 6336, 6339 and 6367. Potential Microsales would not 

affect the logging costs, indicated bid amount, or logging systems by 

harvest method for the Central Kupreanof Timber Sale Project 

alternatives. Microsales would however, have the potential to slightly 

Opportunities for 

Small Sales 

Opportunities for 

Microsales 
3 Environment and Effects 

20  Chapter 3 Central Kupreanof Timber Harvest FEIS 

increase the total volume, direct jobs, and direct income generated 

from the project. 

Also proposed are Projects Common to all Action Alternatives which 

may be implemented through stewardship contracts, further providing 

economic opportunity and benefiting local communities. The proposed 

projects include trail and cabin maintenance to meet current recreation 

use, manual invasive plant species control, wildlife enhancements, 

silviculture treatments, and regular road maintenance. Road storage or 

decommissioning is also a possibility for inclusion within a 

stewardship contract, as is the prioritization of pulling culverts. 

However, this is dependent on road management decisions analyzed 

and made in the ATM process. There would be no direct effects to 

timber sale economics. Indirect effects from using stewardship 

contracts may include an increase in employment and benefit local 

economies. Stewardship contracts also provide opportunities for 

potential timber sale operators to amortize costs over various contracts 

requiring similar skills. This could indirectly affect project logging 

costs and ultimately indicated bid values. 

Projected Employment and Income 

The action alternatives would have direct and indirect impacts to the 

economies of the local communities. 

Direct employment and income likely to result from timber harvest is 

estimated by converting board feet to jobs and income. Table 3-7 

displays estimated direct logging and sawmilling-related employment 

and income. Alternative 1 would not generate timber-related jobs 

since no timber would be sold. 

Table 3-7. Estimated Project Employment and Income in 

Alaska 

Employment1 Alt. 1 Alt. 2 Alt. 3 Alt. 4 

Logging2 0 91 136 55 

Sawmills3 0 65-130 98-196 39-78 

Direct Jobs 0 156-221 234-332 94-133 

Direct Income 

( $ millions) 0 $6.1–8.3 $9.1–12.5 $3.6-5.0 

Source: NEAT_R Version 2.15 June, 2008 output. 

1 Number of Job years 

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

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

Alaska to all sawlogs processed in Alaska 

Projects Common 

to all Action 

Alternatives 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 21 

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

in Table 3-7 to reflect the variety of options the timber purchaser has 

under the Limited Interstate Shipping Policy. The purchaser may elect 

to process all the sawlogs locally or to ship up to 50 percent of the 

total sawlog volume and 100 percent of the utility volume to markets 

outside Alaska in the lower 48 states. The Limited Interstate Shipping 

Policy allows shipment to the lower 48 states of unprocessed Sitka 

spruce and Western hemlock sawlogs smaller than 15 inches in 

diameter at the small end of a 40-foot log, and grade 3 or 4 logs of any 

diameter. Shipments are limited on each sale to a maximum of 50 

percent of total sawlog contract volume harvested of all species, 

including Western redcedar and Alaska yellow-cedar. 

The upper end of this range assumes all of the timber sold, including 

Alaska yellow-cedar is processed in Southeast Alaska. The lower end 

of this range assumes that the maximum of 50 percent of total sawlog 

volume is shipped to markets outside Alaska. The number of jobs and 

related income will likely fall somewhere between the high and low 

end of this calculated range, based upon factors such as current timber 

markets and mill configuration. 

Effects on other employment opportunities, such as those for tourism 

and commercial fishing are not included in the financial efficiency 

analysis. Because of the regional nature of these occupations, this 

analysis is done at the Forest planning level and is included in the 

analysis for the 2008 Forest Plan Amendment FEIS (USDA Forest 

Service 2008). Information on the effects to tourism and commercial 

outfitters and guides is found in the recreation section. Effects on the 

commercial fish species was done through the Essential Fish Habitat 

Assessment as required by the Magnuson/Stevens Fisheries 

Conservation Act (2000), found in the Fisheries section of the project 

record. 

Indirect calculations are not included with this analysis. Robertson 

(2003) found that even in small communities where shifts in basic 

employment may be extreme, the economic base hypothesis 

(sometimes referred to as indirect job effects) is not supported by the 

empirical evidence. Linear indirect impact multipliers derived from 

modeling are, therefore, not applicable in small communities 

(Alexander, 2006). Effects on other employment opportunities, such 

as those for tourism and commercial fishing are not included in the 

financial efficiency analysis. Because of the regional nature of these 

occupations, this analysis is done at the Forest planning level and is 

included in the Forest Plan FEIS (January 2008). 

Other 

Employment 

Opportunities 
3 Environment and Effects 

22  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 

Direct and Indirect Effects on Timber 

Economics Summarized by Alternative 

No timber income would be created from this project. Timber needed 

to meet the estimated demand would have to be harvested from other 

areas on the Tongass National Forest. 

This alternative would offer up to 46.8 MMBF of timber (sawlog and 

utility volume) for harvest. This alternative proposes the second 

highest volume of timber using ground based and helicopter logging 

systems. Alternative 2 would provide the Forest Service with less 

flexibility at the time of sale packaging than Alternative 3 given that 

fewer units and less volume would be available to offer for sale. 

However, Alternative 2 would provide more flexibility than 

Alternative 4. 

The estimated logging and transportation costs would be $374 per 

MBF with road costs estimated to be $18.20 per MBF. The indicated 

bid is a negative $86.42 per MBF. Between 156 and 221 direct 

annualized jobs would be supported in Alaska, providing an estimated 

$6.1–8.3 million in direct income. 

This alternative would offer up to 70.2 MMBF of timber (sawlog and 

utility volume) for harvest. This alternative has the highest volume of 

timber. This alternative proposes harvesting all the units in the project 

unit pool. This alternative proposes helicopter yarding for those units 

where access by road construction is not feasible, otherwise ground 

based systems and associated road construction are analyzed for this 

alternative. Consequently, Alternative 3 proposes the greatest amount 

of NFS road and temporary road construction. Alternative 3 provides 

the Forest Service the most flexibility in sale packaging and the 

greatest ability to respond to future market conditions. 

Estimated logging and transportation costs would be $410 per MBF 

with road costs estimated to be $47.79 per MBF. The indicated bid is a 

negative $129.16 per MBF. Between 234 and 332 direct annualized 

jobs would be supported in Alaska, providing an estimated $9.1 to 

12.5 million in direct income. 

This alternative would offer 28.2 MMBF of timber (sawlog and utility 

volume) for harvest. Alternative 4 was developed in response to public 

concerns about the impacts of increased access, timber harvest, and 

road building on roadless area characteristics. This alternative 

proposes the lowest volume and the least flexibility in sale packaging. 

This alternative has the highest indicated bid under current market 

conditions, as it proposes only harvesting stands accessible from the 

Alternative 1 

Alternative 2 

Alternative 3 

Alternative 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 23 

existing road system or temporary roads and avoids building new 

National Forest System roads and helicopter yarding. 

Estimated logging and transportation costs would be $353 per MBF 

with road costs estimated to be $16.91 per MBF. The indicated bid is 

a negative $85.46 per MBF. Between 94 and 143 direct annualized 

jobs would be supported in Alaska, providing an estimated $3.6 to 5.0 

million in direct income. 

Table 3-8. Comparison of Alternatives 

1

 NEAT_R Version 2.15 June, 2008 Outputs. Total volume is slightly different then 

Table 3-5 due to rounding 

Cumulative Effects on Timber Supply and 

Timber Economics 

Economic effects are analyzed in the 1997 Forest Plan FEIS, 2003 

Forest Plan SEIS, and most recently in the analysis for the 2008 Forest 

Plan Amendment FEIS. Alternatives 2 through 4 would contribute to 

the timber related economy of Southeast Alaska. Alternative 1 would 

not and timber from other areas on the Tongass would have to be used 

Alt 1 Alt 2 Alt 3 Alt 4 

Indicated Bid 

Value/MBF 0 ($86.42) ($129.16) ($85.46) 

Stump to Mill 

Cost $/MBF 0 $374 $410 $353 

Road 

Costs/MBF 0 $18 $48 $17 

Temp Road 

Miles

0 3.9 6.1 2.2 

System Road 

Miles 

0 7.3 25.1 0 

Helicopter 

Sawlog Volume 

MMBF1

0 3.0 3.4 0 

Ground Based 

Sawlog Volume 

MMBF1

0 36.4 55.6 23.6 
3 Environment and Effects 

24  Chapter 3 Central Kupreanof Timber Harvest FEIS 

to provide a supply. Presently, other timber sale projects in the 

vicinity include volume analyzed for the Kuiu Timber Sale EIS, the 

Scott Peak EIS, the Bohemia Mountain EIS, the Todahl Mountain EA, 

the 6367 Small Sale categorical Exclusion (CE) and the Kake 

Microsale I CE. Appendix A of the Central Kupreanof EIS includes 

information about how the Tongass timber program is structured. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 25 

Issue 2- 

Inventoried Roadless Areas 

Timber harvest and building roads in Inventoried Roadless Areas will 

reduce roadless acres within the project area and may affect roadless 

values. 

Comments were received from the public concerning management of 

the inventoried roadless areas in the project area. Several comments 

expressed the desire to avoid roads and harvest in Tongass inventoried 

roadless areas because of the potential to affect their roadless 

characteristics and size. The Central Kupreanof project area includes 

portions of four inventoried roadless areas: North Kupreanof, South 

Kupreanof, Rocky Pass and Castle Inventoried Roadless Areas (See 

Figure 3-1). 

 Units of Measure: 

 Acres of timber harvest and miles of new NFS and temporary 

road construction, total affected acres, and percent of IRA 

affected, including the 600-foot and 1,200-foot buffers. 

 Relative change in the roadless characteristics of each 

individual IRA. 

Inventoried roadless areas are undeveloped areas typically exceeding 

5,000 acres that meet the minimum criteria for wilderness 

consideration under the Wilderness Act. Although these areas are not 

currently under consideration for wilderness designation, they contain 

values that may include pristine watersheds, diversity of native plant 

and animal communities, habitat for threatened, endangered or 

sensitive species, primitive and remote recreational opportunities, 

scenic values, cultural or historic features, unique wetlands or geologic 

formations, or highly valued subsistence opportunities. Because 81% 

of the project area is comprised of inventoried roadless areas, these 

values are included in the general description and characterization of 

the project area, and evaluated in individual resource reports (see 

Wildlife, Subsistence, Watershed, Fisheries, Soils and Geology, 

Heritage, Scenery, and Recreation reports). This section in the EIS 

specifically considers the relative change to these values for each 

inventoried roadless area potentially affected by the Central Kupreanof 

project. 
3 Environment and Effects 

26  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The Roadless Area Conservation Rule (January 2001) has been the 

subject of numerous lawsuits. Courts have simultaneously upheld and 

overturned the 2001 Roadless area Conservation Rule. On May 28, 

2009, the USDA Secretary reserved decision making authority over 

construction and reconstruction of roads and the cutting, sale or 

removal of timber in inventoried roadless area (in a memorandum that 

stated): 

“The authority to approve road construction and timber harvest in 

Inventoried Roadless Areas is reserved to the Secretary of Agriculture 

(Secretary’s Memorandum 1042-154).” 

The Secretary’s Memorandum is intended to ensure the careful 

consideration of activities in Inventoried Roadless Areas while long 

term roadless policy is developed. 

During the analysis conducted in the 2008 Forest Plan Amendment, 

protection of high value roadless areas were identified as a key issue 

that drove development of alternatives and focused the effects 

analysis. The issue responded to the protection of high value 

inventoried roadless areas from road development and timber harvest, 

particularly for wildlife, biodiversity, recreation, and tourism. The 

Tongass National Forest is currently more than 90 percent roadless, 

including Wilderness. Seeing a balance between the protection of 

inventoried roadless areas (deemed to have high qualitative value), and 

timber market demand in the 2008 Forest Plan development of 

Alternatives, the Record of Decision selected Alternative 6. 

Alternative 6 retains 76% of the roadless acreage in natural setting 

Land Use Designations (LUDs) and allows 3.2% suitable for timber 

harvest. 

As an additional step, the 2008 Forest Plan incorporated the Timber 

Sale Program Adaptive Management Strategy in response to concerns 

that an overestimate of timber demand would lead to timber harvest in 

areas perceived by many as more environmentally sensitive, such as 

higher value Inventoried Roadless Areas, that would not have to be 

developed if the Plan were based on a lower estimate of timber 

demand (See Forest Plan, Record of Decision, page 17, and pages 37-

43). 

All of the IRA acres within the Central Kupreanof project area have 

been identified to be within the Phase 1 suitable land base. 

Portions of four IRAs are within the project area. For each IRA, the 

entire IRA is included within the resource analysis area for effects. 

Regulatory 

Framework 

Resource 

Analysis Area 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 27 

Affected Environment 

In the evaluation of inventoried roadless areas in the 2003 Forest Plan 

SEIS, all Tongass National Forest lands were assessed to determine if 

they were suitable for wilderness based on the Wilderness Act and the 

procedures in the Forest Service planning directives. Appendix C 

(2003 Forest Plan SEIS Volumes II and III) includes documentation of 

the analysis and evaluation for each roadless area, describing 

qualitative resource attributes and the relative contribution each 

roadless area would make to the National Wilderness Preservation 

System. These characteristics included the wilderness potential or 

wildernesses attribute rating (WARS), the opportunity for solitude and 

serenity, scenic value, recreational values, ecologic values, cultural or 

historic values, and research values. Characterization and values of the 

IRAs in the project area were reviewed. There is no new information 

or changes to update the IRA descriptions. These descriptions serve as 

the reference condition and will be used in this analysis to describe the 

degree of change that would occur by the implementation of the 

Central Kupreanof EIS to the affected Inventoried Roadless Areas. 

Table 3-9. 2008 Forest Plan Development and Nondevelopment LUD allocation for project area 

Inventoried Roadless Area 

Roadless 

Area 

Roadless 

Area 

number 

Nondevelopment 

LUD 

Acres 

Development 

LUD 

Acres 

Total acres 

in Roadless 

Area 

North 

Kupreanof 211 53,107 46,456 99,566 

South 

Kupreanof 214 48,060 165,067 213,122 

Rocky 

Pass 243 73,181 5,921 79,103 

Castle 215 29,815 22,621 52,432 

Total Acres 204,163 240,065 444,223 

1

 Total acres are from the 2003 SEIS. Addition of non-development and development 

LUD acres do not equal total SEIS acres due to slivers resulting from unmatching 

shorelines in GIS layers. 

Reference 

Condition 
3 Environment and Effects 

28  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Existing Condition 

The North Kupreanof Inventoried Roadless Area (99,566 acres) is 

located at the north end of Kupreanof Island and lies along the 

southern shore of Frederick Sound. Approximately 29,054 acres of 

this inventoried roadless area are within the project area. 

North Kupreanof Inventoried Roadless Area is generally characterized 

by uniformly rolling lowlands with considerable muskeg. The 

Bohemia Range rises to an elevation of over 2,200 feet to the east, 

providing topographic relief to essentially flat terrain. Three major 

drainage systems, Hamilton Creek, Big Creek and Cathedral Falls 

Creek, wind across much of the area. There are also many small lakes. 

The area is mostly unmodified; however, it is influenced by 

development on the east and west sides, as well as by two roads which 

nearly divide the area. The overall area has moderate natural integrity 

and relatively high apparent naturalness. None of the landscape in the 

area is considered distinctive for the character type from a scenery 

standpoint. While a small portion of this roadless area located in 

Hamilton Creek drainage is part of the Kake Municipal Watershed, 

this area is outside of the project boundary. Also, the small area of 

karst near Hamilton Creek north of Towers Lake lies outside of the 

project boundary. 

The North Kupreanof IRA is influenced by development on the east 

and west sides, as well as by roads which nearly divide the roadless 

area. The area was rated 19 out of a possible 28 points using the 

Wilderness Attribute Rating System (WARS) (SEIS 2003) and ranked 

70th along with 13 other Tongass inventoried roadless areas. 

The South Kupreanof Inventoried Roadless Area (213,122 acres) 

occupies most of the southern half of Kupreanof Island. 

Approximately 93,804 acres of this inventoried roadless area are 

within the project area. 

Landforms in this area are characterized by uniformly rolling to 

moderately-steep hills, typically less than 1,500 feet in elevation, 

though some peaks are over 2,000 feet. The ridges parallel each other 

in a roughly northwest to southeast direction. The area contains 

approximately 107 miles of shoreline on saltwater. 

This relatively large roadless area is mostly unmodified and natural 

appearing. However, the extension of the road system from the north 

influences the area to some degree. The natural integrity and apparent 

naturalness are rated very high. None of the area is rated as distinctive 

for the character type from a scenery perspective. There is a small area 

of karst north of Taylor Creek along the shore of Towers Arm. Stone 

North Kupreanof 

Inventoried 

Roadless Area 

South Kupreanof 

Inventoried 

Roadless Area 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 29 

columns comprised of columnar basalt form the “totems” at the head 

of Totem Bay, outside of the project area. 

The South Kupreanof IRA has an existing road corridor extending 

halfway through the interior and partially into the upper Castle River 

watershed. The southern half of this area is predominantly unmodified 

and undeveloped. The area was rated 24 out of a possible 28 points 

using WARS and ranked 24th along with 4 other Tongass inventoried 

roadless areas among the 109 on the forest. 

Rocky Pass Inventoried Roadless Area (79,103 acres) includes many 

small islands and is divided into two portions separated by the Rocky 

Pass saltwater channel. The western portion lies on the eastern edge of 

Kuiu Island, and the eastern portion lies on the western edge of 

Kupreanof Island, just south of Kake. Approximately 251 acres of this 

inventoried roadless area are within the project area boundary. 

Landforms within this area are characterized by rolling to moderately 

steep hills, typically less than 1,500 feet in elevation. The roadless 

area is bordered to the west by the Camden Inventoried Roadless Area, 

and South Kupreanof Inventoried Roadless Area to the east. 

The area is natural appearing. The natural integrity is very high and the 

apparent naturalness is outstanding. Approximately nine percent of the 

landscape is considered distinctive for the character type from a 

scenery standpoint. This area has very high cultural, historic, and 

recreational values. The area is prized for its geologic diversity and is 

a prime area for rock hounds to visit. These unique features of the 

Rocky Pass Inventoried Roadless Area are located outside of the 

Central Kupreanof project area boundary. 

The Rocky Pass IRA, especially the southern half, is predominantly 

unmodified and undeveloped. The area was rated 26 out of a possible 

28 points using WARS and ranked 5th along with 6 other Tongass 

inventoried roadless areas. 

Castle Inventoried Roadless Area (52,432 acres) lies along the 

southwest shore of Duncan Canal in the southeast corner of the main 

lobe of Kupreanof Island. It is mostly northwest of Kah Sheets Bay 

and includes Castle River estuary and flats, and the lower 1/3 of the 

watershed. The roadless area also includes the Castle Islands in 

Duncan Canal, Kah Sheets and Lung Islands in Kah Sheets Bay, the 

Level Islands south of Kah Sheets Bay, and several other small 

islands. 

The area is mostly unmodified; however, some of the shoreline along 

Kah Sheets Bay and areas along Little Duncan Bay are outside the 

roadless area boundary due to the presence of roads constructed for 

Rocky Pass 

Inventoried 

Roadless Area 

Castle Inventoried 

Roadless Area 
3 Environment and Effects 

30  Chapter 3 Central Kupreanof Timber Harvest FEIS 

timber management in the mid 1970s. The older harvested areas are 

mostly natural appearing as they mature. 

The Castle River IRA was rated 25 out of a possible 28 points using 

WARS and ranked 12th along with 12 other Tongass inventoried 

roadless areas. 

Approximately 188 acres of the IRA are within the project boundary; 

however, there are no proposed or reasonably foreseeable future 

activities within this roadless area. Therefore this inventoried roadless 

area will not be discussed further. 

Environmental Consequences 

The 2003 Forest Plan SEIS GIS layer as incorporated by the 2008 

Forest Plan reflects the best and most current information for the 

Tongass inventoried roadless areas and was used for summarizing the 

information required for the analysis. No changes have been made to 

these roadless area boundaries or values since the 2003 Forest Plan 

SEIS inventory. The analysis boundary for direct and indirect effects 

includes the entire North Kupreanof, South Kupreanof, and Rocky 

Pass Inventoried Roadless Areas. 

Effects will be measured by acres of harvest and miles of road 

construction within roadless area boundaries as well as total acres 

affected by proposed activities. Total acres affected will include the 

600-foot buffer around harvest units and 1,200-foot buffer placed 

around roads (2003 Forest Plan SEIS). For the 2003 Forest Plan SEIS 

inventory, helicopter logged units that were not adjacent to a road or 

associated cable unit were included as part of the inventoried roadless 

areas. In accordance, all helicopter units for this project will not 

receive the 600-foot zone of influence buffer (2008 FEIS, p. 3-443). 

Direct and Indirect Effects of the 

Alternatives 

This analysis does consider that helicopter logging will influence 

roadless characteristics. Effects to wildlife and other resources in 

helicopter units would be less than clearcut units since 60 percent of 

the stand will remain after harvest. Temporary roads and NFS roads 

were given the same buffer (1,200 feet) and are similarly treated in this 

analysis although temporary and closed system roads may have a 

lower degree of influence on wildlife, watershed and recreation 

resources after the timber harvest is complete. Temporary roads in 

particular will continue having a diminishing effect on inventoried 

roadless areas over time as natural revegetation and water drainage are 

established. 

Methods 

Effects Common 

to all Action 

Alternatives 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 31 

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

created by the 600-foot buffer and 1200-foot buffer around harvest 

acres and roads. These buffers were used by the Roadless Area 

Inventories in the 2003 SEIS and in the update of effects in the 2008 

Forest Plan amendment to account for the influence of harvest and 

roads. This analysis shows the main reduction is from these buffers 

and indirect effects to IRAs. 

While the overall roadless characteristic of each inventoried roadless 

area would remain unchanged, individually identified roadless values 

would either remain unchanged or be minimally influenced by the 

proposed activities. Soil, water and air quality would remain 

unchanged. There would be no effect to public drinking water. Each 

roadless area would still be able to support a diversity of plant and 

animal communities and provide habitat for sensitive species (no 

threatened or endangered species exist within the project area). While 

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

variety of recreation experiences including primitive, semi-primitive 

non-motorized and semi-primitive motorized classes. All inventoried 

roadless areas would still provide large areas in natural settings that 

could serve as reference landscapes. While there would be limited 

visible changes to the inventoried roadless areas, overall scenic 

qualities would not change. No traditional or cultural properties or 

sacred sites would be affected by the proposed activities. No 

Attractions or Features of Special Interest (as identified in the Forest 

Plan SEIS) would be affected by the implementation of any action 

alternative. 

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

Pass Inventoried Roadless Areas would remain greater than 5,000 

acres in size and eligible for Wilderness consideration in subsequent 

forest planning. Areas are rated using the Wilderness Attribute Rating 

System (WARS). WARS ratings for each inventoried roadless area are 

not expected to change with implementation of any alternative. 

Comparison of Alternatives 

Alternatives 2 and 3 include timber harvest within the boundaries of 

the North Kupreanof, South Kupreanof, and Rocky Pass Inventoried 

Roadless Areas. The predominant effect would be to the South 

Kupreanof Roadless Area with approximately 341 acres of timber 

harvest and one mile of new NFS road in Alternative 2 and the harvest 

of 1,184 acres and 15 miles of road construction in Alternative 3. In 

comparison, the North Kupreanof Inventoried Roadless Area acres of 

harvest would vary from 90 acres in Alternative 2 to 152 acres in 

Alternative 3. No new roads are proposed within the North Kupreanof 

or Rocky Pass Inventoried Roadless Areas. Both Alternative 2 and 3 
3 Environment and Effects 

32  Chapter 3 Central Kupreanof Timber Harvest FEIS 

propose three acres of timber harvest within the Rocky Pass 

Inventoried Roadless Area. 

Of the three action alternatives, Alternative 3 affects the most total 

roadless acres. Up to 5,273 acres would be treated as developed in the 

South Kupreanof Inventoried Roadless Area. The affected acres 

represent about two percent of the South Kupreanof Inventoried 

Roadless Area. 

Alternative 4 avoids timber harvest and road building within the 

boundary of inventoried roadless areas. However, the application of 

the 600 feet and 1,200 feet around harvest units and roads would spill 

into the inventoried roadless area boundaries. Alternative 4 affects the 

least total roadless acres of any action alternative. 

Tables 3-10 through 3-12 display the effects to inventoried roadless 

areas by Alternative. 

This alternative does not propose road construction or timber harvest 

and would have no effect on any inventoried roadless areas. 

In the North Kupreanof Inventoried Roadless Area, timber harvest 

would total approximately 90 acres, with no NFS or temporary road 

construction. Unit 216 would total approximately 32 acres of harvest 

by single tree selection and helicopter yarding. Harvest proposed by 

clearcut methods and conventional yarding include Units 215 and 903, 

totaling approximately 58 acres. Approximately 294 total roadless 

acres (0.3%) would be affected with the 600 foot delineation around 

harvest units. 

Alternative 2 proposes approximately 341 acres of timber harvest and 

one mile of NFS road construction in the South Kupreanof Inventoried 

Roadless Area. Units 218, 219, 222, 223, 224, 232, 233, 234, 235, and 

249 would remove approximately 211 acres by single tree selection 

and helicopter yarding. Harvest proposed by clearcut methods and 

conventional yarding include Units 250, 252, 253, 270, 282, 284, and 

285, which total approximately 130 acres. Approximately 881 total 

acres (0.4%) would be affected with application of the 600 feet around 

harvest units and 1200 feet for road construction. 

Approximately three acres of timber harvest (Unit 310 by clearcut 

methods) is proposed in the Rocky Pass IRA. No road construction 

would occur inside the Inventoried Roadless Area boundary. A total 

of approximately 80 acres (0.1%) would be affected. 

For all Inventoried Roadless Areas in Alternative 2, the characteristic 

values for availability as wilderness would remain unchanged. No 

unique attributes would be affected. The biological value of oldgrowth forest would be reduced proportionally by the amount of 

timber harvest in each inventoried roadless area. The scenic 

Alternative 1 

Alternative 2 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 33 

conditions to the Rocky Pass Inventoried Roadless Area would only be 

slightly changed by timber harvest activities outside the Inventoried 

Roadless Area. 

Alternative 3 proposes approximately 152 acres of timber harvest and 

no road building within the North Kupreanof Inventoried Roadless 

Area. Approximately 32 acres (Unit 216) of harvest would be by 

single tree selection and helicopter yarding. Harvest proposed by 

clearcut methods and conventional yarding include Units 215 and 903, 

totaling approximately 58 acres. Approximately 356 total acres 

(0.4%) would be affected. 

Alternative 3 proposes about 1,184 acres of timber harvest, 13 miles of 

NFS road, and two miles of temporary road within the South 

Kupreanof Inventoried Roadless Area. All or portions of Units 218, 

219, 221, 222, 223, 224, 232, 233, 234, 235, 236, 239, 241, 243, 246, 

248, 249, 250, 252, 253, 254, 257, 258, 260, 261, 262, 263, 264, 265, 

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

285, and 286 would be within the roadless area. Approximately 5,273 

total acres (2.4%) would be affected with application of the 600-foot 

and 1,200-foot around harvest units and roads. 

Under Alternative 3, the Rocky Pass roadless area would be affected 

by the three acres of timber harvest proposed in Unit 310 by clearcut 

methods. No road construction would occur inside the inventoried 

roadless area boundary. Approximately 80 total acres (0.1%) would 

be affected. 

For all inventoried roadless areas in Alternative 3, the characteristic 

values for availability as wilderness would remain unchanged. The 

biological value of old-growth forest would be reduced proportionally 

by the amount of timber harvest in each roadless area. The scenic 

conditions to the Rocky Pass Roadless Area would only be slightly 

changed by timber harvest activities outside the Inventoried Roadless 

Area. 

Alternative 4 proposes no timber harvest or road building within the 

North Kupreanof, South Kupreanof, or Rocky Pass Inventoried 

Roadless Areas. However, when the 600-foot and the 1,200-foot 

buffers are applied to harvest units and roads proposed outside and 

adjacent to the inventoried roadless areas, the Inventoried Roadless 

Areas would be influenced by proposed activities. Total acres affected 

would include 24 acres (0.02%) in the North Kupreanof Inventoried 

Roadless Area, 103 acres (0.04%) in the South Kupreanof Inventoried 

Roadless Area, and 13 acres (0.01%) in the Rocky Pass Inventoried 

Roadless Area. 

For all inventoried roadless areas in Alternative 4, the characteristic 

values for availability as wilderness would remain unchanged. No 

Alternative 3 

Alternative 4 
3 Environment and Effects 

34  Chapter 3 Central Kupreanof Timber Harvest FEIS 

unique attributes would be affected. The biological value of oldgrowth forest would not be reduced as no timber harvest would occur 

within any Inventoried Roadless Area. 

Table 3-10. North Kupreanof Inventoried Roadless Area(99,566) 

Measure of Direct and Indirect 

Effects By Alternative 1 2 3 4 

Acres of timber harvest 0 90 152 0 

Miles of NFS roads (closed after 

harvest) 0 0 0 0 

Miles of temporary roads 

(decommissioned after harvest) 0 0 0 0 

Total acres affected including 

buffers (600' for harvest units, 1200' 

for roads)1

0 294 356 24 

Percent of North Kupreanof 

Roadless Area affected 0% 0.3% 0.4% 0.02%

1

 Helicopter units do not receive buffers. 

Table 3-11. South Kupreanof Inventoried Roadless Area 

(213,122 acres) 

Measure of Direct and Indirect 

Effects By Alternative 1 2 3 4 

Acres of timber harvest 0 341 1,184 0 

Miles of NFS roads (closed after 

harvest) 0 1 13 0 

Miles of temporary roads 

(decommissioned after harvest) 0 0 2 0 

Total acres affected including 

buffers (600' for harvest units, 1200' 

for roads)1

0 881 5,273 103 

Percent of South Kupreanof 

Roadless Area affected 0% 0.4% 2.4% 0.04%

1 Helicopter units do not receive buffers. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 35 

Table 3-12. Rocky Pass Inventoried Roadless Area 

Measure of Direct and Indirect 

Effects By Alternative 1 2 3 4 

Acres of timber harvest 0 3 3 0 

Miles of NFS roads (would be 

closed after harvest) 0 0 0 0 

Miles of temporary roads (would 

be closed after harvest) 0 0 0 0 

Total acres affected including 

buffers (600' for harvest units, 

1200' for roads)1

0 80 80 13 

Percent of Rocky Pass 

Inventoried Roadless Area 

affected 

0% 0.1% 0.1% 0.01%

1

 Helicopter units do not receive buffers. 

Direct and Indirect Effects of Associated 

Timber Harvest Activities 

Utilization of the existing Little Hamilton LTF for log transfer, 

storage, and camp operations would have no direct effects as they 

occur outside inventoried roadless area boundaries. However, use of 

the LTF, across the bay from Rocky Pass Inventoried Roadless Area 

would indirectly affect users as water traffic in the Hamilton Bay and 

mouth of Rocky Pass would temporarily increase (although logging 

traffic would most likely avoid the shallow waters of the Rocky Pass). 

Sights and sounds of logging operations would also temporarily affect 

roadless recreation in the adjacent portion of the roadless area. Effects 

from other ground disturbing activities necessary to implement the 

Central Kupreanof project such as rock pit development are included 

in the footprint and total effect of road construction. 

Cumulative Effects 

The cumulative effects analysis boundary for Inventoried Roadless 

Areas includes the entire inventoried roadless area both inside and 

outside of the project area, since any effect outside the project area 

may have the potential to reduce the size of the roadless area and 

represent a cumulative effect. The Catalog of Events for Kupreanof 

Island was referenced in determining cumulative effects. 
3 Environment and Effects 

36  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The Petersburg Ranger District is currently analyzing Access Travel 

Management. Road management decisions will become part of the 

District’s Motor Vehicle Use Map to be published in 2009. Road 

closures adjacent to roadless area boundaries would influence the 

quality of the North Kupreanof, South Kupreanof, and Rocky Pass 

Inventoried Roadless Areas by reducing the adjacent sights and sounds 

of vehicle traffic at current levels while roads remain closed. 

Harvest of the remaining NEPA cleared units from the Bohemia 

Mountain ROD will harvest an additional 58 acres within the North 

Kupreanof Roadless Area. With delineation of the 600 feet and 1,200 

feet, total acres affected would be about 104, or about 0.1%. Total 

cumulative effects to the North Kupreanof IRA would range from 

0.1% with the No Action Alternative up to 0.5% with Alternative 3. 

Remaining units from Shamrock EIS have been incorporated into the 

Central Kupreanof unit pool and would not be harvested separately. 

Cumulative effects on inventoried roadless areas were reanalyzed in 

the 2008 Forest Plan Amendment. During this analysis for the Forest, 

the unique characteristics and values of the inventoried roadless areas, 

their location, and proximity to other inventoried roadless areas, 

especially Congressionally-designated Wilderness Areas, were 

evaluated. To determine the final allocations for development, in the 

Selected Alternative of the Record of Decision, decisions were made 

based on the specific factors and characteristics listed above. 

There are currently 9.6 million acres of land that are considered 

inventoried roadless areas on the Tongass National Forest. Even with 

full implementation of activities allowed under the 2008 Forest Plan 

Amendment and no further Wilderness designation, 80 percent of the 

Tongass would remain in an undeveloped condition without roads 

after 100 years. None of the alternatives for the Central Kupreanof 

Timber Harvest project would affect the future Wilderness eligibility 

of any affected inventoried roadless area after implementation. 

It is reasonable to assume that timber harvest and associated road 

management will continue on Kupreanof Island. Although in all 

alternatives for the Central Kupreanof Timber Harvest project roads 

affecting inventoried roadless areas will be closed within ten years 

after the completion of timber harvest activities, it is intended these 

roads will be used and additional roads be planned for future access to 

the suitable timber within inventoried roadless areas. 

Since timber harvest and associated road building and major facilities 

are not allowed within non-development LUDs, a considerable portion 

of the inventoried roadless areas on Kupreanof Island would remain in 

a natural state for the life of the Forest Plan. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 37 

Effects of Projects Common to all Action 

Alternatives 

The Big John Trail and Cabin are located with the Rocky Pass 

Inventoried Roadless Area. Maintenance of these recreation facilities 

would continue to enhance the current recreation experience; however, 

because these are existing developed recreation facilities and 

maintenance will occur within the existing footprint, no additional 

direct or indirect effects are expected to the roadless area. 

Opportunities to pull or replace red fish crossings are dependent on 

decisions made in the District ATM process; however any road 

closures adjacent to roadless area boundaries would influence the 

quality of the North Kupreanof, South Kupreanof, and Rocky Pass 

Inventoried Roadless Areas by reducing the adjacent sights and sounds 

of vehicle traffic from current levels while roads remain closed. There 

would be no other direct, indirect or cumulative effects from the 

Projects Common to all Action Alternatives as none of these activities 

enter into Inventoried Roadless Area boundaries or influence their 

roadless characteristics. 

There would be no significant effect from a Microsales program to 

inventoried roadless areas as these activities would occur on existing 

NFS roads open for long term management. 
3 Environment and Effects 

38  Chapter 3 Central Kupreanof Timber Harvest FEIS 
901

314

1 5

207

252

7

206

276

250

205

905

270

903

502

217

265

234

284

258

6

282

219

318

204

263

261

277

248

501

203

275

310

209

215

241

900

235

280

272

221

285

208

243

224

2

286

279

260

313

305

202

304

253

257

320

273

3

229

309

264

231

266

271

307

274

281

246

315

216

201

268

218

232 233 236

312

316

222

306

904

267

254

249

317

262

230

223

239

214

255

269

c:/workspace/ckupre/plots/deis/fig3_1_roadless.mxd 09-20-08 EP

Legend

Unit Pool

Developed Areas

Inventoried Roadless Area

Unroaded area > 1000 and < 5000 acres

Wilderness

Private Land

Project Area Boundary

Existing Open NFS Road

Existing Closed NFS Road

Portage and Tonka Existing NFS Road

SOUTH KUPREANOF IRI

NORTH KUPREANOF IRI

SOUTH KUPREANOF IRI

SOUTH KUPREANOF IRI

0 1 2 4

Miles

 ̄

Duncan

Canal

Big John 

Bay

R o c k y P a s s

Central Kupreanof Timber Harvest

Figure 3-1

Inventoried Roadless Areas

ROCKY PASS IRI

CASTLE IRI

LINDENBERG

IRI
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 41 

Issue 3- 

Road Management/Access 

The construction, reconstruction and use of forest roads associated 

with the Central Kupreanof Timber Harvest may change access within 

the project area. 

Roads influence wildlife populations, water quality, subsistence use, 

the type of recreational opportunities available and the ability to 

maintain open roads. Comments ranged from requesting no more new 

roads, closure of most existing roads, and requests to increase access 

by new roads and opening more existing roads. This analysis considers 

the effects of the new construction and reconstruction of roads used to 

access the proposed timber harvest. It will also analyze the status of 

these roads after timber harvest (open or close). 

National Forest System (NFS) roads are constructed to provide access 

to NFS lands (Transportation Standards and Guidelines in Chapter 4 of 

the Forest Plan). They are considered NFS roads as are other roads that 

are wholly or partially on NFS lands and are intended to be maintained 

for the long term (see Chapter 4 for a glossary with transportation 

terms). Most forest roads are single lane, constructed with blasted 

quarry rock, and designed for off-highway loads. 

For the Tongass, the demand for roads has primarily been a function of 

the demand for access to timber resources. The maintenance and 

reconstruction requirements of the existing system depend mainly on 

the volume of timber hauled and, to a lesser extent, on recreational 

use. Road maintenance consists of periodic repairs to an existing road 

surface, brushing, cleaning, and repairing drainage features. These 

tasks are performed to keep the roads in the safe and useful condition 

for which they were designed. Repairs may be accomplished as annual 

maintenance. The amount of future construction is anticipated to be 

largely determined by the need to access timber resources. 

Roads have the potential to affect fish habitat, soils, and water quality 

by increasing erosion and landslide potential, changing recreation 

settings and opportunities, altering scenery, and increasing wildlife 

harvest. These types of effects are discussed in the subject resource 

sections. 
3 Environment and Effects 

42  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 Miles of new NFS road constructed 

 Miles of temporary road construction 

 Miles of reconstructed NFS road 

 Miles of road to remain open to motorized vehicle traffic 

 Miles of road to be closed associated with this timber harvest 

project 

 Miles of new NFS and temporary road construction in 

inventoried roadless areas 

 Cost including maintenance of open roads, reconstruction, and 

new (NFS and temporary) road construction 

Affected Environment for Roads 

The existing roads in the Central Kupreanof project area are connected 

to a contiguous road system consisting of approximately 114 miles of 

NFS roads on the northern portion of Kupreanof Island known as the 

Kake Road System. There are approximately 79 miles of existing NFS 

roads within the Project Area, 64 miles are currently open to motorized 

vehicles (see Table 3-15). All roads within the project area fall under 

Forest Service jurisdiction. 

NFS roads were constructed as part of previous timber sale contracts 

for the purpose of timber haul and administration. Most of the road 

use on the island is administrative, logging traffic or because of the 

proximity of the Kake, by the public. Traffic is primarily seasonal. 

Roads are usually closed December thru April by snow. 

Project area roads may be accessed from the community of Kake by 

NFS Road 6040 or from the existing Log Transfer Facility (LTF) at 

Little Hamilton Bay. NFS roads 6000, 45006, portions of 6030 and 

6040 are not located within the Central Kupreanof project area, but 

would be used by administrative traffic, and for the transport of 

harvested timber. 

Kupreanof Island’s transportation system is accessible by the Alaska 

Marine Highway. An additional road system, operated by local Alaska 

Native Corporations, connects to the city of Kake. 

An NFS road is “a forest road other than a road which has been 

authorized by a legally documented right-of-way held by a State, 

county or other local public road authority.” NFS roads are generally 

required to provide long-term or intermittent motor vehicle access. 

Units of Measure 

NFS Road 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 43 

These roads receive constant or intermittent use depending upon the 

timing of the timber harvest(s) and other activities. NFS roads form 

the primary transportation network in the project area. NFS roads 

have in the past been referred to as “Forest Development Roads,” 

“classified,” “system” roads, or “specified” roads. 

Unauthorized roads include unplanned roads, abandoned travel ways, 

and off-road vehicle tracks that have not been designated and managed 

as a trail. Roads that are no longer under permit or other authorization 

and have not been decommissioned are also considered unauthorized. 

 “A road or trail necessary for emergency operations or authorized by 

contract, permit, lease, or other written authorization that is not a forest 

road or trail and that is not included in a forest transportation atlas.” 

Temporary roads are intended for short-term use and maintained for a 

limited time usually to access a timber harvest unit. Temporary roads 

are decommissioned by removing culverts and bridges after a timber 

harvest. Temporary roads have also been called “spur” roads. 

Road decommissioning activities result in the stabilization and 

restoration of unneeded roads (in the long-term) to a more natural 

state. The term generally refers to temporary roads constructed for 

timber harvests that have had stream courses restored, culverts 

removed, waterbars added where needed, and cut and fill slopes 

revegetated. Decommissioning can occur for all three types of roads. 

For NFS roads, decommissioning removes the road from the long-term 

forest road transportation system. Otherwise, the act of 

decommissioning is the same for all roads. Action on the ground for 

decommissioning ranges from blocking the entrance and removing 

drainage structures to obliterating the road, returning the natural 

contours, and replanting vegetation. The end result is the stabilization 

and restoration of unneeded roads to a more natural state (36 CFR 

212.1). 

A road is a motor vehicle travel way over 50 inches wide, unless 

National Forest System and managed as a trail. A road may be 

National Forest System, unauthorized, or temporary (36 CFR 212.1). 

Unauthorized 

Road 

Temporary Road 

or Trail 

Road 

Decommissioning 

Road 
3 Environment and Effects 

44  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-13. Miles of Road by Maintenance Levels 

Miles of Road 

By 

Maintenance 

Level 

1- Basic 

Custodial 

Care 

2- High 

Clearance 

Vehicles 

3- Suitable 

for 

Passenger 

Cars 

Total 

Miles 

Project Area 

NFS Road 

14.7 32.7 31.7 79.1 

NFS Roads 

Outside 

Project Area 

Used For 

Haul to LTF 

0 1.3 6.1 7.4 

Decommissioned Former Temporary Roads Miles 10.1 

There is a need for a rock source for the construction of new NFS and 

temporary roads, and the reconstruction, and maintenance of the 

existing NFS roads in this project. It is preferred that the rock source 

is close to the site of road construction or maintenance, usually within 

two miles is best. 

There are numerous rock quarries throughout the project area and 

usually there is one within a few miles of the proposed site. The easy 

accessibility of existing rock quarries may eliminate the need to 

develop some new rock quarries. Existing rock quarries in the project 

area that are available for future expansion and use are shown on 

Figure B-1. 

New rock quarries may be developed to support new road construction 

and road maintenance. Quarry sites would be developed within 500 

feet of a road and avoid Class I and Class II stream buffers, and eagle 

and goshawk nest tree buffers. With either the expansion of an existing 

quarry or the development of a new site, the area footprint would not 

exceed five acres. 

The transfer of harvested timber requires that logs be hauled directly to 

mills by trucks, or removed from trucks, transferred to salt water then 

towed to a mill by barge. The existing permitted LTF is located in 

Hamilton Bay. Approximately 4 miles outside of the Central 

Kupreanof project area, Little Hamilton LTF is a steel piling and 

concrete dock facility. The permit allows for both rafting or barging 

of logs. 

Hamilton Bay was placed on the 1996 Section 303 (d) list for debris. 

Past dive surveys had indicated that excessive bark existed on the 

Rock Quarries 

Log Transfer 

Facility (LTF) 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 45 

bottom of Hamilton Bay as a result of logging operations on 

Kupreanof Island that used the Hamilton Bay log transfer facility. 

Dive survey reports from September 2000 and June 2002 of 0.6 acre 

coverage document that this water is compliant with standards. This 

water was removed from the Section 303 (d) list in 2002/2003. 

All action alternatives would use the sort yard adjacent to the Little 

Hamilton LTF. This sort yard is approximately 2 1⁄2 acres in size 

located next to the LTF on Road 6000. Presently the sort yard is in 

good condition with a clean surface of rock aggregate. 

No land camp is proposed in the project area for any of the 

alternatives. National Forest Lands across from the Kake 

administrative facility have been used as a logging camp in the past. A 

special use permit would have to be approved before this site could be 

used. The town of Kake or a floating camp could be used during 

harvest activities. Appropriate permits would need to be acquired by 

the operator for use of a floating camp. 

There are no Forest Service administrative sites in the Project Area. 

The Kake administration site is located approximately 9 miles 

northwest of the Project Area Boundary. 

The desired condition for the forest transportation system is guided in 

part by 36 CFR 212.5 - Road System Management. Part b provides 

guidance for determining the minimum road system needed. Among 

other direction, the Roads Rule requires that an area-specific roads 

analysis be completed and a determination of need for amendment or 

revision of the Forest Plan be made if any roads are to be constructed 

or reconstructed in inventoried roadless or contiguous unroaded areas, 

until forest-wide roads analysis has been completed (FSM 7712.16(c)). 

No amendment would be required to the Forest Plan with 

implementation of any alternative. 

For the Central Kupreanof project area, “The Kake Road Analysis 

Report” was completed in September 2000 for the Kake area. 

Analyzing this area is a logical unit since the road system is not 

connected to any other island or the mainland, except by water or air 

transportation. In April 2008, this road analysis was updated by the 

Central Kupreanof Inter-Disciplinary team (ID Team). The Road 

Analysis Process (RAP) for the Kake Road System is a science-based 

system of analysis and tiered to the Tongass Forest-wide RAP (USDA 

Forest Service 2003). 

The Kake Road System RAP consists of a report and accompanying 

maps and tabular information located in the Central Kupreanof project 

record. While this road analysis does not contain any road 

management decisions, it does make recommendations for road 

management objectives (RMOs). For those roads associated with 

Sort Yard 

Logging Camp 

Forest Service 

Facilities 

Roads Analysis 

Process 
3 Environment and Effects 

46  Chapter 3 Central Kupreanof Timber Harvest FEIS 

proposed timber harvest activities, the recommendations have been 

analyzed in this EIS and decisions for those roads will be made in the 

Record of Decision. New and reconstructed roads that remain open 

for interim public use will be designated as such on the District Motor 

Vehicle use Map (MVUM). Subsequent closures of these roads 

pursuant to ANILCA Section 811 (b) will be incorporated into the 

annual review of the MVUM, during the year in which the closure 

takes effect. Recommendations for roads not used with this timber 

sale proposal will be carried forward and analyzed in the District’s 

Access Travel Management EA. 

Methods 

The analysis area for the transportation system includes the project 

area and road segments leading into the project area. Information 

sources for transportation analysis include the transportation GIS 

records which house the spatial data for road locations. An inventory 

of road attributes for NFS roads is maintained on National Forest 

through the I-Web database. A complete list of road attributes and 

definitions of these attributes is located in the project record. Forest 

Service personnel have conducted road condition surveys on many of 

the existing roads in the project area. These surveys supply site 

specific detailed information about each road (and section of road) 

surveyed, including: 

 Whether the road, or a particular section of the road, is 

drivable; 

 Number, size, and condition of drainage structures and bridges; 

 Barriers to vehicle access (e.g., vegetation, barrier ditches, 

pulled bridges, slides); 

 Maintenance requirements; and 

 Barriers to fish passage through road drainage structures 

Proposed new road location corridors are planned using aerial photo 

interpretation and GIS layers (including topography, streams, 

vegetation and soils) and field investigations, to access proposed units. 

Some, but not all, of the primary concerns include: minimizing rock 

excavation, selecting stable stream crossings, minimizing the traverse 

of steep slopes, avoiding areas of unstable soils and wetlands, 

minimizing impacts within riparian areas, and avoiding wildlife 

buffers. The intent is to select a location that balances acceptable 

environmental impact with the lowest construction and maintenance 

costs. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 47 

Areas of concern on new road construction routes are field reviewed 

by resource specialists. Field information such as specific comments 

and concerns along with site-specific mitigation measures are 

incorporated into the respective resource analysis and reports as well 

as into the design criteria on the road cards (Appendix B). Cumulative 

effects are discussed jointly at the end of the direct and indirect effects 

analysis for alternatives. All road mileage is approximate. 

Environmental Consequences and 

Effects Common to all Action Alternatives 

The effects of roads and access management on resources are 

discussed in their respective resource sections and reports. Site 

specific design criteria can be found on the road cards. 

Under alternatives 2, 3, and 4, road maintenance would occur on roads 

used for timber haul associated with this project. Maintenance 

activities could include road grading, brushing, ditch cleaning, and 

culvert cleaning. Other repairs would take place during timber haul 

operations on an as needed basis. 

All road construction would follow the applicable BMPs and meet or 

exceed Forest Plan Standards and Guidelines. 

The amount and level of maintenance and repair is dependent upon 

traffic management objectives and maintenance criteria. Road 

reconditioning is heavier maintenance on an existing road such as 

culvert replacement, surface rock replacement, and subgrade repair. 

Road reconstruction is an activity that results in improvement or 

realignment of an existing National Forest System road. Road 

improvement results in an increase of an existing road’s traffic service 

level, expansion of its capacity, or a change in its original design 

function. Road realignment results in a new location of an existing 

road or portions of an existing road and treatment of the old roadway 

(36 CFR 212.1). 

Maintenance of existing NFS roads is an ongoing process that occurs 

on a periodic basis. Normally this kind of road work is determined to 

fit the category of routine repair and maintenance of roads that do not 

individually or cumulatively have a significant effect on the quality of 

the human environment and may be categorically excluded (FSH 

1909.15, 31.12). The maintenance of NFS roads in the project area 

may occur before, during, and after the project analysis. This work is 

done through separate service contracts to reduce the backlog of 

deferred maintenance, comply with best management practices, 

maintain the existing infrastructure for the proposed timber sale or any 

Road 

Maintenance 
3 Environment and Effects 

48  Chapter 3 Central Kupreanof Timber Harvest FEIS 

future harvest entries, and other National Forest management 

activities. The timing of this work may coincide with this project's 

analysis but is not part of the proposed action or alternatives being 

considered. Any effects from the road maintenance work are included 

in the cumulative effects analysis for this project. 

In addition to using the existing roads, some new NFS and temporary 

road construction would be needed to access harvest units within the 

project area for silvicultural activities. All new construction would be 

off of the existing road system. All newly constructed NFS road will 

be managed as a maintenance level 2, open to motorized vehicle 

traffic, during timber sale activities. These roads would be either 

constructed in a self maintaining hydrological status, or after 

completion of the timber sale activities, be placed in a self-maintaining 

hydrologic status. They may remain open an additional five to ten 

years for other activities such as regeneration surveys and firewood 

removal. This would include the placement of drivable water bars or 

dips at all drainage culvert locations to direct water across the road in 

event that the culvert becomes blocked. Other design elements like 

oversized culverts may be used to help reduce the need for routine 

drainage maintenance. 

All newly constructed NFS roads would be intermittent service roads 

(maintenance level one) within ten years and would be physically 

blocked, or natural vegetation allowed to eliminate motorized access. 

Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A 

review will be conducted at the time of closure for any additional 

resource concerns needing addressed. 

NFS roads are needed for long term management of the National 

Forest to access future timber lands or have resource concerns that 

require engineering controls in construction. Closed NFS roads 

needed in the future could be re-opened for timber salvage and/or 

expansion into development LUDs. 

Temporary roads are not needed for long term management of the 

National Forest. Temporary roads do not access future timber lands 

and do not have resource concerns that require engineering controls in 

construction. All temporary roads would be decommissioned after 

timber harvest. This involves removing culverts and bridges, restoring 

natural drainage patterns, and allowing the roadway to re-vegetate. 

Proposed New 

Roads 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 49 

Table 3-14. Proposed New Road Miles in the Central Kupreanof 

Timber Harvest Project Area 

Alternative 

1 

Alternative 

2 

Alternative 

3 

Alternative 

4 

Proposed 

New NFS 

Roads 

0 7.3 25.1 0.0 

Proposed 

Temporary 

Road 

0 3.9 6.1 2.2 

Roads proposed for reconstruction are existing NFS roads currently in 

storage; most drainage structures have been removed to restore natural 

drainage patterns and the roadway has re-vegetated with alders 4-inch 

to 8-inch in diameter. Reconstruction activities would include 

brushing, clearing of alders and replacing drainage structures. 

Reconstruction would keep the roads in a safe and useful condition for 

which they are managed, while meeting Forest Plan Standards and 

Guidelines and following the applicable BMPs (See RMO road cards 

in Appendix B for site-specific items). 

When developing a transportation system to support timber harvest, 

the Forest Plan directs to perform an integrated logging system and 

transportation analysis to determine the least-cost facility (considering 

cost of construction, maintenance, and hauling) and design standards 

necessary to meet LUD objectives. This is accomplished on an 

alternative by alternative basis through the NEPA Economic Analysis 

Tool – Residual Value (NEAT_R) version 2.15. This analysis is 

discussed further in the Timber Supply and Sale Economics section in 

this chapter. 

Table 3-15 summarizes the proposed road construction and 

reconstruction by alternative. Road Management Objectives (RMOs) 

are included as part of Appendix B. The RMOs specify the design 

criteria, best management practices, resource concerns, and mitigation 

for each NFS road. 

Estimated average cost of new NFS road is $200,000 per mile, average 

road reconstruction cost of $50,000 per mile, and average cost of new 

temporary road of $130,000 per mile. NFS roads in Southeast Alaska 

are more expensive to build than in other parts of the nation. The 

major factor that contributes to higher costs is obtaining the rock for 

the roadbed. Rock is obtained by blasting bedrock, which is then 

Roads Proposed 

for 

Reconstruction 

Road Costs 
3 Environment and Effects 

50  Chapter 3 Central Kupreanof Timber Harvest FEIS 

hauled and shaped into a road over typically soft uneven terrain. Other 

factors that contribute to the high cost of constructing roads include 

the higher costs of shipping and labor, the numerous drainage 

structures needed, and complex logistics. 

An analysis was completed for the location of all new roads to 

minimize impacts to soils, water and associated resources in 

accordance with BMPs. Road location will be completed to avoid 

wetlands whenever practicable. Wetlands were unavoidable on some 

portions of the location due to safety, engineering design constraints 

and consideration for other resources. Alternatives to the location on 

wetlands would mean longer, higher-cost roads that may have 

impacted similar areas of wetlands. High value wetlands were 

particularly avoided wherever practicable. 

There are approximately 114 miles of NFS roads in the Kake road 

system, which encompasses the Central Kupreanof Timber Harvest 

project area. Of those 114 miles of roads there are approximately 94 

miles of open roads (64 miles within the project area) that need 

maintenance to remain open. This maintenance generally includes 

brush cutting, blading of the road surface, ditching and cleaning of 

culverts to keep proper drainage. Of the 94 miles of open road, there 

are approximately 38 miles of mainline roads (6040, 6328, 6314, 

6314S) that take first priority for maintenance. 

Petersburg Ranger District historically has approximately $70,000 per 

year to spend on road maintenance in Kake. On the average it costs 

about $2,000 per mile to maintain roads which equates to 

approximately 35 miles of road per year that can be done in Kake. 

Generally, two thirds of the mainline roads are done and the remaining 

portion is spent on some selected side roads. 

The only direct, indirect, or cumulative effects from transportation 

projects would be improved access due to keeping roads open. The 

removal of red fish crossings are dependent on the analysis and 

decisions made in the District’s ATM EA document. The remaining 

Projects Common to all Action Alternatives would have no effects on 

the transportation system. 

A Microsale program located along existing roads open for long-term 

use would have no effects on the transportation system as no new 

roads (NFS or temporary) would be built or closed in association with 

Microsale activities. 

Wetlands 

Avoidance 

Projects Common 

to all Action 

Alternatives 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 51 

Direct and Indirect Effects 

Alternative 1 does not propose any new road construction. This is the 

no action alternative. 

Under this alternative, current management plans would continue to 

guide the management of NFS roads. All system roads would be 

managed as directed by the Forest Plan, road management objectives, 

and previous NEPA decisions. This alternative would not increase, 

nor decrease, access to this area for recreation or subsistence activities. 

The 64 miles of currently open NFS road within the project area would 

remain open and maintenance would continue to be ongoing. 

Alternative 2 proposes construction of approximately 7.3 miles of NFS 

road. About 1.0 mile of construction would enter the South Kupreanof 

Inventoried Roadless Area. Future harvest along these roads is a 

possibility, as well as future extensions. This alternative would 

enhance opportunities for other timber harvest projects by providing 

access through suitable timber lands. 

Alternative 2 proposes about 2.9 miles of reconstruction of existing 

NFS road to access timber harvest. This would include activities such 

as culvert replacement, surface rock replacement, and sub grade repair. 

The following NFS roads would be used in this alternative; 45803, 

45805, 45807, 45808, 45810, 45885, 45886, 45887, 45888, 45889, 

45890, 45891, 45893, 45894, 45898, 45899, 6000, 6040, 6314, 6314S, 

6315, 6326, 6327, 6328, 6330, 6333, 6334, 6336 and 6339.. For more 

specific information regarding these roads see Appendix B Road 

Cards. 

This alternative proposes approximately 3.9 miles of temporary road. 

All of the temporary roads would be decommissioned after timber 

harvest. See unit cards for temporary road site-specific detail. 

This alternative would use Little Hamilton LTF (Log Transfer 

Facility) and incur approximately $2,039,000 in road costs. 

There would be new stream crossings that may require site-specific 

design consideration for volume of flow, fish habitat, or other design 

complexity. See road cards for site-specific detail. 

An additional 1.69 miles of existing open NFS Roads (6327, 45805, 

45807) used in the proposed timber harvest, would be closed and 

placed into storage up to ten years after the timber sale. Any red fish 

crossings would be pulled at the time of storage. 

Motorized access would temporarily increase during the timber sale 

and for up to ten years after the completion of timber sale activities. 

Approximately 74.2 miles of road will remain open for up to ten years 

Alternative 1 

Alternative 2 
3 Environment and Effects 

52  Chapter 3 Central Kupreanof Timber Harvest FEIS 

after the timber sale. Motorized access would then decrease in the long 

term as roads are closed and put in intermittent service. Approximately 

62.3 miles of NFS road would ultimately remain open with this 

alternative. Closed roads would still provide a long term increase in 

non-motorized access. 

Roads in storage would remain in a self-maintaining state, making 

more road maintenance funds available. Having more maintenance 

funds available and less miles open to maintain would help maintain 

the open roads to their operating standards and reduce deferred 

maintenance cost. 

Alternative 3 proposes construction of approximately 25.1 miles of 

NFS road. About 13 miles of new NFS road would enter the South 

Kupreanof Inventoried Roadless Area. Future harvest along these 

roads is a possibility as well as future extensions. This alternative 

would enhance opportunities for other timber harvest projects by 

providing access through suitable timber lands. 

This alternative proposes about 9.1 miles of reconstruction of existing 

NFS roads to access timber harvest. This would include activities such 

as culvert replacement, surface rock replacement, and sub grade repair. 

The following NFS roads would be used in this alternative; 45800, 

45803, 45805, 45806, 45807, 45808, 45810, 45885, 45886, 45887, 

45888, 45889, 45890, 45891, 45892, 45893, 45894, 45895, 45896, 

45897, 45898, 45899, 45915, 6000, 6040, 6314, 6314S, 6315, 6326, 

6327, 6328, 6330, 6333, 6334, 6336 and 6339 would be involved in 

this alternative. 

This alternative proposes 6.1 miles of temporary road of which about 

2.0 miles would enter the South Kupreanof Inventoried Roadless Area. 

All temporary roads would be decommissioned after timber harvest. 

This alternative has all the timber transported to Little Hamilton LTF 

and would incur approximately $6,017,000 in road costs. 

There would be new stream crossings that may require site-specific 

design consideration for volume of flow, fish habitat, or other design 

complexity. See road cards for site-specific detail. 

An additional 1.69 miles of NFS roads used in the proposed timber 

harvest (6327, 45805, 45807)) would be closed and placed into storage 

up to ten years after the timber sale. Any red fish crossings would be 

pulled at the time of storage. 

This alternative would have the greatest temporary increase for 

motorized public access to the area. The Project Area would provide 

about 98.2 miles of roads open for motorized vehicle use for up to ten 

years after the timber sale. Motorized access would then decrease as 

Alternative 3 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 53 

roads are closed and put into intermittent service. Ultimately, 

approximately 62.3 miles of NFS road would remain open with 

implementation of this alternative. Closed roads would still provide a 

long-term increase in non-motorized access. 

Roads in storage would remain in a self-maintaining state making 

more road maintenance funds available. Having more maintenance 

funds available and less miles open to maintain would help maintain 

the open roads to their operating standards and reduce deferred 

maintenance cost. 

Alternative 4 proposes no new NFS roads and no new road 

construction in any inventoried roadless areas. Approximately 2.6 

miles of reconstruction of existing NFS road would be needed to 

access timber harvest. This would include activities such as culvert 

replacement, surface rock replacement, and sub grade repair. 

The following NFS roads would be used in this alternative; 45803, 

45805, 45807, 45808, 45810, 6000, 6040, 6314, 6314S, 6315, 6326, 

6327, 6328, 6330, 6333, 6334, 6336 and 6339 would be involved in 

this alternative. 

This alternative proposes 2.2 miles of temporary road. All temporary 

roads would be decommissioned after timber harvest. See unit cards 

for temporary road site specific detail. 

This alternative has all timber transported to Little Hamilton LTF and 

will incur approximately $416,000 in road costs. 

An additional 1.69 miles of NFS roads used in the proposed timber 

harvest (6327, 45805, and 45807) are listed in the RMOs to be closed 

and placed in storage up to ten years after the timber sale. Any red 

fish crossings would be pulled at the time of storage. 

This alternative changes access the least of all action alternatives. 

While Alternative 4 does not create any new access with the 

construction of any NFS roads, motorized access would be slightly 

increased with the 2.6 miles of existing NFS road reconstruction. 

Approximately 66.6 miles of road would remain open for up to ten 

years after the timber sale. Motorized access would then decrease in 

the long-term as roads are closed and put in intermittent service. About 

62.3 miles of NFS road would remain open with implementation of 

this alternative. 

Roads in storage would remain in a self-maintaining state making 

more road maintenance funds available. Having more maintenance 

funds available and less miles open to maintain would help maintain 

the open roads to their operating standards and reduce deferred 

maintenance cost. 

Alternative 4 
3 Environment and Effects 

54  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Comparison of Alternatives Tables 

All roads, both existing and proposed, would be located, designed, 

constructed or reconstructed, and maintained following Best 

Management Practices (BMPs), and other applicable laws, regulations, 

and specifications. Refer to the road cards in Appendix B for more 

information on specific BMPs. 

Table 3-15. Existing and Proposed Open Road Miles within the 

Central Kupreanof Timber Harvest Project Area 

Alt 1 Alt 2 Alt 3 Alt 4 

Miles of Open Existing NFS Road 64 64 64 64 

Miles of Proposed New NFS Road 

Construction 

0 7.3 25.1 0 

Miles of Proposed Temporary 

Road Construction 

0 3.9 6.1 2.2 

Miles of Reconstruction of 

Existing NFS Road 

0 2.9 9.1 2.6 

Total Miles of NFS Road Left 

Open for up to 10 Years after 

Harvest 

64 74.2 98.2 66.6 

Miles of Proposed Existing NFS 

Road to Close within 10 Years of 

Harvest 

0 1.69 1.69 1.69 

Total Miles of NFS Road 

Remaining Open with 

Implementation of Alternative 

64 62.3 62.3 62.3 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 55 

Table 3-16. Planned Road Construction Miles and Cost by 

Alternative 

Alternative

New 

Temporary 

Road Miles

New 

NFS 

Road 

Miles 

Reconstruction 

NFS Road 

Miles 

Total 

Road 

Costs* 

1 0 0 0 $0 

2 3.9 7.3 2.9 $2,039,000 

3 6.1 25.1 9.1 $6,017,000 

4 2.2 0 2.6 $416,000 

Cumulative Effects 

The cumulative effects boundary includes the Kake Road System. The 

Catalog of Events for Kupreanof Island was referenced for this 

analysis. 

While the number of open miles and therefore access may temporarily 

increase for up to ten years after timber sale activities with any action 

alternative, the overall open road miles associated with this project 

access would decrease slightly in the long term. Up to approximately 

1.69 miles would be closed within the project (see Table 3-15). 

Closure of roads includes mainly side roads and no main access routes 

are proposed for closure. 

The Petersburg Ranger District is presently working on the Access and 

Travel Management Plan and analysis for the District that will affect 

access on the Kake Road System by potentially closing some roads, 

restricting class of vehicle use, or decommissioning roads. However, 

the RAP for this project only proposes an additional closure of about 

seven miles (mostly side roads and roads with resource issues) and 

decommissioning of another about 2.8 miles (which lead into an 

OGR). Road management objectives and use designations for the 

entire Kake Road System roads that are not associated with proposed 

timber harvest activities will be analyzed and decisions made in the 

PRD ATM EA. Decisions from the Central Kupreanof project will be 

incorporated by the PRD ATM EA and analyzed cumulatively. The 

District’s ATM EA was published in July of 2009. The Motorized 

Vehicle Use Map will be updated yearly. Maps will be available at the 

Petersburg Ranger District. 

Other potential activities could affect access and open road miles on 

the Kake Road System. Potential activities could include Forest 
3 Environment and Effects 

56  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Service activities that implement the Forest Plan as well as State or 

Federal Highway projects and the Kake-Petersburg Intertie. 

Such projects, in addition to the proposed activities with the Central 

Kupreanof project, could increase access either for the short-term or 

long-term, as well as decrease long-term access overall on the Kake 

Road System. 

Irreversible and Irretrievable Commitments 

of Resources 

Borrow pits and quarries would be needed for road construction and 

reconstruction under all action alternatives. The amounts of shot rock 

and crushed rock would vary with each alternative and miles of 

proposed construction and reconstruction. Location and sites can be 

designed, as well as timing used, to minimize the impacts upon other 

resource values and existing facilities. The extraction of shot rock or 

gravel would be apparent and excavation sites would be evident, 

altering the landscape, even with screening. These resources are not 

replaceable therefore these actions would be irreversible. See Figure 

B-1 for location of existing rock sources proposed to reuse and 

expand. 

Rock quarries are usually developed on a hillside by removing any 

trees and overburden from above the bedrock, which is usually within 

five feet of the surface. The bedrock is then drilled and blasted to 

produce rock in one foot diameter and less size. This rock is then used 

as an overlay to produce the road surface which supports the vehicles. 

Compliance with the Forest Plan and 

Other Regulatory Direction 

All alternatives comply with Forest Plan standards and guidelines. 

The standards and guidelines relevant to transportation can be found in 

the Tongass Forest Plan beginning on page 4-80. All roads are 

constructed to American Association of State Highway Transportation 

Officials (AASHTO) and Occupational Safety and Health 

Administration (OSHA) standards. Roads are constructed to meet 

Standard Specifications for Construction of Roads and Bridges on 

Federal Highway Projects, FP-03. 

A discharge of dredge or fill material for normal silvicultural activities 

such as harvesting for the production of forest products is exempt from 

Section 404 permitting requirements in waters of the United States, 

including wetlands (404(f)(1)(A). Forest roads qualify for this 

exemption only if they are constructed and maintained in accordance 

with best management practices (BMPs) to assure that flow and 

Clean Water Act 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 57 

circulation patterns and chemical and biological characteristics of the 

waters are not impaired (404)(f)(1)(E). The BMPs that must be 

followed are specified in 33 CFR 323.4(a). All road construction 

would follow the applicable BMPs. 

There are no mining claims in the project area that the road system 

accesses or runs across. 

Contracts, permits, road maintenance plans and project design 

documents would contain appropriate provisions concerning the 

prevention and/or spread of invasive species along the road system. 

Best Management Practices (BMPs) are used to assure soil and water 

resources are considered in transportation planning activities. Specific 

BMPs are listed by resource on the road cards. 

In general, resource concerns and mitigation measures identified in the 

road cards consist of the following. 

 Cutslope erosion would be mitigated by timely erosion control. 

 Side slopes of greater than 67% would be mitigated by full 

bench construction and slope stabilization, if necessary. 

 Road construction across muskegs would be mitigated by using 

wetland protection measures. 

 Open road density, road induced sedimentation, road 

maintenance requirements would all be mitigated through 

timely road storage after harvest activities are complete. 

Additional details of specific road construction concerns and 

mitigation measures are shown on the road cards. Site-specific 

mitigation measures are listed on the road cards by resource. 

Minerals and 

Geology 

Resource 

Invasive Species 

Prevention 

Mitigation and 

Monitoring 
3 Environment and Effects 

58  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Other Resources 

Considered 

Botany 

This section provides a summary of the botanical work done to 

analyze the potential effects of this project on sensitive, rare, and 

invasive plant species. Detailed information on the survey methods 

and effects analysis for sensitive, rare and invasive plants are found in 

the Botany resource report, Biological Evaluation for Plants and Risk 

Assessment for Invasive Plants (Clemens 2008). 

Individual analysis was completed for each plant category (sensitive, 

rare, and invasive). The ‘Effects Common to All Action alternatives’ 

apply to, and have been considered in, all three following plant 

analyses. 

Effects Common to All Action Alternatives 

Trail Maintenance and Cabin Maintenance 

There would be no effects to threatened, endangered, sensitive, or rare 

plants from the proposed stewardship project of maintaining the four 

area trails and Big John Bay cabin. 

The risk of spreading invasives plants with these activities is low since 

there would be no new ground disturbance and most of the invasives 

found on the trails were limited to the roadside trailheads. No high 

priority species were found near the trailheads or cabin. Gravel sources 

will be checked before using on the trails to insure no high priority 

invasive weed species were present at the site. 

Invasive Plant Control 

There would be no effects to threatened, endangered, sensitive or rare 

plants from the proposed invasive plant control stewardship project. 

This project would help control and limit the spread of invasive plants 

present in the project area, particularly the spotted knapweed. 

Fisheries/Hydrology 

There would be no effects to threatened or endangered plants from the 

proposed fisheries/hydrology stewardship project of pulling culverts 

on fish streams on closed roads. While no known populations of 

sensitive or rare plants would be affected, correcting or pulling 

Projects Common 

to All Action 

Alternatives 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 59 

culverts has the potential to affect unknown populations and habitat at 

stream crossings. 

There is moderate risk of spreading invasive plants into uninfected 

areas if the equipment used to pull the culverts goes from a weeded 

area to a weed-free area. 

Silviculture/Wildlife 

There would be no effects to threatened, endangered, sensitive or rare 

plants from the proposed silviculture stewardship project of precommercial thinning second-growth stands. 

There would be no effects to invasive plants with this project. Secondgrowth stands are not likely habitat for invasive plants due to the thick 

tree growth. While the pre-commercial thinning would allow more 

light into the stands, the ground would not be disturbed. Leaving the 

cut trees on the ground would further inhibit invasive weed growth. 

Transportation 

The proposed transportation stewardship project of maintaining the 

Kake area roads would not adversely affect any known threatened, 

endangered, sensitive or rare plants in the project area. One sensitive 

plant species, Davy mannagrass (Glyceria leptostachya), is sometimes 

found in roadside ditches and could be affected by ditch maintenance. 

However, this species thrives in disturbed areas, so increased 

disturbance could actually enhance its habitat and populations. Also, 

this species is more abundant on the Tongass than once thought, and 

has been removed from the 2009 Alaska Region Sensitive Plant List. 

There is moderate risk of spreading invasive plants into uninfected 

areas with road maintenance if the equipment used goes from a 

weeded area to a weed-free area. 

Microsales 

The proposed Microsale areas along NFS roads open for long term 

management 6030, 6040 and 6314, 6314S, 6326, 6328, 6334, 6336, 

6339 and 6367 may impact unknown individual rare or sensitive plants 

but would not likely lead to federal listing for any species. 

The proposed Microsale areas would have no significant effects to 

invasive plants. 

Threatened and Endangered Plants 

No threatened or endangered plants are known or suspected to occur in 

Southeast Alaska; therefore federally listed plants were not evaluated. 
3 Environment and Effects 

60  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Affected Environment for Sensitive Plants 

The analysis area considered for direct and indirect effects, for 

sensitive and rare plants, is the Central Kupreanof project area. For 

cumulative effects, the area considered is the Tongass National Forest. 

Botanical surveys were conducted in the major plant communities 

present in the project area. One hundred fifty-five vascular plant 

species were identified from these surveys. Detailed information about 

common forest and wetland types in the project area can be found in 

the Silviculture-Vegetation resource report and the Soils-Wetlands 

resource report. 

Botanical surveys were concentrated in proposed harvest units, where 

populations could be directly affected. Only limited surveys were 

completed in non-harvest areas. Therefore, it is possible sensitive plant 

populations occur in areas of proposed road construction as well as 

within the project area where no harvest or road building activities are 

proposed. 

Units of measure 

 Number of known plant populations affected by proposed 

activities 

 Qualitative discussion of potential effects to unknown 

populations and habitat 

 Determinations from the Biological Evaluation (Clemens, 

2008a) risk assessment 

The Regional Forester’s sensitive species list was undergoing revision 

during the analysis for the Central Kupreanof project. The Regional 

Forester signed the revised list on February 2, 2009. The revised list 

does not include several plants analyzed in the Biological Evaluation 

for this project. The following plants were analyzed but are no longer 

designated as sensitive: Glyceria leptostachya, Hymenophyllum 

wrightii, and Poa laxiflora. The two sensitive species found in the 

Central Kupreanof project area, Wright filmy fern (Hymenophyllum 

wrightii), and Davy mannagrass (Glyceria leptostachya), have been 

removed from the 2009 Alaska Region Sensitive Species List. 

Furthermore, 11 rare plants are newly designated as sensitive in the 

2009 list revision. None of the newly added species were found in the 

Project Area. Only one species on the revised list has been 

documented on the Petersburg Ranger District. The lichen Lobaria 

amplissima has been found on trees on windswept, exposed beaches 

on south Mitkof Island and Tebenkof Bay on Kuiu Island. 

Sensitive Plants 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 61 

Due to the project’s advanced stage when the 2009 list was approved 

and signed, the Central Kupreanof project surveys and following 

analysis were based on the 2002 list. The difference would be fewer 

effects to sensitive species in the area with the revision since none of 

the new species were found in the project area. The 2009 list and the 

analysis of the rare and sensitive plants found within the Central 

Kupreanof project area can be found in the Botany resource report and 

Biological Evaluation located in the planning record. 

Four sensitive species from the 2002 Alaska Region Sensitive Plant 

List are suspected or known to occur in the project area since the area 

contains appropriate habitat and is within the known or suspected 

range of the plants. Three of the four species were removed from the 

sensitive plant list because they are more widespread than previously 

thought. Though these species are not all on the 2009 Sensitive List, 

they were analyzed in the Biological Evaluation for Sensitive Plants 

(See Appendix E of this document) due to their status as sensitive 

during this project analysis. Two of those species are known to occur 

on Kupreanof Island and two are suspected to occur there. 

Glyceria leptostachya – This species is found in wet habitats often 

where there is natural or human-caused disturbance, including along 

streams, ponds, lake margins and roadside ditches. Roots are often 

submerged. 

Hymenophyllum wrightii –This species is found at the base of trees, on 

downed logs, and rock outcrops in damp, humid woods. The 

gametophyte form of this species has been found to be fairly common 

in low elevation coastal areas in the southern and central Tongass. 

Poa laxiflora- This species has been found throughout the Tongass, 

typically on upper beach meadows, estuaries, and streamsides. 

Romanzoffia unalaschcensis- This species is known from a few 

widespread areas in Southeast Alaska. It is often associated with 

streamside/riverbank habitats and rock outcrops, often near the ocean. 

Environmental Consequences 

Two sensitive plant species from the 2002 list were found in the 

Central Kupreanof project area: Wright filmy fern (Hymenophyllum 

wrightii) and Davy mannagrass (Glyceria leptostachya). Seventeen 

populations of Hymenophyllum wrightii were found during surveys in 

the area with fourteen populations found in nine proposed units, and 

three in locations outside proposed units. 

One population of Davy mannagrass (Glyceria leptostachya) was 

found on the north shore of Kluane Lake east of Unit 254. The 

population would not be directly, or indirectly, affected by timber 

Sensitive Plants 

Known or 

Suspected in the 

Project Area 

Direct and Indirect 

Effects 
3 Environment and Effects 

62  Chapter 3 Central Kupreanof Timber Harvest FEIS 

harvest activities since it is outside any proposed units. Disturbance to 

its habitat could have beneficial effects to populations. 

There would be no direct or indirect effects to sensitive plants with 

implementation of Alternative 1. 

In Alternatives 2 and 3, fourteen known populations of Wright filmy 

fern (Hymenophyllum wrightii) would be affected by proposed timber 

harvest activities. Thirteen known populations would be affected in 

Alternative 4. Unknown populations may also be affected. Plants may 

be destroyed and habitat lost in road corridors due to trampling by 

workers, machinery, and deposition of road materials. Plants may be 

destroyed in timber harvest units due to trampling by workers, trees 

falling on the plants, trees dragged over the plants during removal or 

slash deposited on the plants. Plants may also be destroyed from 

operation of shovel yarding equipment and habitat alteration from soil 

compaction. 

Indirect effects on these species in other locations as a result of timber 

harvest and road construction are essentially undocumented at this 

time. However, changes in the habitat condition may have some 

indirect effects such as soils moisture changes, light regime changes 

and increased susceptibility to disturbances (human and natural). 

Some of the possible changes include increased groundwater 

hydrology due to decreased levels of evapotranspiration after harvest; 

alterations due to possible sedimentation caused by landslides or 

windthrow as a result of timber harvest or roading activities; increased 

competition from native or non-native species that may establish as a 

result of road building activities and other disturbance; impacts caused 

by changes in the light regime as a result of canopy removal; and 

increased disturbance caused by humans who may access these areas 

for recreation or subsistence use. 

In Alternatives 2 and 3, three populations located within riparian 

buffers or dropped units would remain unaffected. In Alternative 4, 

one additional population would be protected by the changed shape of 

Unit 310. 

Since there would be no direct or indirect effects in Alternative 1, 

there would be no cumulative effects in associated with this project in 

Alternative 1. For Alternatives 2, 3, and 4, the Catalog of Events was 

referenced. The following activities may add to the cumulative effects 

to sensitive species or their habitat within the project area; road and 

trail construction, road storage or decommissioning, gravel extraction, 

timber harvest, subsistence use and recreation. While individual 

populations and areas of potential habitat may be impacted by the 

proposed activities within the project area and across the Forest, 

cumulatively, the effects are not likely to lead to federal listing of any 

species. 

Alternative 1 

Alternatives 2, 3 

and 4 

Cumulative 

Effects 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 63 

As more sensitive plant surveys are conducted and more potential 

habitats surveyed, specialists are learning better methods on how to 

look for these plants. With this increasing knowledge, more plants are 

being found. Across the Tongass National Forest, from just the 

surveys concentrated in areas of proposed activities, approximately 86 

populations of Hymenophyllum wrightii have been found, seventeen 

populations in the Central Kupreanof project area alone. The 2009 

Regional sensitive plant species list did not include this species reflect 

due to the recent findings of abundant populations across the Forest. 

Table 3-17. Determinations for Sensitive Plant Species by 

Alternative. 

Species 

Known or 

Suspected in 

Project Area 

Alternative 1 Alternatives 

2-4 

Hymenophyllum 

wrightii Known No Impacts *May impact 

Individuals 

Glyceria 

leptostachya Known No Impacts *May impact 

Individuals 

Poa laxiflora Suspected No Impacts *May impact 

individuals 

Romanzoffia 

unalaschensis Suspected No Impacts No impacts 

*May adversely impact individuals, but not likely to result in a loss of viability in the 

Project Area, nor cause a trend toward Federal listing. 

Affected Environment for Rare Plants 

Two rare plant species were found in the project area and analyzed in 

the Botany Resource Report for the Central Kupreanof Timber Harvest 

EIS (Clemens 2008). Rare plant species considered for this project 

include any plant listed on the Alaska Natural Heritage Program 

(AKNHP) Vascular Plant Tracking List that was found during 

botanical surveys in the project area. One population of Galium 

kamtschaticum and eight populations of Listera convallarioides were 

found in the project area. 

Botanical surveys were concentrated in proposed harvest units, where 

populations could be directly affected. Only limited surveys were 

completed in non-harvest areas and proposed road corridors. 

Therefore, it is possible that rare plant populations occur in areas of 

proposed road construction as well as in areas where no harvest or 

road building activities are proposed. 
3 Environment and Effects 

64  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 Number of known plant populations affected by proposed 

activities 

 Qualitative discussion of potential effects to unknown 

populations and habitat 

 Determinations from the risk assessment completed for the 

Botany Resource report (Clemens, 2008c) 

Galium kamtschaticum and Listera convallarioides are often found in 

the same habitats: wet lady fern/skunk cabbage/forb communities. 

This community type is common from low to subalpine elevations in 

the Central Kupreanof project area and much of the Tongass National 

Forest. Galium kamtschaticum is also found in better-drained settings, 

such as avalanche slopes, brush fields or broken mountain slopes near 

the subalpine zone. Listera convallarioides is a perennial orchid 

typically found in wetter sites, including forested edges, openings with 

lady fern and skunk cabbage, lady fern and forb communities, and 

fens. 

The assessment of risks to populations of rare plants takes into account 

size, density, vigor, habitat requirements, location of the population, 

and consequence of adverse effect on the species as a whole within its 

range and within the Tongass National Forest. 

Direct and Indirect Effects 

Alternative 1 is the “no action” alternative and would have no direct or 

indirect impact on rare plant populations or their habitat. 

The direct effects to rare plants are the same in all the action 

alternatives (Alternatives 2, 3, and 4) since they occur in or near units 

that are proposed for identical actions in the three alternatives. Also, 

where rare plants were found in or near deferred units or roads, those 

activities were deferred in all three alternatives. The direct and 

indirect effects described under “Sensitive Plants” are the same for 

rare plants and their habitat. 

The known population of Galium Kamtschaticum in Unit 229 would 

be impacted by harvest activities. The consequences of adverse 

impacts to this rare plant due to project activities are moderate. The 

likelihood of adverse effects is high since it is in a unit proposed for 

harvest in all action alternatives. The overall risk to this species is low 

because it commonly occurs in open-forested and non-forested niches, 

often where management activities are not likely to occur. 

Units of measure 

Rare Plant Habitat 

Environmental 

Consequences for 

Rare Plants 

Alternative 1 (No 

Action) 

Alternatives 2, 3, 

and 4 

 Galium 

kamtschaticum 

(Boreal 

bedstraw): 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 65 

The consequences of adverse impacts to this rare plant due to project 

activities are low to moderate as two of the eight populations identified 

in the Central Kupreanof project area would be directly impacted by 

harvest. Habitat would also be impacted. The likelihood of adverse 

effects is moderate as harvest may change the hydrology and 

microclimate needed by this plant. The overall risk to this plant in the 

Central Kupreanof project area is low because it is commonly found in 

habitats that will be avoided by harvest activities and foreseeable 

future activities. 

The timber harvest activities could also affect some undetected rare 

plants. More Listera convallarioides and Galium kamtschaticum

populations could possibly occur in areas where no harvest or road 

construction is proposed since most surveys were concentrated in 

proposed units and only limited surveys were done in non-harvest 

areas. 

Since there would be no direct or indirect effects in Alternative 1, 

there would be no cumulative effects associated with this project in 

Alternative 1. For Alternatives 2, 3, and 4, the Catalog of Events was 

referenced. The following activities may add to the cumulative effects 

to sensitive species or their habitat within the project area; road and 

trail construction, road storage or decommissioning, gravel extraction, 

timber harvest, subsistence uses, and recreation. Individual 

populations and areas of potential habitat may be impacted by various 

proposed activities (such as, but not limited to, those listed above) 

across the Forest. 

As more rare plant surveys are conducted and more potential habitats 

surveyed, specialists are learning better methods on how to look for 

these plants. With this increasing knowledge, more plants are being 

found. Recent findings across the Tongass National Forest of Listera 

convallarioides and Galium kamtschaticum populations indicate 

population trends may be higher than anticipated and may affect 

overall State rankings in the future. To date, with inclusion of 

populations found in the Central Kupreanof project area, 40 

populations of Galium kamtschaticum and 68 populations of Listera 

convallarioides are known on the Tongass National Forest. These 

populations have been found from surveys specifically concentrated on 

proposed disturbance areas, such as in proposed timber harvest units or 

road prisms. While some of these populations and potential habitats 

may be affected by Forest projects, by the number of occurrences 

discovered and the similar habitats in non-development areas, it can be 

suggested that large unknown populations may occur outside proposed 

activity areas and remain unaffected. In fact, much of the primary 

habitat for the known or suspected rare plants is not in productive 

timber stands and is commonly found throughout the Tongass. 

Listera 

convallarioides 

(Broad-leaved 

twayblade): 

Cumulative 

Effects 
3 Environment and Effects 

66  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Invasive Plants 

The area of analysis for invasive plants includes the project area plus 

the roads outside the project area that connect to Kake. This is 

because roads are the main vector for spreading invasive plants. 

An “invasive plant species” is a plant, including its seeds, spores or 

other biological material that is not native to the ecosystem under 

consideration and whose introduction causes or is likely to cause 

economic or environmental arm or harm to human health (Executive 

Order 13112; USDA Forest Service 004a; USDA Forest Service 

2005). Invasive plant surveys were conducted in the project area in 

2006, primarily on the roads and rock quarries. 

An invasive plant risk assessment for the Central Kupreanof project 

was completed and included in the project record with the Botany 

resource report. This risk assessment clarifies the management 

concerns, objectives and mitigation measures proposed to address 

invasive species for the Central Kupreanof project. 

Units of Measure 

 Qualitative discussion of potential effects and risk of spread 

determinations from Invasive Plant Species Risk Assessment 

(Clemens, 2008b) 

Eight invasive plant species found on the Kake road system are ranked 

moderately to highly invasive, according to the Alaska Natural 

Heritage Invasive Plant Ranking System (2007, Alaska Natural 

Heritage Foundation Weed Ranking Project). 

Three of the high priority invasive species (FSM 2080 R10 TNF 

Supplement 2000-2007-1) on the Kake road system occur in the 

project area. The other five species occur on non-national forest lands 

within four miles of the City of Kake. Spotted knapweed, one of the 

three high priority species found within the project area, is 

recommended for control. It is a small isolated population found on 

Road 6337. The other two species in the project area, oxeye daisy and 

reed canarygrass, are not recommended for control because they are 

widespread along most roads in the area and successful control without 

the use of pesticides is not likely. Future control of these species may 

be evaluated in District-wide programmatic decisions. Table 3-18 lists 

the known invasive plant species along the Kake road system. 

Priority Invasive 

Plant Species 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 67 

Table 3-18. High priority Invasive Plants on the Kake Road 

System 

Species Common Name Status 

Actively controlling these plants where feasible on the Tongass 

Centaurea 

biebersteinii spotted knapweed Rd 6337, within 

project area. 

Senecio jacobaea. tansy ragwort 

On the beach next to 

the ferry terminal in 

Kake 

Sonchus arvensis. 

ssp. uliginosis perennial sowthistle In City of Kake, 

several locations 

Polygonum 

cuspidatum Sieb & 

Zucc. 

Japanese knotweed In City of Kake and 

one rockpit near town 

Actively controlling these plants only in certain locations on the 

Tongass

Leucanthemum 

vulgare 

oxeye daisy, white 

daisy 

Occurs commonly 

along Kake roads 

Melilotus alba 

Medikus white sweetclover In rockpit 7 miles 

from project 

Phalaris 

arundinacea reed canarygrass 

Occurs commonly 

along Kake roads 

including within the 

project area 

Brassica rapa field mustard In the City of Kake 

1 Plants in bold are located on National Forest lands. 

Direct and Indirect Effects 

Habitat vulnerability is a review of site specific factors that are present 

in the project area which would make the project area vulnerable or 

resistant to invasive plant infestation. For most invasive plants, two 

elements usually exist which promote their spread: open sunlight and 

exposed mineral soil (disturbance). Mineral soils are generally found 

along riparian areas, estuaries, and mountain and hill slopes of forested 

habitats. Therefore, the habitats with the highest vulnerability related 

to soil type is riparian areas, estuaries and other stream corridors 

directly adjacent to road corridors. 
3 Environment and Effects 

68  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The degree of soil disturbance within forested habitats as a result of 

timber harvest is related to the type of logging system used to remove 

the timber. For example, cable systems using suspension (partial or 

full) will create little or no soil disturbance; however, ground-based 

systems (high lead and shovel) have the potential to create more soil 

disturbance. 

The primary vectors responsible for invasive plant species spread 

within the project area are wind and water, although wildlife and the 

use of vehicles may also play a role to a lesser degree. 

Plants listed in Table 3-18 are considered a high risk to the project area 

either because they are highly invasive species already present in the 

project area or they are moderate to highly invasive species known on 

the Kake road system. While the project invasive plant species risk 

assessment analyzes overall risk of spread, the likelihood of some of 

the individually listed species to spread into the project area is quite 

low. For example, the Japanese knotweed generally spreads through 

movement of contaminated soil. Because the population is outside of 

the Project Area and will not be disturbed by project activities, there is 

very little risk this invasive will spread to the Project Area. Also, the 

white sweetclover population is isolated in a rockpit seven miles from 

the project area. Because this rock source will not be used for 

proposed activities, the risk of spread is very low. Due to the distance 

from the Project Area and haul route, there is a moderately low to low 

risk of spread for both the perennial sowthistle and field mustard 

populations. 

The tansy ragwort is also located outside the project area. It is located 

on the beach next to the ferry terminal in Kake. The primary vectors 

spreading the tansy ragwort are wind and vehicles. Because it is 

unlikely that vehicles will come in contact with the plants the risk of 

spreading due to vehicle traffic is low. 

The small isolated population of spotted knapweed was found along 

Road 6337. This road, while in the project area, would not be used in 

any proposed alternative. Therefore, because the population is not 

located along the haul route or in an area proposed for harvest, and is 

recommended for control through the Projects Common to all Action 

Alternatives, the risk of spread is low. 

While the project area is not an area where the oxeye daisy and reed 

canarygrass are being actively controlled, the risk of spread of these 

invasive plants along the road corridor is moderate. However, with 

implementation of soil erosion best management practices (BMPs) the 

primary habitat vulnerability elements can be limited and the risk 

lessened. For example, immediately reseeding disturbed areas in new 

road construction and reconstruction corridors with standard seed mix 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 69 

can lessen the time mineral soils are exposed and open to sunlight, 

encouraging the establishment of native species. 

There is no increased risk of spreading invasive plants into the project 

area with this alternative. 

Overall this alternative has a low to moderate risk of increasing the 

spread of invasive plants in the project area because there would be 

some ground disturbance with the 11.2 (NFS and temporary) miles of 

new road construction proposed and 2.9 miles of reconstruction. 

Of all action alternatives, Alternative 3 has the highest risk of 

increasing the spread of invasive plants in the project area because it 

proposes the most new road construction (NFS and temporary) of 31.2 

miles and 9.1 miles of reconstruction. 

With the exception of the no action alternative, this alternative has the 

lowest risk of increasing the spread of invasive plants in the project 

area because it only proposes 2.2 miles of temporary road construction 

and 2.6 miles of reconstruction. 

The activities occurring in Alternatives 2, 3, and 4 have an overall 

assessment of moderate to low risk for increasing the spread of 

existing invasive plants (Invasive Plant Risk Assessment, Clemens, 

2008) as well as increasing new introductions of other invasive plants 

due to ground disturbance as a result of new and reconstructed road 

development. 

Cumulative Effects 

The Catalog of Events was referenced in identifying cumulative 

effects for along the Kake Road System. Programmatic hand or 

mechanical treatment of weeds and cooperative work with the City of 

Kake, would help to limit the spread of invasive weeds related to past, 

ongoing, and future projects. Road maintenance would continue along 

the road system and depending on measures taken, may continue to 

pose a moderate risk of invasive species spread along the road 

corridor, specifically of the oxeye daisy and reed canarygrass. The 

District Access Travel Management NEPA document will decide 

whether roads remain open (and type of vehicle use), be placed into 

storage, or be decommissioned. The effects of these decisions and risk 

to spread of invasive species will be analyzed in that document; 

however, whenever there are ground-disturbing activities, particularly 

within the road corridor, and the presence of invasive plant species, 

there will be some foreseeable risk of spread. 

Alternative 1 

(No Action) 

Alternative 2 

Alternative 3 

Alternative 4 

Alternatives 2, 3, 

and 4 
3 Environment and Effects 

70  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Alternative 1 would have no cumulative effect on weed species as it 

would not cause any new disturbance or additional road construction 

in the project area for weed species to occupy or spread. 

Disturbances caused by road building and timber harvest favor the 

spread of invasive plants. It is likely that some invasive plants would 

be spread or spread naturally into newly disturbed areas. Currently 

most weed species are limited to the road corridor and rock quarries. 

The spotted knapweed population on Road 6337 is recommended for 

control with Projects Common to all Action Alternatives. 

Management Considerations/Mitigation 

and Monitoring 

The invasive plant management goals and strategies for this project 

will follow the guidance contained in the new Forest Service Manual 

supplement (FSM 2080 R10 TNF Supplement 2000-2007-1) and the 

Region 10 and Tongass Invasive Plant Management Plans. The 

primary goal for this project is prevention and minimization of 

spreading certain invasive plants further into the project area. It will 

focus on limiting the introduction and spread of existing high priority 

invasive plants into new areas, especially in the process of road 

construction. 

Several factors for management are considered: 

1. Focus efforts on high priority invasive plants that the Tongass N.F. 

has committed to actively control where feasible. In the Central 

Kupreanof area, this means efforts will focus on controlling the 

spotted knapweed population found on Road 6337. This could be 

accomplished by including the work in a stewardship contract or by 

using Forest Service personnel to hand pull the plants annually. 

2. Management considerations for this project will not include those 

high priority invasive plants known in the project area which the 

Tongass N.F. has committed to actively control only in certain 

locations. These include the following species: 

Leucanthemum vulgare – oxeye daisy 

Phalaris arundinacea – reed canarygrass 

The logic for not treating these species at this time is due to their 

widespread distribution along the Kake road system and the low 

likelihood of success in their ultimate control. However, the 

application of soil erosion BMPs will assist in reducing the risk of 

continued spread. Management efforts across the Forest will focus on 

avoiding the introduction of these species into pristine habitats and 

Land Use Designations that are managed for natural and near natural 

Alternative 1 

Alternatives 2, 3, 

and 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 71 

conditions. These do not include the Timber LUD, of which this 

project area is located. 

With the above stated management considerations, the following 

mitigation measures are recommended for management to consider in 

lowering the risk of spread of invasives: 

 Require contractors to use approved rock sources, which have 

been identified by the Forest Service. 

 This will require an invasive species specialist to inventory all 

rock sources prior to use and certify in writing that it is 

acceptable. The existing rock quarries in the project area were 

surveyed in 2006 and no high priority species were found. 

 If any rock sources become contaminated with high priority 

species and certification can not be attained without treatment 

methods, consider the use of contaminated rock for reconstructing existing roads only. 

 Rock material free from high priority species will be required 

of all new road constructions and new landings. 

 Monitor the newly constructed roads, the active quarries, and 

the project area for at least 3 years after the project for new 

non-native plant introductions. 

 Eradicate or control any newly introduced high priority 

invasive plant species/populations not currently in the project 

area after project completion as part of the District 5-year 

program of work for invasive species management. Prioritize 

controlling any new populations relative to other populations of 

high priority species needing treatment on the District. 
3 Environment and Effects 

72  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Wildlife 

Resource Analysis Area 

The Central Kupreanof project area is located on the Petersburg 

Ranger District on the Tongass National Forest. The project area is 

located on Kupreanof Island and is along the Kake road system. The 

project area is approximately 152,517 acres. It follows the boundary 

lines of Value Comparison Units (VCUs) 429, 438, 426, 436, 427.1 

(Figure 1-1) which account for most of the interior portion of 

Kupreanof Island. 

Within the project area wildlife habitat can be assessed based on 

different types of geographical areas. Biogeographic Provinces (BP) or 

Game Management Units (GMU) are geographical areas defined by 

the Alaska Department of Fish and Game (ADFG) to manage wildlife 

populations. Wildlife Management Areas (WAAs) are subdivisions of 

GMUs and are used by ADFG for data collection purposes. VCUs are 

National Forest System land divisions that approximate watersheds. 

See Figure 1-1 for delineations of WAAs and Biogeographic 

Provinces. 

Wildlife habitat, for this project, will be analyzed at the Biogeographic 

Province level. This is consistent with the analysis of POG used in the 

Forest Plan. The Biogeographic Province was used in the Forest Plan 

to describe the amount of Productive Old-Growth forest (POG) 

remaining on the Tongass and is summarized for the 

Kupreanof/Mitkof Biogeographic Province. Wildlife habitat is also 

analyzed at the project level, disclosing localized effects, and also 

using multiple WAAs. Because it is possible for animals to move 

between Kuiu Island and Kupreanof Island, seven WAAs representing 

hunting/trapping use areas, were used to show effects on wildlife 

habitat. 

The amount of productive old-growth (POG) forest (a percentage of 

what was existing prior to large-scale and human-caused habitat 

change) on the Tongass is a good indicator of habitat loss, as well as 

how fragmented habitat is likely to become.

Species Screen 

The National Environmental Policy Act (NEPA) directs the Forest 

Service to conduct a full and fair discussion of significant issues, and 

to identify and eliminate issues that are not significant. Some elements 

of wildlife habitat require a detailed analysis and discussion to 

determine potential effects. Other elements may not be affected, or 

may be affected at a level that does not influence use, occurrence, or 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 73 

the decision to be made. Others can be adequately addressed through 

design of the project. These elements will not necessarily require 

further analysis. 

The species screened for relevancy include threatened, endangered, 

sensitive, Management Indicator Species (MIS), and any others 

identified through the scoping process. The appropriate method and 

level of analysis needed to determine potential effects are influenced 

by a number of variables including; presence of species or habitat, the 

scope and nature of the activities associated with the alternatives, and 

the risks that are known or expected to occur within the project area. 

Species that may be potentially affected by the proposed actions will 

receive a detailed analysis. However further analysis was determined 

to be unnecessary for those species considered absent from the project 

area, where impacts could be avoided or where impacts would be 

inconsequential given the type or magnitude of the action (see Table 3-

19). 

Table 3-19. Species Screen Analysis 

Species Probability of 

Occurrence 

Potential for 

Measurable 

Effects to 

Habitat in 

Analysis Area 

Need for Further 

Analysis 

Threatened and Endangered Species 

Humpback 

Whale 

(Megaptera 

novaengliae)

Mod No No 

Stellar Sea Lion 

(Eumetopias 

jubatus) 

Mod No No 

Federal Candidate Species 

Kittlitz’s 

Murrelet 

(Brachyramphus 

marmoratus)

Low No No 

Yellow-billed 

Loon (Gavia 

adamsii) 

Low No No 
3 Environment and Effects 

74  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Sensitive 

Aleutian Tern 

(Sterna aleutica) Low No No 

Black 

oystercatcher 

(Haematopus 

bachmani)

Mod No No 

Trumpeter Swan 

(Cygnus 

buccinator)

Mod Yes No 

American 

Osprey 

(Pandion 

haliaetus 

carolinensis) 

Mod Yes No 

Queen Charlotte 

Goshawk 

(Accipiter gentilis 

laigni) 

High Yes No 

Peale’s Peregrine 

Falcon 

(Falco peregrinus 

pealei) 

Low No No 

MIS 

Red Squirrel 

(Tamiasciurus 

hudsonicus) 

High No No 

Black Bear 

(Ursus 

americanus) 

High Yes Yes 

Brown Bear 

(Ursus arctos) Low No No 

Marten 

(Martes 

americana) 

High Yes Yes 

River otter 

(Lutra 

canadensis) 

High No No 

Sitka Blacktailed Deer 

(Odocoilus 

hemionus 

sitkensis) 

High Yes Yes 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 75 

Mountain Goat 

(Oreamnus 

americana) 

Low No No 

Gray Wolf 

(Canis lupus 

ligoni) 

High Yes Yes 

Vancouver 

Canada Goose 

(Cygnus 

buccinator) 

Mod No No 

Bald Eagle 

(Haliaeetus 

leucocephalus) 

High No No 

Red-breasted 

Sapsucker 

(Brachyramphus 

brevirostris) 

High No No 

Hairy 

Woodpecker 

(Piodoies 

villosus) 

High No No 

Brown Creeper 

(Certhia 

americana) 

High No No 

Others 

Forest Land 

Birds High Yes No 

Moose 

(Alces alces) High Yes Yes 

Table 3-19 explains how this analysis dealt with the species list. The 

humpback whale, Stellar sea lion, Kittlitz’s murrelet, yellow-billed 

loon, Aleutian Tern, Black Oystercatcher and Peale’s peregrine falcon 

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

to the habitat in the analysis area is very low. The trumpeter swan, 

American osprey, and Queen Charlotte goshawks have a moderate to 

high probability of occurring in the project area and have a potential 

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

information about these species refer to the Biological Evaluation in 

Appendix E. 

This section discusses the affected environment of species known or 

suspected to occur in the project area that may be affected by project 

activities. Rationale for excluding other species from further 
3 Environment and Effects 

76  Chapter 3 Central Kupreanof Timber Harvest FEIS 

discussion in the FEIS is included in Table 3-21. The red squirrel, 

river otter, brown bear, mountain goat, Vancouver Canada goose, bald 

eagle, red-breasted sapsucker, hairy woodpecker, and brown creeper 

will not be analyzed further in this document as they do not have the 

potential for measurable effects and habitat is provided for by the 

Forest Plan. Other Forest land birds will not be addressed as these 

birds are discussed in the report Neo-tropical birds of concern on the 

Tongass National Forest (Brainard 2008). Harvest activities may have 

direct or indirect effects on these species. The maintenance of oldgrowth reserves, old-growth habitat in other non-development LUDs, 

beach, estuary and riparian buffers, the cavity nester standards and 

guidelines (USDA 2008), as well as structure left in the stands due to 

partial harvests will aid in minimizing the cumulative effects to these 

species. The MIS species that have a high probability of occurrence 

and may have a high probability for measurable effects to the habitat 

in the analysis area will be discussed further in this report. These 

species’ habitats are provided for by the Forest Plan in the Standards 

and Guidelines, the Conservation Strategy, Old-Growth Reserves, 

estuary buffers, riparian buffers, and beach fringe buffers (which 

provides for the viability of the species; FSM 2080 R10 TNF 

Supplement 2000-2007-1). 

Methods 

The wildlife analysis for this project does not use the deer or marten 

models. Instead the analysis uses a quantitative approach which looks 

at the reduction of productive old-growth (POG). POG is defined in 

the Forest Plan and in the glossary in this document. Looking at the 

reduction of POG provides a way to measure effects to wildlife and 

display the amount of habitat that is no longer available to a suite of 

wildlife species. This approach provides a clear comparison of 

alternatives. 

According to preliminary research conducted by Hanley and Friberg 

(pers. Comm. Hanley 2009), all Stand Density Model (SDM) 

categories are not equal (See “Stand Density Model” discussion under 

Environmental Consequences). They found that grouping the seven 

Stand Density (SD) classes into three supra-classes made sense 

statistically for the winter seasons. They placed SD4H in the small 

tree category because it produces the highest amount of deer forage 

during winter months (if it is available). The second category they 

called medium tree, which is composed of SD4S, SD4N, SD5H, SD5S 

and SD5N. Finally the large tree group, which comprised SD67, 

produced the lowest amount of winter forage for deer. These three 

supra-classes make up POG. Hanley’s analysis shows that the best 

winter habitat is comprised of small and medium tree categories and 

therefore lumping all POG into suitable habitat is consistent with the 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 77 

best science available to predict alternative effects on deer winter 

habitat. While looking at the currently available studies on deer in 

Southeast Alaska, one thing becomes evident; the categories that make 

the up medium tree class provides good deer winter habitat and 

grouping the POG together creates a conservative approach to deer 

habitat during the winter (Schoen and Kirchhoff 1990, Doerr et al. 

2005, Farmer et al. 2006 and Schoen and Kirchhoff 2007 found in the 

Nature Conservancy Publication 2007). The majority of POG habitat 

in the Central Kupreanof project area is considered winter habitat for 

deer because of its low elevation. 

Field surveys were completed by the Integrated Resource Inventory 

(IRI) crews during the 2006 and 2007 field seasons. When raptor 

nests were found, they were buffered according to Forest Plan 

Standards and Guidelines. 

Deer quick cruise plots were recorded in the majority of the unit pool 

which scores habitat from 0 to 100. Results were analyzed and the 

habitat with the highest total scores was evaluated to make sure 

connectivity exists. Connectivity was evaluated in the project area 

using POG and connectivity will be maintained. See IRI crew survey 

results in project record. 

Looking at the reduction of POG provides a way to measure effects to 

wildlife as well as to display the amount of habitat that is no longer 

available to a suite of wildlife species. This approach provides a clear 

comparison of alternatives. A brief discussion of the relevant species’ 

habitat preferences and requirements is also included. 

A road density analysis was also completed. Total road densities for 

this analysis include open and closed NFS roads as well as any private 

or State roads within the appropriate boundaries. Road layers of 

private and State roads may not be complete (for instance mapped 

Kake Tribal roads may be incomplete) and actually densities may be 

higher. Municipal roads, for Petersburg and the city of Kake were not 

included in the calculations. 

Affected Environment 

The Central Kupreanof project area is located on the interior portion of 

western Kupreanof Island on the Kake road system. Kupreanof is the 

sixth largest island in Southeast Alaska and is located near the 

geographic center of the Alexander Archipelago, a group of 

mountainous islands lying west of the mainland. The island is 

approximately 1,089 square miles in size, with 313 miles of shoreline. 

The community of Kake on the northwestern shore and Kupreanof on 

the eastern shore are the only two municipalities on the island. The 

Characterization 

of Wildlife 

Habitats 
3 Environment and Effects 

78  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Central Kupreanof project area is characterized by mostly old-growth 

temperate forest and wetland plants. Most of the old-growth forest is 

classified as non-productive forest (Figure 3-2). Young growth forest 

resulting from timber harvest occurs along the road system and 

shorelines. Small areas of natural second-growth forest have 

developed after blow-down has occurred (Figure 3-2). 

The forest consists of about 80 percent Western hemlock with lesser 

amounts of Sitka spruce, mountain hemlock, Alaska yellow-cedar and 

Western red cedar. Alder grows on exposed and disturbed soil sites 

such as old roads. Dense understory plants grow where enough 

sunlight can penetrate the forest canopy. Understory plants include 

devil’s club, rusty menziesia, skunk cabbage, salmonberry, bunch 

berry and several species of blueberries. The most productive forests 

develop on well drained sites such as along the mountain slopes of 

Missionary Range in the northeast, in the Petersburg-Duncan Salt 

Chuck Wilderness, in the Keku Creek and Big John drainages and in 

the headwaters of the Castle River drainage. 

Kupreanof Island has several large areas of muskeg. The southeast 

corner of the island and the north central area near the Bohemia Range 

are mostly muskeg savannas. Muskeg vegetation is a mixture of 

sedges, deer cabbage, sphagnum mosses, and low growing shrubs such 

as Labrador tea and bog laurel. Stunted, slow-growing shore pines 

grow on less saturated muskeg areas. Very small ponds dapple most 

muskegs. 

Due to the low elevations on Kupreanof Island, few areas of subalpine 

or alpine vegetation exist. The few mountaintops where this habitat is 

present are the Missionary Range, the Bohemia Range, Portage 

Mountain and several ridges higher than 1,500 feet in the middle of the 

island. Plants that grow in subalpine and alpine areas are copperbush 

sedges, cottongrass, mountain hemlock and several species of 

blueberries (USDA 2000). 

For this analysis, the reference condition is the historic or original 

condition and is defined as the habitat condition present before timber 

cutting began. 

Existing Condition 

Kupreanof Island contains muskeg habitat as well as POG. Within the 

project area there is approximately 57,628 acres of POG. Within the 

WAAs (5012, 5013, 5018, 5130, 5131, 5131, and 5132) there are 

approximately 268,611 acres of POG and within the Biogeographic 

Province there is approximately 307,710 acres of POG. 

Black bear range through all major habitat types found in the project 

area and require large expanses of habitat. Movements and 

Reference 

Condition 

Productive OldGrowth (POG) 

Black Bear 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 79 

distribution of black bear are primarily influenced by food and cover. 

Black bear are opportunistic omnivores that feed on new shoots, 

leaves, berries and spawning salmon (late summer and fall). Estuarine, 

riparian and forested coastal habitats receive the highest use by black 

bear and have the highest habitat values. Within forested areas, both 

early and late (old-growth) successional stages provide the best forage 

and/or cover for black bear. Although many of their preferred foods 

grow best in openings, bears prefer not to move very far from cover 

when they are foraging; therefore large openings without cover are 

thought not to be utilized. From 1998 through 2007 the average 

harvest in WAAs 5130, 6131, and 5133 has been 28 black bears 

annually, with the highest harvest of 45 and the lowest harvest of 15 

(Meucci 2008). Approximately 79 percent of the annual harvest 

occurs from nonresidents (Lowell 2005). 

Moose prefer shrubs, timber line plateaus, areas along (glacial 

riverwash shrub stands) major rivers and post-glacial early 

successional vegetation types. Moose also prefer shallow ponds where 

lush vegetation is available. From 1998 through 2007 the average 

harvest in WAAs 5130, 6131, and 5133 has been 6 moose annually, 

with the highest harvest of 9 and the lowest harvest of 2 (Meucci 

2008). 

Marten are naturally occurring on Mitkof, Kupreanof and Kuiu 

islands. The subspecies of Martes caurina is not known to occur in 

the project area. This member of the weasel family depends on 

mature forests with snags and downed logs for denning and prey 

habitat. The quantity of quality winter habitat is considered the most 

limiting factor for marten in Southeast Alaska. Due to lower snow 

accumulations, habitats at lower elevation have higher value for 

wintering marten. 

High volume old-growth coastal habitats (beach fringe) and riparian 

areas have the highest value, followed by upland habitats between 800 

and 1,500 feet in elevation. These stands provide marten with 

important habitat components, including overstory canopy, snags, 

fallen logs, trees with large exposed root systems and a lush 

understory. The fallen logs, decadent trees and large snags in oldgrowth forests provide marten with important resting microsites. 

Because marten store little fat, these microsites are important in 

minimizing thermal loss. Large old trees, standing snags and large 

diameter logs provide important sites for marten (Suring 1992). 

Optimum use of habitat occurs when patches of preferred habitat are 

greater than 180 acres. From 1998 through 2007 the average harvest 

in WAAs 5130, 6131, and 5133 has been 3 marten annually, with the 

highest harvest of 9 and the lowest harvest of 0 (Meucci 2008). 

Moose 

Marten 
3 Environment and Effects 

80  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The Alexander Archipelago wolf ranges through all habitat types 

found within the project area. A wide-ranging, opportunistic predator, 

the wolf does not exhibit a preference for specific habitats or habitat 

characteristics. Wolf presence is more indicative of the availability of 

habitat for its primary prey species, Sitka black-tailed deer, rather than 

land form, climate or vegetation (Suring et al 1993 and Person et al. 

1996). Person et al. (1997) recommends maintaining sufficient 

habitat to support at least 18 deer per square mile in areas where deer 

are the primary prey species. The wolf secondarily preys upon beaver, 

moose and where available, spawning salmon and waterfowl (Person 

et al. 1996). Availability of suitable denning habitat is of secondary 

importance to wolves. Dens are generally located in sites with good 

drainage and within 10 meters of fresh water (Person et al. 1996). 

Wolves tend to have home ranges that cross several wildlife analysis 

areas. The Forest Plan estimates on average 17 deer per square mile 

(in the Biogeographic Province) were available in 2008 in the analysis 

area. Additionally, the Forest Plan predicts approximately 15 deer per 

square mile (in the Biogeographic Province) will be available in 2095 

with the full implementation of the Forest Plan selected alternative 

(USDA 2008). From 1998 through 2007 the average harvest in WAAs 

5130, 6131, and 5133 has been 3 wolves annually, with the highest 

harvest of 13 and the lowest harvest of 0 (Meucci 2008). 

Sitka black-tailed deer are considered a generalist species that ranges 

throughout all major habitats of Southeast Alaska. Deer utilize all 

successional stages at all elevations, including alpine, meadows, and 

subalpine forests, for most of the year. In the winter, deer prefer low 

elevation, high volume old-growth forests. The availability of high 

quality winter range is the most limiting habitat factor to deer. 

The capability of winter habitat to support Sitka black-tailed deer is a 

function of forage abundance and quality (Hanley et al. 1989), snow 

interception qualities of the overstory and climate as influenced by 

aspect, elevation and maritime conditions (Suring et al. 1992b). 

Winter snow conditions affect deer greatly through decreased forage 

availability and increased energetic costs. Stands with closed canopies 

minimize the amount of snow accumulation, promoting forage 

availability and movement of deer. The habitat in the project area is 

not capable of supporting large numbers of deer because this area on 

Kupreanof Island lacks large contiguous stands on higher volume 

timber with high quality browse that deer rely on to provide cover and 

forage. From 1998 through 2003 the average harvest has been 58 deer 

annually, with the highest harvest of 110 and the lowest harvest of 18 

(Meucci 2008). 

Wolf 

Deer 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 81 

Central Kupreanof is made up of areas of POG and non-forested 

muskeg. Historic timber sale harvest has occurred in most of the 

project area. Connectivity is provided by the Conservation Strategy 

which includes areas of non-development LUDs, beach buffers and 

Old-Growth Reserve (OGR) system. 

Kupreanof Island is a large island compromising of approximately 

664,796 acres. The 2008 Forest Plan increased the quality and 

quantity of the Old-Growth Reserve (OGR) system providing 

landscape connectivity between non-developmental LUDs and larger 

old-growth reserves for both animals that use a variety of habitats and 

endemic mammals. Approximately 102,341 acres on Kupreanof 

Island are protected in large, medium and small OGRs and a total of 

249,798 acres (38%) in non-development LUDs. The Central 

Kupreanof project area covers approximately 152,517 acres. Up to 

3,647 acres (2.4% of the project area) are proposed for harvest with 

proposed units spread out along the roaded base and logical road 

extensions. Small OGRs on Kupreanof and specifically within the 

project area were adjusted during the Forest Plan amendment to 

provide connectivity across the middle of the island. 

The Federal Endangered Species Act (ESA) defines endemic as “a 

species native and confined to a certain region; having comparatively 

restricted distribution.” Forest Plan Standards and Guidelines for 

endemic mammals direct the Forest to “maintain habitat to support 

viable populations ands improve knowledge of habitat relationships of 

rare or endemic terrestrial mammals that may represent unique 

populations with restricted ranges.” 

Due to its historic isolation, ecological complexity and narrow 

distribution between the Pacific Ocean and coastal mountain ranges 

the North Pacific Coast is considered a “hot spot” of endemism (Cook 

and MacDonald 2001, Cook et.al. 2006). Southeast Alaska has been 

found to be a region with an especially high degree of endemism in its 

small mammal fauna, principally because of the combination of its 

archipelago geography and its highly dynamic glacial history 

(Demboski et. al 1998, USDA 2008). In “Conservation of Highly 

Fragmented Systems: The North Temperate Alexander Archipelago” 

(Cook et. al. 2006), Kupreanof Island rated relatively low and was not 

considered a “hot spot” in comparison to other southeast islands. 

The following species are known to occur in the project area. common 

shrew, dusky shrew, red squirrel, beaver, Keen’s mouse, long-tailed 

vole, porcupine, muskrat, wolf, black bear, marten, ermine, mink, 

wolverine, river otter, mountain lion, Sitka black-tailed deer, moose 

(MacDonald and Cook 2000). 

Landscape 

Connectivity 

Endemics 
3 Environment and Effects 

82  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 
901

314

5 1 207

252

7

206

276

250

205

905

270

903

502

217

265

234

284

258

6

261

282

219

318

204

263

277

248

501

203

275

310

209

215

241

900

235

280

272

221

285

208

243

224

2

286

279

260

313

305

202

304

253

257

320

273

3

229

309

266 264

231

271

307

274 281

246

315

216

201

268

218

232

233

236

312

316

222

306

904

267

254

249

317

262

230

223

239

214

255

269

c:/workspace/ckupre/plots/deis/fig3_2_vegetation.mxd 09-20-08 EP

Legend

Old-growth Reserve

1000ft Shore Buffer

Non-development LUD

Wilderness

Unit Pool

Productive Old-growth

Forested Non-productive

Managed Stands

Project Area Boundary

D u n c a n

C a n a l

R

o

c

k

y

P

a s s

Central Kupreanof Timber Harvest

Vegetation

Figure 3-2

 ̄
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 85 

Environmental Consequences 

Wildlife use an assortment of habitats including POG and non-forest 

structures. Because the proposed activities primarily alter POG, the 

effects of timber harvest on wildlife habitat will be analyzed by 

comparing changes in POG using the Size Density Model (SDM). The 

analysis includes comparisons of changes between past, present and 

foreseeable future habitat capability by alternative. 

Wildlife was analyzed at three different landscape scales: project area, 

WAAs, and biogoegraphic province (Kupreanof/Mitkof). The project 

area analysis provides the localized and direct/indirect effects of 

timber harvest on POG. Cumulative effects impacts were analyzed at 

both multiple WAA and the Biogeographic Province scales. Multiple 

WAAs (5012, 5013, 5018, 5132, 5131, 5133 and 5130) were analyzed 

for cumulative effects to provide a reference of the impacts at a 

smaller scale than the Biogeographic Province but larger than the 

project scale. The northern part of Kuiu Island (WAAs 5012, 5013 

and 5018) was included in the Central Kupreanof Analysis because it 

is possible for animals to move to this area if individuals are displaced 

from the project area. 

Kuiu is also considered part of the customary and traditional use area 

for the people of Kake and activities in these seven WAAs may 

interact together to affect subsistence resource uses. Finally, home 

ranges may include areas as large as the Biogeographic Province. The 

2008 Tongass Land and Resource Management Plan displays the 

distribution of existing POG acres by Stand Density Model (SDM) 

category for the Kupreanof/Mitkof Biogeographic Province. This 

analysis tiers to the Forest Plan and displays the reduction of POG 

acres by SDM (and as a percent reduction) for each alternative. 

The following excerpts are from the 2008 Forest Plan and describe the 

Size Density Model. 

For the 1997 Forest Plan, the Tongass classified POG on the basis of 

three volume strata (low, medium and high). These were refined 

based on using the existing TIMTYP inventory, soils and slopes. 

Since the issuance of the 1997 Forest Plan, several landscape and 

timber sale analyses have effectively used the three broad timber-type 

categories delineating non-forest, unproductive old-growth forest, and 

POG forest lands, which were divided further into high, medium, and 

low volume strata forest stands (USDA 2008). 

While the three volume strata approach for POG is useful for 

estimating timber volume for forest planning purposes, it is not as 

useful for describing other important forest elements, including forest 

Units of Measure 

and Areas of 

Analysis 

Size Density 

Model 
3 Environment and Effects 

86  Chapter 3 Central Kupreanof Timber Harvest FEIS 

structure, ecosystem diversity and wildlife habitat. Forest structure is 

defined as the spatial arrangement of the components of vegetation and 

is a function of tree size and height, vertical stratification into layers, 

and horizontal spacing of trees. It is important because it reflects the 

complex spatial and temporal interaction between plant growth (e.g., 

dispersal and competition), physiographic factors (e.g., geology, soils, 

slope, aspect, and elevation), climate, and disturbance, (e.g., wind, 

landslides, and human activities). Areas of high-structure habitat are 

typically located in areas of well-drained soils on unconsolidated 

sediments associated with alluvial fans, floodplains, or toe slopes. 

Differences in forest structure are more useful because timber volume 

may be misleading when describing wildlife habitat or other attributes 

of the stand. For example, two stands may have the same volume but 

one may be a dense stand of medium-sized trees with a single canopy 

layer while the other stand may be a combination of widely-spaced 

large over story trees and two or three lower canopy layers containing 

small and medium sized trees (Caouette et. al. 2000, Caouette and 

DeGayner 2001). 

To move beyond the limitations of timber volume, Forest Service 

managers and planners have begun to revise and refine forest mapping 

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

POG forests. Such information is more applicable for assessing 

conservation of biodiversity, estimating timber values and developing 

wildlife habitat models. 

One alternative to using volume estimates is using a combination of 

two common forest measurements: tree sizes and tree densities 

(Caouette et. al. 2000). These two measures provide a more 

comprehensive forest measuring system than timber volume (Spies 

and Franklin 1991, Franklin 1995). The Forest Service recently 

published National Guidance on vegetation classification and mapping 

that specifically requires tree sizes (expressed as quadratic mean 

diameter of all live dominant/co-dominant trees) and tree densities 

(expressed as canopy closure) for the mapping of forest structure 

(USDA Forest Service 2004d). The Tongass National Forest has 

developed an approach that uses these two measurements to model 

structural diversity in order to better define and describe forest 

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

proven to be the best tool for representing these other forest elements 

(USDA 2008). 

Size-density model (SDM) uses timber volume class, hydric soil class 

and aspect to characterize forest structure. These attributes were 

correlated with the stand density index and mean quadratic mean to 

derive the various SDM categories (USDA 2008). 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 87 

As the SDM is used, it is expected the limitations will become evident. 

Much of the SDM is based in theory and the results have not been 

verified for all areas. As more information is gathered, improvements 

may be made. This analysis collapsed the SDM to the basic level of 

POG . 

Differences in Forest Plan Predictions of 

Available Deer Habitat and Project 

Planning 

The SDM layer that is used for this analysis displays different results 

than the SDM strata that were used in the 2008 Forest Plan. There 

appears to be between a 2 to 4 percent difference in the numbers 

generated. This difference appears to be due to the more precise 

information that is utilized at the project level compared to the broad 

scale information used at the Forest level. This difference is expected. 

Direct and Indirect Effects 

Removal of stream crossings and closures of roads may benefit 

wildlife by limiting road densities and motorized human access. 

Vegetation treatments (proposed thinning) should benefit wildlife as it 

helps to restore side lighting to the forest floor, increasing the 

production of forbes and shrubs as well as helping to promote taller 

and denser stands of trees that can provide shelter (snow interception). 

Projects involving recreation may not benefit wildlife as the projects 

may increase access (improving trails) or encourage people to gather 

(camp sites, shelters). These projects may not harm wildlife directly 

but may encourage people to be in the area who may indirectly take 

wildlife as part of their experience or opportunity. 

Microsales are planned to occur in the project area on Roads 6030, 

6040, 6314, 6314s, 6326, 328, 6334, 6336, 6339 and 6367. If a 

Microsale is requested a site specific survey will be conducted. These 

sales are not expected to adversely affect wildlife in the project area. 

Effects Common 

to all Action 

Alternatives 
3 Environment and Effects 

88  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-20. Reduction of Productive Old-Growth Habitat 

Alternatives 

1 2 3 4 

Acres of POG Habitat 

Harvested 

0 2,427 3,568 1,261 

Percent Change from 

Current Condition 

within Project Area 

(57,628 acres of POG) 

0% 4.2% 6.2% 2.2% 

Percent Change from 

Current Condition 

(2008) within WAAs 

(269,593 Acres of POG) 

0% 0.9% 1.3% 0.5% 

Percent Change From 

Current Condition 

(2008) within 

Biogeographic Province 

(307,710 acres of POG) 

0% 0.8% 1.2% 0.4% 

Project Area 

This alternative proposes no new activities in the Central Kupreanof 

project area. Currently there are approximately 57,628 acres of POG, 

within the project area. The area displayed in this project area analysis 

is different than the area displayed by other resources (timber 

economics, Silviculture) because this POG analysis used SDM and the 

other resources used volume strata. Volume strata define some areas as 

POG where SDM describes that same habitat as “non-forested.” As a 

result, acres of POG are slightly different. 

Wildlife habitat may decline as current second-growth stands 

regenerate and the under story forage is shaded. There will be no 

change in the current road network by these actions; however, 

maintenance activities would continue. This alternative will have no 

affect on wildlife habitat. 

This alternative would directly affect approximately 2,427 acres of 

POG. This would be about 4.2 percent of the project area POG and 

0.8 percent of the available POG in the Biogeographic Province. This 

reduction may have an effect on individuals but will not affect wildlife 

populations. The reduction of habitat capability is considered to be 

minor because of the remaining POG habitat. The remaining 95.8 

percent of the project area POG would remain unaffected by proposed 

activities. Part of this remaining habitat is made up of nondevelopmental LUDS including riparian corridors and beach fringe. 

Also, areas of partial harvest can be used by wildlife as habitat. 

Alternative 1 

Alternative 2 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 89 

This alternative proposes to harvest 3,568 acres of POG in the Central 

Kupreanof Project Area. This would be a reduction of approximately 

6.2 percent of POG within the project area and 1.2 percent of POG 

within the Biogeographic Province. This reduction may have an effect 

on individuals but will not affect wildlife populations. The reduction 

of habitat capability is considered to be minor because of the 

remaining POG habitat. The remaining 93.8 percent of the project 

area POG would remain unaffected by proposed activities. Part of this 

remaining habitat is made up of non-developmental LUDS including 

riparian corridors and beach fringe. Also, areas of partial harvest can 

be used by wildlife as habitat. 

This alternative proposes to harvest 1,261 acres of POG in the Central 

Kupreanof Project Area. This would be a reduction of approximately 

2.2 percent of POG within the project area and 0.4 percent of POG 

within the Biogeographic Province. This reduction may have an effect 

on individuals but will not affect wildlife populations. The reduction 

of habitat capability is considered to be minor because of the 

remaining POG habitat. The remaining 97.8 percent of the project 

area POG would remain unaffected by proposed activities. Part of this 

remaining habitat is made up of non-developmental LUDS including 

riparian corridors and beach fringe. 

Black Bear habitat is provided for by Forest Wide Standards and 

Guidelines, Conservation Strategy, Old-growth reserves and beach 

buffers. This project may impact part of their habitat due to road 

building and associated timber harvest activities. The impacts will be 

inconsequential as bear are generalists (an organism or species with a 

very broad ecological niche, which can tolerate a wide range of 

environmental conditions and eat a variety of foods) as a result they 

are capable of using a variety of habitats and are not exclusively 

dependent on productive old-growth (POG). Therefore, the reduction 

of POG habitat to all action alternatives will not have effect to black 

bear populations. Depending upon which alternative is selected at 

least 93.8 percent of POG habitat will remain within the project area. 

Moose habitat is provided for by Forest Wide Standards and 

Guidelines, Conservation Strategy, Old-Growth Reserves and beach 

buffers. This project may impact part of their habitat but the impacts 

will be inconsequential as moose are generalists and do not rely on 

POG exclusively. Therefore, the reduction of POG habitat to all 

action alternatives will not have an effect on moose populations. 

Depending upon which alternative is selected at least 93.8 percent of 

POG habitat will remain within the project area. 

While there may be localized effects from road building and timber 

harvest, and some individual marten may be displaced, there is not an 

anticipated effect to the marten population. Marten populations are 

Alternative 3 

Alternative 4 

Black Bear 

Moose 

Marten 
3 Environment and Effects 

90  Chapter 3 Central Kupreanof Timber Harvest FEIS 

sensitive to overexploitation for trapping. Currently the open road 

density in the project area is 0.27 miles/miles2 and the total road 

density is 0.33 miles/miles2. Table 3-21 displays road densities for the 

project area and Kupreanof Island. Road building will increase 

motorized vehicle access during the timber sale and for an additional 

five to ten years after the sale. Marten and their highest value habitat 

are provided for by Forest-wide standards and guidelines, conservation 

strategy, old-growth reserves and beach buffers. Marten may be 

affected at a level that does not influence their habitat. Because of the 

conservation strategy marten are well above the status of maintaining 

viability in the population. Therefore, the reduction of POG habitat to 

all action alternatives will not have an effect to marten populations. 

Depending upon which alternative is selected at least 93.8 percent of 

POG habitat will remain within the project area. 

Wolves are protected by Forest-wide standards and guidelines, 

conservation strategy, old-growth reserves, and beach buffers. Wolves 

tend to have home ranges that cross several wildlife analysis areas. 

The 2008 Forest Plan estimates an average of 17 deer per square mile 

(in the Biogeographic Province) are currently available. 

The Forest Plan states, on page 3-283: “The Wolf guideline is intended 

to apply to Biogeographic Provinces where deer are the primary prey 

of wolves. Thus, the number of WAAs that appear to fall below 18 

deer per square mile in terms of habitat capability is inflated because 

many either do not naturally contain much suitable deer habitat (sic 

Kupreanof Island), or are areas where wolves also prey heavily on 

species other than deer such as moose, beaver or mountain goats.” 

The Forest Plan goes further and states that there is a “high likelihood 

of sustaining persistent core wolf populations and reducing risks to 

long-term viability in the two principal areas of concern in Southeast 

Alaska (GMU 2 and 3) as well as the remainder of the historic wolf 

range on the Tongass”. 

The Forest Plan predicts 15 deer per square mile (in the Biogeographic 

Province) will be available in 2095 with the full implementation of the 

Forest Plan selected alternative (USDA 2008). The habitat within the 

Central Kupreanof Timber Harvest project area is not capable of 

supporting large numbers of deer. With implementation of any action 

alternative, deer would still average between 17 and 15 deer per square 

mile. 

Currently the open road density in the project area is 0.27 miles/miles2 

and the total road density is 0.33 miles/miles2. Table 3-21 displays 

road densities for the project area and Kupreanof Island. Increased 

road building may provide additional access for hunters/trappers. This 

project may impact part of their habitat but the impacts will be 

inconsequential as wolves are generalists and do not utilize POG 

 Wolf 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 91 

exclusively. Therefore, the reduction of POG habitat to all action 

alternatives will not have an effect to wolf populations. Depending 

upon which alternative is selected at least 93.8 percent of POG habitat 

will remain within the project area. 

Table 3-21. Road Densities 

Road densities 

(mi/mi2) 

Alt 1 Alt 2 Alt 3 Alt 4 

Project Area 

Open Road 

0.27 0.31 0.41 0.28 

Project Area 

Total Road 

0.33 0.36 0.44 0.33 

Kupreanof Island 

Total Road1

0.22 0.23 0.25 0.22 

1 Displays cumulative road densities (including foreseeable future activities). Calculations 

include both open and closed NFS roads as well as State and available mapped private roads. 

According to Hanley and Friberg (personal communication 2009), all 

SDM categories are not equal. They found that grouping the seven SD 

classes into three supra-classes made sense statistically for the winter 

seasons. They placed SD4H in the small tree category because it 

produces the highest amount of deer forage during winter months (if it 

is available). The second category they called medium tree, which is 

composed of SD4S, SD4N, SD5H, SD5S and SD5N. Finally the large 

tree group, which comprised SD67, produced the lowest amount of 

winter forage for deer. These three supra-classes make up POG. 

Hanley’s analysis shows that the best winter habitat is comprised of 

small and medium tree categories and therefore lumping all POG into 

suitable habitat is consistent with the best science available to predict 

alternative effects on deer winter habitat. While looking at the 

currently available studies on deer in Southeast Alaska, one thing 

becomes evident; the categories that make the up medium tree class 

provides good deer winter habitat and grouping the POG together 

creates a conservative approach to deer habitat during the winter 

(Schoen and Kirchhoff 1990, Doerr et al. 2005, Farmer et al. 2006 and 

Schoen and Kirchhoff 2007 found in the Nature Conservancy 

Publication 2007). This analysis tiers to the Forest Plan Standards and 

Guidelines that require the consideration of Sitka black-tailed deer 

habitat needs as part of project analysis. As such, the reduction of 

POG habitat was used to analyze effects of all action alternatives. 

The effects of proposed activities on POG are analyzed. Deer habitat is 

provided for by Forest-wide Standards and Guidelines, Conservation 

Strategy, Old-growth reserves and beach buffers. This project may 

Sitka Black-tail 

Deer 
3 Environment and Effects 

92  Chapter 3 Central Kupreanof Timber Harvest FEIS 

impact deer habitat and individual deer will be affected but the 

viability of the deer population is not in question. At most 6.2 percent 

of the POG may be removed which will leave 93.8 percent of POG 

habitat remaining for the deer to utilize within the project area. 

Landscape connectivity is maintained by non-development LUDs, 

OGRs and beach fringe areas. During the Forest Plan amendment, 

small OGRs were reevaluated and the OGRs within the project area 

adjusted to better maintain connectivity across the island. According to 

the conservation strategy, these adjustments provide for landscape 

connectivity (FP FEIS, Appendix D). Additionally, connectivity was 

addressed within the project area by looking at the results of the deer 

quick cruise plots. Additional consideration for connectivity was part 

of the proposed action’s design. The areas with the higher total group 

of quick cruise plot scores were buffered by either a no cut buffer or 

silvicultural prescription to make sure there was additional 

connectivity across the planning area. Forest Plan Standards and 

Guidelines are met with this analysis. 

Direct effects on landscape connectivity would be greatest with 

implementation of Alternative 3 because harvest of proposed Unit 315 

could have impacts on deer movement through the corridor across 

Kupreanof Island. Alternative 2 provides 50 percent retention in Unit 

315 and Alternative 4 does not harvest this unit. All action alternatives 

maintain connectivity in the project area. 

Species that are associated with old-growth would be affected by the 

harvest old-growth. Species associated with primarily non-POG 

habitat would not be affected with the exception of non-forested 

habitat associated with roads and turnouts. Old-growth habitat is 

being removed causing a change at the stand level. This change will 

remove cover and possible habitat for small mammals they may be 

exposed to a greater degree to predation. The increased side light may 

provide an increase in vegetation that may benefit small mammals. 

However, landscape connectivity is maintained and, depending upon 

which alternative is selected, at least 93.8 percent of POG habitat will 

remain within the Project Area. 

Cumulative Effects 

The cumulative effects analysis area for POG habitat is the 

Biogeographic Province. The province was selected as the analysis 

landscape scale since it is the scale used by animals with large home 

ranges and is the same scale used for analysis of POG in the Forest 

Plan. Approximately 51 percent of the province was originally POG 

forest. Historic harvest has reduced POG by 28 percent in the 

Biogeographic Province since the reference condition. The 

Kupreanof/Mitkof Biogeographic Province includes Native 

Landscape 

Connectivity 

Endemics 

Biogeographic 

Province 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 93 

Corporation lands near Kake as well as other private lands. Due to 

lack of information about these Corporation lands, it is assumed all 

lands available were clearcut harvested. It was also assumed all lands 

were POG prior to harvest. Due to these assumptions, the amount of 

habitat converted to young growth will be overestimated as will the 

impacts to wildlife habitat where harvest has occurred. However, this 

will allow a reasonable estimate of the reduction of POG in the 

absence of data. 

In addition to the reduction in habitat on private lands, the analysis 

also includes those lands that are or will be harvested in other timber 

sales; including Bocephus, Scott Peak, Lindenberg, Finger Point, 

Overlook, and Woodpecker timber sales, and Kake small sales. 

Assuming these sales harvest the volume available, there would be 

another approximately 1 percent reduction in POG habitat for a total 

decrease of approximately 29 percent in the Biogeographic Province. 

Timber sales are planned for the Tonka area in the near future. A 

detailed analysis of these effects will take place in the planning 

process before any action occurs. Projects Common to all Action 

Alternatives would not contribute to overall cumulative effects to POG 

habitat. The catalogs of events for Kupreanof and Mitkof islands were 

reviewed. 

The conclusions in this analysis are consistent with the 2008 Forest 

Plan. The Forest Plan estimates that in 100 years (2105) with 

implementation of Alternative 6, the Kupreanof/Mitkof Biogeographic 

Province 10 will retain 61 percent of the original POG acres on all 

land ownerships. The Forest Plan estimates that 39 percent of the 

POG in the province will be harvested (USDA 2008). 

This alternative proposes no new activities in the Central Kupreanof 

Project Area. No harvest or road building would occur within the 

project. Wildlife habitat may decline as current second-growth stands 

regenerate and the understory forage is shaded. There will be no 

change in the current road network by this action; however, the 

District-wide Access Travel Management (ATM) Environmental 

Assessment (EA) will analyze road management objectives for the 

Biogeographic Province. The ATM EA is expected to change access 

and open road densities. Current road maintenance will continue. Oldgrowth stands with POG would continue to support wildlife at their 

current capability at least until the next planning cycle. 

Historic/original harvest has reduced POG by approximately 28 

percent in the Biogeographic Province. Cumulatively, including the 

reasonable foreseeable reduction of POG on Forest Service and nonForest Service lands, there would be approximately a total of 29 

percent reduction of POG from the historic/original condition within 

the Biogeographic Province. 

Alternative 1 
3 Environment and Effects 

94  Chapter 3 Central Kupreanof Timber Harvest FEIS 

There would be a cumulative reduction of 29.8 percent of the POG 

within the Biogeographic Province with implementation of this 

alternative. This reduction in habitat due to the action alternative is not 

expected to affect wildlife populations. 

There would be a cumulative reduction of approximately 30.2 percent 

of the POG within the Biogeographic Province with implementation of 

this alternative. This reduction in habitat is not expected to affect 

wildlife populations. 

There would be a cumulative reduction of approximately 29.4 percent 

of the POG within the Biogeographic Province with implementation of 

this alternative. This reduction in habitat due to the action alternative is 

not expected to affect wildlife populations. 

Cumulative effects were also analyzed at multiple WAAs as this level 

is more appropriate to analyze the effect of subsistence use. Seven 

WAAs were analyzed as an area. Three WAAs are on Kuiu (5012, 

5013, and 5018) and four WAAs include the project area and adjacent 

lands on Kupreanof Island (5030, 5031, 5032, and 5033). Historic 

harvest has reduced POG by approximately 25 percent in these WAAs 

from original condition. This analysis includes Native Corporation 

lands near Kake as well as other private lands. Due to lack of 

information about these Corporation lands, it is assumed all lands 

available were clearcut harvested. It was also assumed all lands were 

POG prior to harvest. Due to these assumptions, the amount of habitat 

converted to young growth will be overestimated as will the impacts to 

wildlife habitat where harvest has occurred. However, this will allow a 

reasonable estimate of the reduction of POG in the absence of data. 

In addition to the reduction in habitat on private lands, the analysis 

also includes those lands that may be harvested in other timber sales; 

including the sales at Kuiu and remaining Crane and Rowan Mountain 

units. Small timber sales are planned along road 6367 in the near 

future. Two units are proposed that would harvest up to 50,000 board 

feet. This removal of POG would not be measurable to the scale of 

this proposed action. Projects Common to All Action Alternatives 

would not contribute to overall cumulative effects to POG habitat. The 

catalogs of events for Kuiu and Kupreanof Islands were referenced in 

this analysis. 

This alternative proposes no new activities in the Central Kupreanof 

Project Area. No harvest or road building would occur within the 

project area. Wildlife habitat may decline as current second-growth 

stands regenerate and the understory forage is shaded. There will be 

no change in the current road network by this action; however, the 

PRD Access Travel Management (ATM) EA will analyze road 

management objectives for the Biogeographic Province. The ATM EA 

is expected to change access and open road densities. Current road 

Alternative 2 

Alternative 3 

Alternative 4 

Multiple WAAs 

Alternative 1 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 95 

maintenance will continue. Old-growth stands with POG would 

continue to support wildlife at their current capability at least until the 

next planning cycle. Historic/original harvest has reduced POG by 

approximately 25 percent in the WAAs. Cumulatively, including the 

reasonable foreseeable reduction of POG on Forest Service and nonForest Service lands, there would be approximately a 26 percent 

reduction of POG from the historical/original condition within the 

WAAs. 

There would be a cumulative reduction of 26.9 percent of POG within 

the WAAs with implementation of this alternative. This reduction in 

habitat due to the action alternative is not expected to affect wildlife 

populations. 

There would be a cumulative reduction of approximately 27.3 percent 

of POG within the WAAs with implementation of this alternative. This 

reduction in habitat due to the action alternative is not expected to 

affect wildlife populations. 

There would be a cumulative reduction of approximately 26.5 percent 

of POG within the WAAs with implementation of this alternative. This 

reduction in habitat due to the action alternative is not expected to 

affect wildlife populations. 

Table 3-22. Cumulative Reduction of POG within the 

Biogeographic Province and WAA 

Alternatives 

Current 

Condition

1 2 3 4 

Percent Cumulative 

Reduction From 

Historic/Original Condition 

Biogeographic Province 

(431,217 acres of POG) 

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

Percent Cumulative 

Reduction From 

Historic/Original Condition 

Multiple WAAs 

(359,445 acres of POG) 

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

When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

POG depending on alternative. Approximately 72.7 percent of the 

Alternative 2 

Alternative 3 

Alternative 4 

Black Bear 
3 Environment and Effects 

96  Chapter 3 Central Kupreanof Timber Harvest FEIS 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Plus, habitat areas 

are provided for by the conservation strategy (which includes OGRs, 

beach buffers, the matrix and other non-development LUDS that 

protects additional habitat). This project meets Forest Plan Standards 

and Guidelines. 

When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

POG depending on alternative. Approximately 72.7 percent of the 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Plus, habitat areas 

are provided for by the conservation strategy (which includes OGRs, 

beach buffers, the matrix and other non-development LUDS that 

protects additional habitat). This project meets Forest Plan Standards 

and Guidelines. 

While there may be localized effects from road building and timber 

harvest, and some individual marten may be displaced, there is not an 

anticipated effect to the marten population. Marten may be affected at 

a level that does not influence use of this habitat. Because of the 

conservation strategy viability of the population will be maintained. 

 When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

POG depending on alternative. Approximately 72.7 percent of the 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Plus, habitat areas 

are provided for by the conservation strategy (which includes OGRs, 

beach buffers, the matrix and other non-development LUDS that 

protects additional habitat). This project meets Forest Plan Standards 

and Guidelines. 

When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

POG depending on alternative. Approximately 72.7 percent of the 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Plus, habitat areas 

are provided for by the conservation strategy (which includes OGRs, 

beach buffers, the matrix and other non-development LUDS that 

protects additional habitat). This project meets Forest Plan Standards 

and Guidelines and remains within Forest Plan predictions. 

When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

Moose 

Marten 

Gray Wolf 

Sitka Black-tail 

Deer 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 97 

POG depending on alternative. Approximately 72.7 percent of the 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Plus, habitat areas 

are provided for by the conservation strategy (which includes OGRs, 

beach buffers, the matrix and other non-development LUDS that 

protects additional habitat). This project meets Forest Plan Standards 

and Guidelines. 

When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

POG depending on alternative. Approximately 72.7 percent of the 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Landscape 

connectivity is maintained by the existence of non-development 

LUDs, OGRs and beach fringe areas. During the Forest Plan 

amendment, small OGRs were re-evaluated and the OGRs within the 

project area adjusted to better maintain connectivity across the island. 

According to the conservation strategy, these adjustments provide for 

landscape connectivity (Forest Plan FEIS, Appendix D). When looked 

at the multiple WAA level, the cumulative reduction of POG habitat is 

lower than when POG is displayed at the project scale (this is due to 

the larger scale). This project meets Forest Plan Standards and 

Guidelines. Connectivity is maintained in the project area and across 

the landscape. 

When an analysis was conducted at the multiple WAA for cumulative 

effects the percent change ranged from 1 to 2.3 percent and 1 to 2.2 

percent respectively in the multiple WAAs, and in the reduction of 

POG depending on alternative. Approximately 72.7 percent of the 

multiple WAA POG and 69.2 percent of the POG in the 

Biogeographic Province would remain unaffected. Species that are 

associated with old-growth would be affected because of the harvest of 

old-growth (see POG analysis). Removing old-growth habitat causes a 

change at the stand level and would be lessened at the multiple WAA 

or Biogeographic Province level. This change would remove cover 

and possible habitat for small mammals and they may be exposed to a 

greater degree of predation. The increased side light may provide an 

increase in vegetation that may benefit small mammals. Connectivity 

was considered and is maintained within the project area and across 

the landscape. Forest Plan standard and guides are met with this 

analysis. 

Conclusion 

These actions would affect wildlife habitat differently depending on 

the amount and type of POG removed. Alternative 1 would not remove 

any POG and would have the least impact to wildlife habitat. 

Landscape 

Connectivity 

Endemics 
3 Environment and Effects 

98  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Alternative 4 would remove the second lowest amount of POG from 

the area. Alternatives 2 would remove the third lowest amount of POG 

from the area and Alternative 3 would remove the most POG from the 

project area having the greatest impact to wildlife habitat. The action 

alternatives would remove approximately 1.3 percent or less of the 

POG habitat in both the WAAs and the Biogeographic Province. This 

reduction is not expected to affect wildlife populations. 

Cumulative impacts would be slightly higher due to the amount of 

harvest on other Forest Service and non-Forest Service lands. The 

reduction of POG due to the action alternatives is still considered low 

and is not expected to impact wildlife habitat. 

All applicable Forest Plan Standards and Guidelines were met for this 

analysis. This analysis is in compliance with all direction, policies and 

regulations. Notice was given to appropriate federal and state agencies, 

local committees, recognized tribal governments. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 99 

Subsistence 

Communities Traditionally Using the 

Central Kupreanof Project Area 

The Forest Plan FEIS includes maps of “community use areas” for 

each of the 32 communities in Southeast Alaska. These maps indicate 

the approximate extent of the areas that are commonly used by many 

of the residents of each community in their day-to-day work, 

recreational, and subsistence activities. 

The Central Kupreanof project area is within part of Kake’s 

community use area (Forest Plan FEIS Part 2, page 3-585) and 

adjacent to Petersburg’s and Kupreanof’s community use areas (Forest 

Plan FEIS Part 2, page 3-623). 

Kake and Petersburg residents are known to use the project area more 

than residents of other communities in Southeast Alaska. This 

opportunity is due to easy access to Central Kupreanof provided by the 

existing road system. Some subsistence activities these residents 

engage in include fishing, deer, bear, moose and waterfowl hunting 

and gathering of shellfish and berries. Traditional Native subsistence 

use also includes gathering medicinal plants, seaweed, spruce roots 

and cedar bark. 

For a detailed discussion of the communities of Kake and Petersburg 

see the Timber Economics section in this chapter and “Community 

Profiles: Kake, Petersburg, Alaska and Environmental Justice” in the 

project record. 

Subsistence Use 

The 1988 Tongass Resource Use Cooperative Survey (TRUCS) study 

found that deer accounted for 24 percent of the total edible pounds of 

subsistence resources harvested by Kake households (Kruse and 

Frazier 1988). Deer accounted for 28 percent of per capita subsistence 

harvest by Kake residents in 1996 (ADF&G 2006). 

Kake residents harvest deer on Admiralty Island and Kupreanof Island, 

which are included in Game Management Unit (GMU) 4 and GMU 3 

respectively. Deer harvest in GMU 4 is considered very high relative 

to other areas of Southeast Alaska, which is indicative of relatively 

high deer populations. Over 1997-2004, there has been no significant 

trend in the number of deer harvested or in the number of hunters 

(ADF&G 2005). Deer harvest in GMU 3 declined from 1998-2002 

and increased between 2002 and 2004. The number of deer hunters 

Kake 
3 Environment and Effects 

100  Chapter 3 Central Kupreanof Timber Harvest FEIS 

declined from 2000-2002 and slightly between 2002 and 2004 

(ADF&G). This is consistent with Kake’s human population, which 

increased from 1970 to 1990, stayed relatively constant between 1990 

and 2000, and decreased from 2000 to 2005. In conversations with 

residents of Kake in 2009, Kake has an estimated population of 519. 

Five WAAs accounted for the majority (76 percent) of deer harvested 

by Kake residents. Three of the five WAAs of greatest importance to 

Kake hunters (WAAs 3939, 3940 and 4041) occur at the south end of 

Admiralty Island. They are currently unroaded and there are no plans 

for future road development in these areas. The other two WAAs of 

importance to Kake hunters (WAAs 5131 and 5132) are located 

surrounding or adjacent to the community on Kupreanof Island. The 

Kake portion ranges from about 19 percent (WAA 3939) to 91 percent 

(WAA 5131) of the total harvest and from 21 percent to 100 percent of 

the rural hunter harvest in the WAAs. About 7 percent of the 

combined harvest in these WAAs is by non-rural hunters, suggesting 

that there is a small harvest buffer that could be restricted, if necessary, 

before restrictions are placed on rural harvest. 

It is recognized that the while Admiralty Island and Kupreanof Island 

represent areas where the majority of deer are harvested, important 

traditional and customary use areas of the Organized Village of Kake 

also include Kuiu Island and the eastern shores of Baranof Island 

(Goldschmidt and Haas, 1998). Some subsistence uses continue to 

occur on Kuiu. It is also acknowledged that as deer populations have 

decreased on Kuiu and Kupreanof islands. Admiralty has become 

more important particularly for subsistence deer harvest. However, 

access to Admiralty during the winter hunting season is often difficult 

for residents of Kake. Kake residents have stated that Admiralty Island 

is not their preference for deer hunting and that if deer numbers 

increase on Kuiu and Kupreanof Islands, more of their hunting will 

shift back to these areas. 

Salmon, other finfish and invertebrate resources account for 52 percent 

of the total edible pounds of subsistence resources harvested by 

Petersburg households (Kruse and Frazier, 1988). Marine resources 

(fish and marine invertebrates) accounted for 65 percent of per capita 

subsistence harvest in Petersburg in 1987. 

The 1988 TRUCS study found that deer accounted for 21 percent of 

the total edible pounds of subsistence resources harvested by 

Petersburg households (Kruse and Frazier, 1988). Deer accounted for 

22 percent of per capita subsistence harvest by Petersburg residents in 

1987 (ADF&G 2006). 

Petersburg residents harvested on and around Mitkof and Kupreanof 

Islands, with the majority of harvest occurring with in GMUs 3 and 4. 

Deer harvest in GMU 3 declined from1998-2002 and increased in 

Petersburg 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 101 

2002-2004. The number of deer hunters declined from 1998-2002 and 

increased in 2002-2004 (ADF&G 20005). Deer harvest in GMU 4 is 

considered very high relative to other areas of Southeast Alaska, which 

is indicative of relatively high deer population (ADF&G 2005). Over 

1997-2004, there has been no significant trend in the number of deer 

harvested or in the number of hunters (ADF&G 2005). The human 

population of Petersburg declined approximately 2 percent between 

2000 and 2005. In 2005, Petersburg had an estimated human 

population of 3,155. 

Units of Measure and Areas of Analysis 

The Subsistence analysis looks at the effects to wildlife habitat 

(referencing the POG analysis completed in the Wildlife section in this 

chapter), the effects to fish habitat and marine environment 

(referencing the Fisheries and Watershed section in this Chapter), and 

the effects to food plants. Additional analysis for changes in access 

(miles of new NFS roads) to subsistence resources is included in this 

section. 

Direct, Indirect and Cumulative Effects to 

Resources 

The Wildlife section talks about wildlife species, such as black bear, 

wolf, deer and marten. The effects of timber harvest on wildlife habitat 

were analyzed by comparing changes in Productive Old-Growth 

(POG) using the Size Density Model (SDM). The analysis included 

comparisons of changes between past, present and foreseeable future 

habitat capability by alternative. This analysis is found in the Wildlife 

section of this chapter and in the Wildlife Resource Report located in 

the project record. 

Based on that analysis, there is not expected to be a significant affect 

or possibility of a significant restriction on black bear, wolf, moose, 

furbearers, or upland birds or waterfowl resources within the project 

area. Recently, the marten trapping season was closed on Kuiu Island 

and is currently being proposed for additional closure to the Federal 

Subsistence Board. This closure is based on recent low study results 

and concluded low marten populations. The reason for these suspected 

low population numbers has not been studied. 

Although there has been a recent closure of marten trapping on Kuiu 

Island, based on the POG analysis for marten in the Wildlife section of 

Chapter 3 there is no significant possibility of a significant restriction 

resulting from cumulative effects in the project area, or Biogeographic 

Province analysis areas due to federal activities. 

Wildlife Habitat 
3 Environment and Effects 

102  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Deer populations in Southeast Alaska live at the edge of the species 

range. The Sitka black-tailed deer is a smaller form of mule deer that 

live in the forests of Alexander Archipelago. Food is not a limiting 

factor in deer survival here but available food, especially during winter 

months, can be limited by snow depth. 

Southeast Alaska lies along the coastal mainland in this archipelago. 

Saltwater influence is readily apparent. Because of this, snow 

conditions differ from what one would expect in other mule deer 

habitats. Constant warming and cooling, caused by the relatively 

warm marine climate, allows the snowpack to create a hard crust that 

deer are able to walk on. While it covers the forbs (generally a snow 

depth of greater than 7 inches or 20 cm) it enables the deer to reach 

higher browse plants and arboreal lichens to augment their diets. 

Following a severe winter these new plant shoots are extremely 

important to deer, without them they will starve very rapidly. 

Conditions leading to this condition occur in Southeast Alaska about 

every 20 or so years. 

The last time there was a catastrophic winter event that killed large 

numbers of deer was during the winter of 1971-72. That year total 

snow accumulation was 221.6 inches at the Petersburg Airport. This 

large amount of snow caused problems for the deer but the real 

problem was the persistence of the snow. There was a snow depth 

greater than 7 inches for 156 consecutive days starting in November 

and carrying into May (Brainard 2008). This event caused many deer 

to die, the population numbers literally crashing. As a result, the 

hunting season on Kuiu and Kupreanof were closed from 1975 to 

1991. 

It is also important to understand that the wolf eradication programs 

(poison drops and unlimited hunting/trapping) came to an end in 1968 

just before the severe winter. Wolf populations grew and contributed 

to the slow recovery of the deer population from 1975 to 1991. Wolf 

predation continues to retard deer population recovery. However, it is 

believed that deer population numbers before the severe winters in the 

early 1970s were artificially high (because of such programs as wolf 

eradication) and exceeded habitat capability. It is concluded then that 

population numbers will never reach those levels regardless of federal 

activities (Brainard 1996). Kake residents have stated that as 

populations increase on both Kuiu and Kupreanof, more and more of 

their hunting will shift back to these areas. 

This severe winter event happened before large scale road building and 

timber harvest occurred in the project area. Deer mortality is often 

considered to be caused by timber harvest activity but in reality deer 

Deer 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 103 

die across the forest due to severe winter conditions. Deer live on the 

edge of their range in this cold and wet climate. Every couple of 

decades harsh winters cause deer to die due to the lack of forage 

covered by the deep snow. 

Based on the POG wildlife habitat analysis (Wildlife section in 

Chapter 3), and the reduction of up to 1.3 percent of POG in the 

multiple WAAs, subsistence use of deer by Kake and Petersburg 

residents is not anticipated to be significantly affected by any of the 

action alternatives. In terms of cumulative effects, this project is not 

expected to affect subsistence use of deer in the reasonable foreseeable 

future to the point that some restriction in hunting might be necessary. 

However, the Forest Plan does determine that with full implementation 

of the plan over the long term, a significant possibility of a significant 

restriction on the subsistence use of deer exists on the Forest. The 

Forest Plan (FEIS 3-631) also predicts that there should be sufficient 

habitat capability for deer hunted in the Kake community use area by 

Kake residents and all rural hunters (the restriction affecting non-rural 

and non-resident hunters first). The risk of hunting restrictions would 

be reduced somewhat, through more intensive management (e.g. 

thinning) of the existing and future closed-canopy, young-growth 

forest in the area. 

No significant effect of salmon, other finfish or invertebrate habitat 

capability is expected from implementation of any alternative (see 

Essential Fish Habitat conclusions on page 133). Therefore use of 

most of these subsistence resources by Kake and Petersburg residents 

(fish and marine invertebrates) is not expected to be affected by any of 

the action alternatives or cumulatively within the analysis area. 

Subsistence plant foods consist of a variety of species. Some of the 

most sought after types include kelp, seaweed, goose tongue, 

mushrooms, and berries. Roads and previous timber harvest areas 

within the project area are excellent berry harvest locations since many 

berry species thrive on open, exposed slopes (Alaback 1982). None of 

the alternatives is expected to negatively affect subsistence plants 

gathered for food. Reasonably foreseeable effects of the action 

alternatives on the abundance and distribution of food plants would be 

minimal. 

Access to Subsistence Resources 

Access to subsistence resources is analyzed on the project area as this 

is the area where access will be affected by proposed activities and 

because the Kake Road System is not connected to another road 

system or community. 

Fish and Marine 

Invertebrates 

Food Plants 

Resource 

Analysis Area 
3 Environment and Effects 

104  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Direct and Indirect Effects 

For a detailed analysis of roads reference the Transportation section in 

this chapter or the resource report in the project record. 

The primary modes of access for harvesting wildlife and other 

subsistence resources include boats, foot travel, motorized vehicles, 

and all-terrain vehicles. The Central Kupreanof project area is 

connected to the community of Kake by a road system. 

Access by boat and foot would not be restricted by any of the action 

alternatives. Access to areas along the beach fringe would not change. 

All action alternatives would increase open road miles during 

implementation of the project and for up to ten years after the 

completion of timber harvest activities; however, all action alternatives 

would ultimately reduce miles open to motorized vehicle access. 

While new NFS roads may remain open for an additional five to ten 

years after the timber sale for such use as regeneration surveys and 

firewood gathering, long-term management objectives for all new and 

reconstructed NFS roads are to place them in storage and close them to 

motorized vehicle use. This increase in motorized vehicle access is 

considered limited and should not be considered for long-term use. An 

additional 1.69 miles of existing open NFS road would also be closed 

after timber harvest activities are completed. This closure would 

ultimately reduce the road density in all action alternatives by 

approximately 1 percent, which is considered insignificant. 

Temporary roads are built by and authorized for use by the timber 

purchaser for the sole purpose of accessing timber. Temporary roads 

are not open to the public and therefore are not considered in the 

increase or decrease of public access. 

Alternative 3 proposes to build the most miles of road and has the 

potential for the most increased access with approximately 25.1 miles 

of new NFS road and 9.1 of reconstruction. Alternative 2 proposes an 

increase in access by construction of 7.3 miles of new NFS road and 

2.9 miles of reconstruction. Alternative 4 does not increase long-term 

access within the project area as it does not construct any new NFS 

roads. However, with 2.6 miles of reconstructed road, areas that have 

been closed would be opened for a limited time. The increase in roads 

in all action alternatives would allow users to access some new areas 

with a motorized vehicle and therefore would increase their access (to 

different degrees) until roads are closed within ten years of the 

completion of the timber harvest activities.. 

Projects Common to all Action Alternatives are planned in the Central 

Kupreanof project area. Removal of stream crossings and closures of 

roads would benefit wildlife but may not benefit subsistence users by 

limiting road densities and motorized human access. Implementation 

Projects Common 

to all Action 

Alternatives 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 105 

of this project would be dependent on the analysis and decisions made 

in the District Access Travel Management process. Vegetation 

treatments should benefit wildlife and subsistence users as it helps to 

restore side lighting to the forest floor, increasing the production of 

Forbes and shrubs as well helping to promote taller and denser stands 

of trees that can provide shelter (snow interception). Projects 

involving recreation may not benefit wildlife but benefit subsistence 

users as the projects may increase access (trails) or encourage people 

to gather (camp sites, shelters). These projects may not harm wildlife 

directly but it may encourage people to be in the area who may 

indirectly take wildlife as part of their experience or opportunity. 

Cumulative Effects for Access 

Recommendations for additional road closures, use designations, and 

road decommissioning were developed through the update of the Kake 

Road System RAP. While these road management objective 

recommendations have the potential to affect access, they will be 

carried forward and analyzed during the District Access Travel 

Management process. Implementation of the road management 

objectives will be dependent on the decisions made in the ATM EA. 

Competition for Subsistence Resources 

Competition is closely linked to access. Building new roads opens an 

area by increasing access. This may be a favorable development for 

some subsistence users who depend on a road to transport their 

animals or resources from the field. On the other hand, the increased 

and potentially easier access could mean increased competition for 

subsistence resources and may have an adverse impact on current 

subsistence users. Increased access can also be favorable for 

subsistence users, creating easier access to hunting and gathering areas 

but may have a long-term adverse impact for users if over-harvesting 

occurs. 

None of the action alternatives are expected to have any effect on 

competition between rural and non-rural residents since none of the 

alternatives change the existing access patterns to other communities. 

Potential conflicts among user groups for subsistence resources would 

be the same among alternatives. 

ANILCA Compliance 

The actions proposed in this document have been examined to 

determine whether they are in compliance with the Alaska National 

Interest Lands Conservation Act (ANILCA) Section 810 and 811. 

Standards used for the review include: 
3 Environment and Effects 

106  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 National Forest Management Act of 1976 and its implementing 

regulations 

 Alaska National Interest Lands Conservation Act (1980) 

 Tongass Land and Resource Management Plan (1997) 

 Tongass Timber Reform Act (1990) 

 Alaska State Forest Practices Act (1993) 

 Alaska Coastal Management Program (1997) 

 Multiple Use Sustained Yield Act (1960) 

 USDA Forest Service Subsistence Management and Uses 

Handbook (FSH 2690.23) 

The actions have been determined to be in compliance with these 

standards and with ANILCA. 

ANILCA placed an emphasis on the maintenance of subsistence 

resources and lifestyles. However, the Act also required the Forest 

Service to make timber available for harvest from the Tongass 

National Forest. The Forest Plan determines which uses are suitable 

for various areas of land within the Tongass National Forest. The 

Forest Plan has determined that the Central Kupreanof Project Area 

should be managed for varying levels of timber production. 

The alternatives presented here encompass three action alternatives 

that would help achieve multiple-use management objectives in the 

Forest Plan. None of the action alternatives has a significant 

possibility of a significant restriction to subsistence uses. For 

subsistence deer use, a significant possibility of a significant restriction 

on the current level of subsistence deer harvest due to federal forest 

management activities is not likely under any of the alternatives. 

Amount of Land Necessary to Accomplish 

the Purpose of the Proposed Action 

The amount of public land necessary to implement each of the 

alternatives is, considering sound multiple use management of public 

lands, the minimum necessary to accomplish the objectives of the 

alternatives. One or more rural communities for subsistence purposes 

use much of the Tongass National Forest. It is not possible to lessen 

timber harvest in one area, and concentrate it in another without 

influencing one or more rural communities’ important subsistence use 

areas. 

Many of the decisions to minimize the amount of public land that 

would be used for timber harvest were made as part of the Forest Plan. 

Necessary and 

Consistent with 

Sound 

Management of 

Public Lands 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 107 

The Forest Plan allocated many important subsistence use areas to land 

use designations that do not allow timber harvest. 

The extent and location of the subsistence use areas in the Central 

Kupreanof project area make it impossible to completely avoid 

subsistence areas during timber harvest. However, large areas of deer 

habitat are protected in old-growth habitat reserves, riparian, beach 

buffers and other non-development LUDs. Fish habitat is protected in 

each alternative through the application of Forest Plan standards and 

guidelines. Existing roads and logged areas are currently used for 

subsistence hunting and food gathering activities. All temporary roads 

would be decommissioned following harvest. All NFS roads reopened 

during the harvest activity and new NFS roads would be put into 

storage within ten years of harvest. Please refer to the Road 

Management Objective for each road located in the Appendix B and 

the project record. 
3 Environment and Effects 

108  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Hydrology/Fisheries 

Analysis area 

Within the project area there are portions of nine watersheds 

corresponding to the 6th level Hydrologic Unit Code (HUC) 

recognized by the US Geological Survey (USGS) (Figure 3-3). These 

include both “true” watersheds in which all surface water drains to a 

single stream or river, and “frontal” watersheds along coastlines or 

bays having more than one outlet. Of the nine watersheds, seven are 

analyzed in detail, with watershed size, occurrence of high and very 

high hazard soils, natural and management-induced sources of 

disturbance, stream density, timber harvest history, road density, and 

percent of basin as roads summarized in tables below. East Keku 

Strait, a watershed partially in the project area, had a 13-acre area 

harvested in 1929 and no previous road building. This watershed has 

no planned timber harvest or road building, and will only be 

considered in terms of cumulative effects. The southwest corner of 

Towers Arm Watershed includes 42 acres proposed for harvest in unit 

217 of Alternative 3. There has been no previous harvest and no roads 

in this watershed, and no roads are proposed. The proposed harvest 

prescription is single tree selection and comprises 0.2 percent of the 

watershed area. The effects of harvesting this area would be negligible 

on the watershed scale, and no detrimental hydrological effects are 

expected if implemented, therefore this watershed will also only be 

analyzed in terms of cumulative effects. 

Watersheds 
!.

!.

6030

6314S

6328

6040

6326

6314

6336

45808

45601

6339

6333

6367

6366

45803

6334

6327

6318

45001

45002

45806

45602

6326

c:/workspace/ckupre/plots/deis/fig3_3_ws_streams.mxd 09-20-08 EP

Legend

Analyzed Watersheds

Watershed Boundary

Lakes

Stream Class I

Stream Class II

Stream Class III

Stream Class IV

Existing Open Roads

Roads in Storage (Closed)

Project Area Boundary

!. Fish Pass

±

0 1 2 3 4 0.5

Miles

Hamilton

McNaughton

Big John

West Duncan

Keku

Tunehean

Castle

D u n c a n

C a n

a l

R

o

c

k

y

P

a

s

s

Central Kupreanof Timber Harvest

Figure 3-3

Stream Class and Watersheds

Irish Creek

Fish Pass

Upper Keku Creek

Fish Pass
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 111 

Affected Environment and Existing 

Condition 

Watersheds were identified, delineated, and characterized primarily 

using information queried from the Tongass GIS library. Climate 

conditions and precipitation values in project-area watersheds were 

determined using a regional water resource atlas (USDA, Forest 

Service 1979), with regional patterns confirmed using the Alaska 

Climate Research Center website (http://climate.gi.alaska.edu/). GIS is 

used to summarize location, climate, geology, hydrology, stream 

density, road density, harvest history, landslide inventory, and 

disturbance regimes including erosion and mass movement hazard. 

District-wide road condition surveys were used in conjunction with 

GIS to determine number of stream crossings, and streams requiring 

additional information or field verification. Field surveys were 

conducted to verify fish presence or absence, fish species, stream class 

and channel type, and to map streams in the proposed harvest units and 

surrounding areas within project area watersheds using Global 

Positioning System (GPS). Employees are trained to determine stream 

class using both fish presence and stream channel characteristics. 

Relative changes in stream gradient, flow, pool quality and frequency, 

and barriers to upstream movement are used to determine extent of 

fish habitat upstream of the last fish detection. Fish presence or 

absence is verified using a backpack electrofisher. Employees also 

categorize stream channels according to the Tongass National Forest 

Channel Type User Guide (USDA Forest Service, 1992), the 

foundation upon which aquatic habitat management prescriptions are 

developed. Individual channel type classification methods are 

discussed in more detail in the Aquatics Resource Report (Whitacre 

and Harlan, 2009). The above information is combined with available 

water quality and fish distribution data for an overall watershed 

characterization. 

Water quality information on streams within the project area is limited. 

An historical USGS stream gage on Hamilton Creek recorded 

temperatures exceeding the Alaska Department of Environmental 

Conservation’s 20 degree C maximum standard in most years of 

record. Hamilton Creek is a large, low gradient stream of sufficient 

width that the riparian canopy cannot effectively shade large portions 

of its length. Occasional water temperatures greater than 20 degrees 

are therefore assumed to be a normal response to ambient conditions 

for this stream. Recent data from three case-study watersheds on 

Prince of Wales Island indicate temperature limits are exceeded even 

in unmanaged watersheds under conditions of higher than normal air 

temperature (Thompson and Tucker, 2007). 

Watershed 

Characterization 

& Field Methods 

Water Quality 
3 Environment and Effects 

112  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Timber harvest within project area watersheds began in 1929 on the 

beach fringe in the West Duncan Canal watershed. Harvest rates were 

low until the mid-1960s when the Kake road system was built, with 

harvest of suitable timber in valley bottoms and toe slopes easily 

accessible from the road system. There are no watersheds within the 

project area with more than 20 percent of the timber harvested in the 

past 30 years, a conservative estimate of the time needed for 

hydrologic recovery. Full hydrologic recovery in the absence of roads 

is expected to require between 10 and 30 years in the Pacific 

Northwest (Hicks et al., 1991; Jones, 2000; Moore and Wondzell, 

2005). Less than 9 percent of McNaughton Point Watershed has been 

harvested in the past 30 years, the highest of all project area 

watersheds (Table 3-23). 

Table 3-23. Summary of Timber Harvest Acres in Project Area 

Watersheds (not including road clearings) 

Watershed Watershed 

Acres 

Total Acres 

Harvested 

Total 

Percent 

Harvested 

Percent 

Harvested 

Since 

1978 

Hamilton 49,810 2,542 5.1 3.2 

McNaughton 

Pt 10,212 898 8.8 8.8 

Big John 

Creek 12,977 585 4.5 4.5 

West 

Duncan 

Canal 

43,817 844 1.9 0.4 

Keku Creek 30,796 57 0.2 0.2 

Castle River 33,060 425 1.3 1.3 

Tunehean 

Creek 24,734 390 1.6 1.2 

Watersheds in the project area are generally characterized by low relief 

(steepness) of the mainstem channels, with portions of the watershed 

having high concavity profiles where steep mountain slopes meet lowgradient valleys. Landslides and debris flows in these settings typically 

deliver sediment and debris in discrete deposits in the form of large log 

jams and fans at confluences, resulting in patchy disturbance patterns 

(May, 2007; Benda et al., 2004). Watershed factors such as drainage 

Harvest History 

Natural 

Disturbance 

Processes 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 113 

efficiency (as measured by stream density), road density, percent of 

basin as roads, time elapsed since timber harvest, steepness of the 

topography, and percent of the watershed with high and very high 

MMI soils (MMI-3 and MMI-4, see Soils report) contribute to 

determining risk of mass movement. Mass movement events such as 

landslides and debris torrents may be accelerated by forest 

management activity if surface or subsurface hydrologic 

characteristics of the site are altered, as can occur with timber harvest 

and road drainage diversions (May, 2007; Swanston and Marion, 

1991). A landslide inventory was completed in December 2003, using 

1998 aerial photos and the Forest Service land surveys completed in 

the 1960s and 1980s. Landslide occurrence in project area watersheds 

is low, reflecting the low percentage of soils within the high and very 

high MMI categories and generally low relief topography (Table 3-

24). 

Table 3-24. Percent of High and Very High Hazard MMI Soil 

Types and Landslide Summary for Project Area 

Watersheds1

Hazard Soils 

/ Landslides 

Hamilton 

Creek 

McNaughton 

Point 

Big 

John 

Creek 

W 

Duncan 

Canal 

Keku 

Creek 

Castle 

River 

Tunehean 

Creek 

MMI-3 2 2 4 9 4 6 7 

MMI-4 1 0.5 6 7 1 5 5 

Number of1

Landslides 3 0 4 1 0 8 6 

Landslide 

Area (acres) 3.0 0 21.2 6.0 0.0 11.4 21.0 

1

 Landslide totals include those slides occurring outside the project area but within 

project-area watersheds. 

Windthrow is also a source of natural disturbance in project area 

watersheds. Aerial photo and field assessments of windthrow in 

proposed units within project area watersheds indicate natural riparian 

windthrow is not a significant stream disturbing process, although 

individual tree windthrow is probably an important source of large 

woody debris to stream channels. See Timber and Vegetation section 

for further discussion of windthrow. 

Watersheds within the project area contain nine of ten process groups 

defined in the Channel Type User Guide for the Tongass National 

Forest (USDA Forest Service, 1992). One characteristic that helps 

define each process group is the predominant sediment transport 

Fluvial Process 

Groups and 

Stream Density 
3 Environment and Effects 

114  Chapter 3 Central Kupreanof Timber Harvest FEIS 

regime. Relative proportions of these regimes and their location with 

respect to proposed management activities within a watershed can aid 

in assessing the risk of sediment delivery to streams. Stream densities 

(miles of stream per square mile of area) can be used to indicate how 

efficiently this sediment may be routed through the watershed. 

Generally, the higher the stream density the more efficiently it may be 

routed. Watersheds with high relative stream densities and a greater 

proportion of streams dominated by deposition regimes may be more 

susceptible to sediment-related impacts. 

There are currently 129 miles of roads in project area watersheds. 

This estimate includes all roads ever built, NFS and temporary roads, 

regardless of age. Since maintenance regimes of roads within the 

project area differ (for example some are decommissioned while 

others are suitable for passenger vehicles), varying degrees of 

hydrological effect due to roads can be assumed. Including all road 

miles in each watershed provides the most conservative analysis 

possible for determining the effect of roads on watershed hydrology. 

Percentage of watershed area occupied by roads, and density of stream 

crossings have been used to help quantify the risk of flow-related 

impacts to aquatic systems including sediment introduction into 

streams. Sediment introduction is influenced by many factors 

including type of structure at the crossing, road slope, age, road 

condition, time since last graded, seasonal timing of maintenance 

activities, hillslope length, soil depth, and cutbank depth (Croke et al., 

2005; Wemple and Jones, 2003; Kahklen and Hartsog, 1997; Reid and 

Dunne, 1984). 

The densities of roads, streams, stream-crossings, and percent basin 

area as roads are low in project area watersheds, with the highest 

values occurring in the McNaughton Point and Big John Creek 

watersheds, respectively (3-25). Studies in Southeast Alaska have 

correlated higher rates of road erosion with heavy traffic and poor 

quality rock surfacing (Kahklen and Hartsog 1999). In Washington’s 

Olympic Peninsula, accumulation of fine sediment in streambeds was 

found to be highest in basins where the road area exceeded 2.5 percent 

of the basin area (Cederholm et al. 1980). A statistical relationship 

between fine streambed sediment and watershed disturbance has not 

been reported in Southeast Alaska studies (Bryant et al 2004, 

Woodsmith et al 2005). Nonetheless, Cederholm’s suggested threshold 

provides a way to evaluate the potential impacts of roaded area in the 

affected watersheds in comparison to findings elsewhere in the Pacific 

Northwest. 

Roads and 

Stream Crossings 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 115 

Table 3-25. Density of Roads and Streams in Project Area 

Watersheds 

Watershed Area 

(mi2) 

Road 

Miles 

Road 

Density 

(mi/mi2)

% 

Basin 

as 

Roads 

Stream 

Density 

(mi/mi2) 

Stream 

Crossing 

Density 

(# crossing 

/mi2) 

Hamilton 

Creek 77.8 49.7 0.6 0.5 2.1 1.5 

McNaughton 

Point 16 16.8 1.1 0.8 2.6 5.5 

Big John 

Creek 20.3 17.6 0.9 0.7 2.8 6 

West Duncan 

Canal 68.5 19.0 0.3 0.2 2.2 1.2 

Keku Creek 48.1 5.5 0.1 0.1 2 0.5 

Castle River 51.7 13.9 0.3 0.2 2.1 0.6 

Tunehean 

Creek 38.6 6.5 0.2 0.1 2.2 0.7 

Total 320.9 128.9 

The condition of existing roads, culverts, and drainage features are 

assessed during road condition surveys (RCS). As part of these 

surveys, each road crossing structure in a fish stream is assessed for its 

ability to provide unimpeded passage (USDA Forest Service, 2001). 

Fish crossings are categorized red, gray, or green according to passage 

conditions. A red fish crossing has a high certainty of not providing 

juvenile fish passage at all desired stream flows; a green crossing has a 

high certainty of meeting juvenile fish passage at all desired stream 

flows; and a gray crossing requires additional analysis to determine its 

ability to provide juvenile fish passage. 

According to the most current RCS data, there are 54 red crossings, 7 

gray crossings, and 47 green crossings within the project area and on 

the haul route between the project area and the Little Hamilton LTF. A 

stream crossing is classified as Class I (anadromous) or II (resident) if 

it has verified anadromous or resident fish downstream and habitat or 

verified fish presence upstream. 
3 Environment and Effects 

116  Chapter 3 Central Kupreanof Timber Harvest FEIS 

An analysis of the available data was conducted to determine the 

amount of upstream habitat impacted by red crossings. The number 

and location of red crossings was queried from the existing RCS data, 

and field-verified Upstream Habitat Assessment (UA) data 

corresponding to these locations was used to determine the amount of 

upstream habitat impacted. GIS and aerial photo interpretation was 

used for 4 crossings for which UA data was unavailable. Of the 54 

culverts, 50 are classified as Class II stream crossings and 4 are 

classified as Class I stream crossings (Table 3-26). 

Table 3-26. Summary of Upstream Habitat Impacted by Red 

Fish Crossings 

Miles of Habitat 

Impacted 

Total Habitat 

Available (miles) 

Watershed 

# of Red 

x-ings 

Class I Class II Class I Class II 

Hamilton Creek 22 0.6 7.2 111.2 16.3 

McNaughton Point 14 0.3 2.3 24.9 4.5 

Big John Creek 8 0 1.7 25.6 11.7 

West Duncan Canal 3 0 0.5 47.5 47.9 

Keku Creek 0 0 0.0 59.1 17.8 

Castle River 6 0 1.9 64.9 16.0 

Tunehean Creek 0 0 0.0 35.6 24.3 

Cathedral Falls1 1 0 0.3 1.6 39.4 

Total 54.0 0.9 13.9 370.4 177.9

1

 Miles of stream in Cathedral Falls Watershed included due to red fish crossing 

along haul route.

A total of 14.8 miles, or 2.7% of the total available habitat was 

determined to be impacted, with 5 of the 54 red crossings accounting 

for 38% of the total habitat impacted. 

While red fish crossings have a high certainty of not providing 

juvenile fish passage at all desired stream flows, they are not 

necessarily complete barriers. More often they impede passage to 

juvenile fish at higher flows, and remain passable at lower flows. A 

study conducted on Mitkof Island found most cutthroat and Dolly 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 117 

Varden move within a narrow range of flows with few moving at 

higher flow volumes (Bryant et al., 2009). All fish in the study moved 

upstream at flows below bankfull conditions. Our analyses shows 93% 

of the red fish crossings in the project area had fish present upstream, 

indicating the culverts are allowing passage at most flows and are not 

complete barriers. The 4 Class II red crossings with no fish upstream 

may or may not be impacting passage because stream class 

determinations are based on habitat characteristics as well as the 

presence of fish downstream. It is unknown whether fish historically 

utilized these upstream areas even if downstream presence is verified. 

For example, the one Class I stream crossing with no anadromous fish 

verified upstream or downstream was classified using habitat criteria. 

This crossing has resident fish upstream and downstream of the 

crossing suggesting the culvert is not impeding passage and 

anadromous fish may never have used the available Class I habitat. 

Additionally, the estimate of total habitat impacted is conservative 

since many Class I and II streams remain unmapped. For example, 

some of the known red fish crossings are not in the GIS layer and 

therefore are not included in the GIS query of total habitat available. 

Also, the UA survey data includes all unmapped tributaries to the red 

fish crossings which have fish or fish habitat, while those queried 

through GIS do not. The 548.6 miles of available habitat in project 

area watersheds, therefore, is likely underestimated and the true 

percentage of habitat impacted by red fish culverts is much lower. 

Overall, the total amount of habitat impacted is proportionally low, 

with 93% of red fish crossings having fish upstream and a 

conservative 2.7% of total habitat impacted. Many of these crossings 

may be corrected through the proposed road closures identified 

through the Road Analysis process (RAP). Red fish culverts 

associated with these proposed closures will be identified in the 

Petersburg Access Travel Management Environmental Assessment 

scheduled in 2009. 

Streams on the Tongass National Forest are divided into value classes 

from I to IV indicating levels of habitat use by fish populations 

(USDA Forest Service, 2001b). The abundant Class I and Class II 

habitat in the form of streams and lakes indicates high fisheries value 

within the project area (Table 3-27). 

Fisheries 
3 Environment and Effects 

118  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-27. Stream Classes and Lake/Pond Habitat within 

Project Area Watersheds 

Stream Class (miles) 

Watershed Area 

(mi2) I II III IV 

Lakes & 

Ponds 

(acres) 

 # 

Lakes 

& 

Ponds 

with 

Fish 

Habitat

Hamilton 

Creek 77.8 111.2 16.3 10.9 26.2 82 18 

McNaughton 

Pt 16 24.9 4.5 2.5 10.1 0 0 

Big John 

Creek 20.3 25.6 11.7 7.1 12.2 98 3 

West Duncan 

Canal 68.5 47.5 47.9 40.3 17.9 313 38 

Keku Creek 48.1 59.1 17.8 18.6 1.5 326 30 

Castle River 51.7 64.9 16 15.2 10.8 70 7 

Tunehean 

Creek 38.6 35.6 24.3 20.6 4.1 189 12 

Total Stream1

Class 320.9 368.9 138.4 115.3 82.8 

1 Miles of stream reflects the best information available from aerial photos and field 

reconnaissance. These numbers do not reflect class 4 streams not visible from aerial 

photos, or those that are not near proposed harvest units 

Alaska Department of Fish and Game maintains a catalog of waters 

important for the spawning, rearing, or migration of anadromous fish 

(Johnson et al., 2004). The catalog and field verification provide 

information about the fish species found within each watershed (Table 

3-28). All project area watersheds contain some fish habitat. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 119 

Table 3-28. Anadromous Fish Presence in Project Watersheds 

Fish 

species 

Hamilton 

Creek 

McNaughton 

Point 

Big 

John 

Creek 

W 

Duncan 

Canal 

Keku 

Creek 

Castle 

River 

Tunehean 

Creek 

coho 

salmon X X X X X X X 

chum 

salmon X X X X X X X 

pink 

salmon X X X X X X 

sockeye 

salmon X 

steelhead X X X X X 

cutthroat X X X X X 

Dolly 

Varden X X X X X X 

Previous fisheries efforts created two fishpasses in the Keku Creek 

watershed, with resting pools blasted into bedrock at a third site that 

delayed fish. Irish fishpass is low in the watershed and outside the 

project area. This fishpass is a 160-foot long vertical slot fish ladder 

that was built in 1984 to allow coho to bypass a 23-foot waterfall. The 

area above the fishpass was stocked with coho but the pass is used by 

steelhead, pink and chum salmon. 

Keku fishpass, built in 1985, is a 30-foot long steeppass located higher 

in the watershed and within the project area to allow coho to bypass an 

11-foot waterfall. The fishpass is used by coho and steelhead. Over 3 

million coho fry from Crystal Lake Hatchery were released in the 

upper watershed from 1983 through 1986. A natural bedrock cascade 

was identified above the Keku fishpass as partially blocking fish 

migration, and was modified three times to improve fish passage. The 

two fishpasses provided anadromous access to approximately 45 miles 

of stream habitat and 170 acres of lake habitat estimated to produce 

40,000 pink salmon, 16,000 chums, and 29,000 coho. Approximately 

67 acres are proposed for harvest in this watershed, in units containing 

no recorded fish habitat. Minimal effect to the fisheries resources 

enhanced by these fishpasses is expected. 

Keku-Irish Creek 

Fishpasses 
3 Environment and Effects 

120  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Watersheds within the project area include some shoreline along 

Duncan Canal and Rocky Pass containing diverse estuarine and tidal 

habitats, areas vital for some commercially important species such as 

Dungeness crab and juvenile salmon. These areas are part of a 

complex and diverse ecosystem that includes shrimp, flatfish, marine 

worms, starfish, sponges, anemones, sea cucumbers, urchins, shellfish, 

plankton, marine algae, and other organisms. 

Log Transfer Facilities are planned points of concentrated activity 

along these shoreline environments, with the remaining shoreline 

protected by a 1,000-foot buffer (Forest Plan, 2008). The Little 

Hamilton Bay LTF would be used to barge or raft the logs for this 

project. The Little Hamilton Bay LTF, located on Little Hamilton 

Island and connected to Kupreanof by a land bridge road, was placed 

on the Section 303(d) list of impaired waters in 1996 due to bark and 

woody debris accumulation on the bottom of Hamilton Bay as a result 

of logging operations. The bay was removed from the list in 

2002/2003 after a dive survey in June 2002 found compliance with 

water quality standards for residues 

(http://dec.state.ak.us/water/wqsar/waterbody/2008FinalIntegratedRep

ort3-19-08.pdf ). 

Direct and Indirect Effects Common to all 

Action Alternatives 

Each of the proposed action alternatives relies on the existing road 

system. Action Alternatives 2 and 3 would require the construction 

and/or reconstruction of NFS roads, while Alternative 4 would only 

require the reconstruction of NFS roads. Constructing roads involves 

the immediate impact of removing rock and debris, placing prism 

material, blading, installing culverts or bridges, and removing timber 

for road clearings. All action alternatives would increase the number 

of crossings on fish-bearing streams. Risk of sediment delivery to 

streams is higher at road crossings, reflecting the potential for culverts 

to become plugged with sediment and debris. Increased sediment 

delivery to streams during construction activities may affect individual 

fish by reducing oxygen levels to developing eggs in spawning gravels 

and/or trapping emerging fry in the gravel. The use of BMPs and 

seasonal timing restrictions during construction activities will 

minimize impacts to fish (see the Road Cards in Appendix B). 

A direct effect of implementing all action alternatives would be the 

temporary increase in sediment delivery to streams due to new road 

building, road reconstruction, bridge construction, and the installation 

of culverts as discussed earlier. Short-term sediment delivery from 

these activities is not expected to degrade water quality beyond the 

standards established to fully maintain the water body’s designated 

Marine 

Environment 

Road 

Construction / 

Reconstruction 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 121 

beneficial uses (USDA Forest Service, 2006). These standards are 

addressed directly through mitigation measures described in the unit 

cards and road cards. 

All newly constructed and reconstructed NFS roads would be placed in 

storage within 10 years of harvest activities. Temporary roads would 

be decommissioned with the timber sale contract. Additionally, 1.7 

miles of currently open NFS road will be stored within 10 years of the 

timber sale (see Transportation section in this chapter). 

Storing roads will keep maintenance needs low and decrease the 

potential for sediment delivery to streams from the failure of drainage 

structures. Bridges would be installed at all crossings on streams with 

fish habitat on proposed temporary roads, and would be removed 

following the completion of harvest activities. Fish passage will be 

designed into all streams containing fish habitat as defined by stream 

class (see Road Cards in Appendix B). 

Removal of trees within 200 feet of NFS roads for constructing log 

stringer bridges, expanding existing rock pits, and constructing new 

rock pits will be addressed by applying BMPs and Forest Plan 

Standards and Guidelines. A Pit Development Plan will be reviewed 

prior to construction of new rock pits. 

Table 3-29. Number of Class I and II Crossings on Anadromous 

and Resident Fish Streams 

 ALT 1 ALT 2 ALT 3 ALT 4 

Watershed I II I II I II I II 

Hamilton 

Creek 0 0 0 0 0 0 0 0 

McNaughton 

Point 0 0 2 0 1 0 0 0 

Big John 

Creek 0 0 0 0 0 0 0 0 

W Duncan 

Canal 0 0 2 1 2 3 0 0 

Keku Creek 0 0 0 0 0 0 0 0 

Castle River 0 0 0 4 1 9 0 4 

Tunehean 

Creek 0 0 0 0 0 0 0 0 

Total 0 0 4 5 4 12 0 4 

Additional direct effects may include localized increase in annual 

water yield, increased peak flows, and altered timing of water delivery 

in small streams. Timber harvest causes changes in the collection, 

storage, and delivery of water in watersheds primarily by affecting 

evapotranspiration, canopy interception, cloud-water interception, and 

snow accumulation and melt rates. Peak flow increases may be 

Hydrologic 

Function 
3 Environment and Effects 

122  Chapter 3 Central Kupreanof Timber Harvest FEIS 

undetectable on the watershed scale when harvest levels are below 25 

percent (Jones and Grant, 1996; Beschta et al., 2000). Recent literature 

suggests peak flow increases can only be detected in flows with a 

return period of six years or less, and that effects of forest harvest on 

extreme flows cannot be detected using current technologies and data 

record lengths (Grant et al., 2008). Forest harvest effects are 

maximized in small watersheds, and diminish or remain constant with 

increasing watershed size. Further, when present, peak flow effects on 

channels should be confined to a relatively discrete portion of the 

channel network (Grant et al., 2008). 

Long-term effects of timber harvesting and road building on summer 

low flows are not well studied. Hicks et al. (1991) documented two 

case studies in which the long-term effects of logging on summer low 

flows were opposite: an eventual decrease in low flows was detected 

in one watershed after a period of increase, but an increase in summer 

low flows persisted in the other. Variable effects on low flows 

following harvest have been reported in rain-dominated coastal 

watersheds (Keppeler and Ziemer, 1990; Hicks et al., 1991). A study 

in Southeast Alaska concluded that timber harvest may result in higher 

levels of stream flow during dry periods (Bartos, 1989). However, 

recent analysis of these data suggests the change could be due to 

climatic cycles, not timber harvest (Neal, 2000). 

Potential changes in hydrologic function from this project are not 

expected to occur on the watershed scale, but may occur in 

subwatersheds and tributaries connecting mainstem streams in the 

short term. These potential effects are expected to diminish with time 

as a result of hydrologic recovery through vegetation regrowth. 

Qualitative assessments of changes in water yield, peak flow, and 

timing of water delivery to channels for each alternative are assumed 

to be site specific and have negligible effects at the watershed scale. 

Protection and maintenance of naturally functioning aquatic 

ecosystems from ground-disturbing activities associated with timber 

harvest is provided through application of Riparian Management Areas 

(RMAs). RMAs are land areas delineated through land management 

planning or watershed analysis that provide for the management of 

riparian resources, and typically occur adjacent to surface water bodies 

such as streams, lakes, and ponds. The Forest Plan Standards and 

Guidelines require that RMAs be delineated according to stream value 

classification and channel type process groups, with minimum 

protection standards defined for harvest activities and activities 

associated with road building. Riparian Management Areas are 

delineated for all Class I, II, and III streams within or adjacent to 

proposed harvest units according to the following guidelines. 

Riparian 

Management 

Areas 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 123 

All Class I and II streams are protected from harvest activities within a 

minimum horizontal distance of 100 feet from the bankfull margins. 

Harvest activities near Class I, II, and III streams require trees be 

felled away from the stream and that trees yarded across or along 

stream courses be fully suspended. Additional measures are taken to 

protect streams based on stream type process group classification 

(USDA Forest Service, 2008; Forest Plan, Appendix D-1 through D20). These measures include increased buffer widths of 140 feet or 

greater along certain types of Class I, II, and III streams. Under these 

standards, a no-harvest buffer protects all Class III streams, with 

harvest excluded in all v-notches associated with steep side slopes. 

Logging debris introduced into Class IV streams must be removed. 

Harvest prescriptions including single tree selection and those 

requiring a percentage of the available timber in a unit be retained may 

also help diminish the influence of altered peak flows to streams by 

lowering the intensity of the harvest treatment (Grant et al., 2008). The 

Unit Cards and maps show the specific locations of the RMAs and 

provide instructions for specific mitigation measures designed to 

protect aquatic resources. 

Clearcut timber harvest and road building cause an increased risk of 

landslides, debris flows, and debris torrents (Swanston and Marion, 

1991; Brardinoni et al., 2002). The increased risk of landslides is 

considered an indirect effect to streams, because if landslides do occur 

they may or may not deliver sediment to streams (see “Soils” section 

this chapter). GIS indicates 6 of 22 landslides within project-area 

watersheds impacted streams, with 3 occurring in the mountains 

forming the eastern boundary in the Big John Creek watershed. Most 

of these landslides are arrayed to the southwest, and have no proposed 

units nearby. Minimizing the risk of landslides in clearcut harvest units 

and where roads are constructed is addressed by applying BMPs and 

Forest Plan Standards and Guidelines. Each of the proposed action 

alternatives would increase landslide potential to some degree, with 

relative risk related to the amount of proposed clearcut harvest acres 

on high or very high hazard soils. Comparisons of this risk are 

presented under each alternative. 

Logs will be hauled to the Little Hamilton Bay LTF for transportation 

by barge or raft to the mill in all action alternatives. Barging the logs 

would have less effect on marine species. Habitat for managed marine 

species and their prey may be diminished due to bark accumulation 

resulting from rafting logs at the LTF. Another effect of log rafting is 

reduced rearing capability for juvenile salmon due to potentially 

reduced water quality from bark leachates and shading beneath log 

rafts and equipment floats. 

Landslides 

Log Transfer 

Facility 
3 Environment and Effects 

124  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Other projects associated with the proposed timber sale having direct 

and indirect effects include silvicultural thinning and pruning 

treatments (precommercial and wildlife habitat enhancements), 

Microsales, road and trail maintenance, invasive plant removal, and 

removal of structures known to limit fish passage on roads proposed 

for closure through the RAP. The effects upon implementation of these 

activities are similar to those described previously and below, 

regarding potential short-term increases in sedimentation and turbidity. 

Activities associated with these projects are not expected to have longterm negative effects on watershed hydrology or fish populations. 

Cumulative Watershed Effects 

Cumulative watershed effects occur both spatially and temporally. The 

6th level HUC watersheds, wholly or partially within the proposed 

project area, provide the spatial boundaries for direct, indirect, and 

cumulative watershed effects in this analysis. The 6th level HUC scale 

is recognized by the U.S. Geological Survey and is the commonly 

accepted scale for determining potential effects of management 

activities (Regional Interagency Executive Committee, 1995). 

Temporally, cumulative watershed effects may be influenced by some 

of the activities summarized above and in the Central Kupreanof 

Catalog of Events. This analysis emphasizes timber harvest activities 

in the past 30 years and road building activities regardless of age, due 

to their potential effect on peak flows and runoff timing, sediment 

delivery to streams, and fisheries resources. 

Management-related and naturally occurring activities influencing 

watershed fisheries and hydrology were considered. These included 

activities summarized in the Central Kupreanof Catalog of Events, 

number and location of known landslides, miles of NFS and temporary 

roads and their respective stream crossings, crossings currently 

impeding fish passage (red fish crossings), and the Irish and Keku fish 

pass project. While there are currently 54 red fish crossings, the Irish 

and Keku fish pass project provided approximately 45 miles of 

anadromous access for coho, steelhead, pink, and chum salmon. 

Cumulative watershed effects on watershed hydrology from previous 

harvest and road-building activities are diminished as vegetation 

encroaches in these areas. The majority of timber harvest in Hamilton 

Creek and McNaughton Point Watersheds occurred primarily in the 

1970s and 1980s, with hydrologic effects trending toward inherent 

levels. Harvest of previously cleared timber units from the Bohemia 

Timber Sale, as well as approximately 70 acres as part of the Kake 

Small Sales project are not considered in the cumulative effects 

Projects 

Analysis Area 

Past Activities 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 125 

analysis since these are not within the 6th HUC boundaries defining 

this analysis. 

Current activities influencing cumulative effects include maintenance 

of existing roads, revegetation on previously closed roads and open 

roads receiving little traffic, and revegetation in managed stands with 

previous harvest. 

Besides timber harvest and road building activities analyzed in each 

alternative below, activities occurring in the foreseeable future which 

could influence cumulative watershed effects include future closure of 

the newly constructed and reconstructed NFS roads associated with 

this sale, decommissioning temporary roads following the timber sale, 

and closure of additional NFS roads located within the project area but 

not associated with the proposed timber sale. Some roads have been 

recommended for closure through the RAP, and will be addressed in 

the Petersburg Access Travel Management Plan NEPA document 

scheduled in 2009. Newly constructed and reconstructed NFS roads 

could remain open for up to 10 years following timber sale activities 

(see Transportation section this chapter). Decommissioning temporary 

roads and closing some or all NFS roads constructed for the timber 

sale would result in a net decrease in the amount of roads needing 

maintenance. Placing or otherwise ensuring roads are in a selfmaintaining hydrologic condition (i.e. constructing water bars, 

designing rolling dips, drivable water bars, oversized crossing 

structures) would lower the amount of potential groundwater 

interception by road cuts, decrease the number of miles in the road 

related stream network by removing those portions associated with 

ditches, improve natural drainage patterns, reduce the risk of culvert 

plugging and stream diversion, and lower the risk of road failures at 

stream crossings. Removal culverts for road closure is known to 

temporarily increase sediment delivery and turbidity in some streams. 

Generally, effects decrease with time and distance downstream and 

mitigation measures can significantly reduce the sediment yield caused 

by removals (Foltz et al., 2008). 

Since NFS road closures are expected to occur within ten years of 

implementation of the proposed timber harvest, cumulative effects of 

these closures are time-sensitive. When culverts are removed, 

hydrologic recovery is immediate at road crossings; when culverts are 

not removed, there continues to be a risk of the culvert becoming 

plugged with sediment and debris. This risk decreases by placing 

water bars for routing water across the road prism in the case of a 

failure. Sediment delivery from the road surface and ditches continues 

until sufficient vegetation regrowth has occurred. Road closures are 

expected to benefit watershed hydrology and fish passage in the longterm. Short-term increases in sediment delivery associated with road 

building activities are addressed directly through mitigation measures 

Current Activities 

& Processes 

Future Activities 
3 Environment and Effects 

126  Chapter 3 Central Kupreanof Timber Harvest FEIS 

described in the Road Cards in Appendix B and through 

implementation of BMPs. These practices are expected to maintain 

water quality and fish passage within standards established by the 

State of Alaska. 

Other projects discussed under “Direct and Indirect Effects” having 

cumulative impacts in the foreseeable future include silvicultural 

thinning and pruning treatments (precommercial and wildlife habitat 

enhancements), Microsales, road and trail maintenance, invasive plant 

removal, and removal of red fish crossings proposed for closure 

through the RAP. The effects upon implementation of these activities 

are similar to those described previously. Road and trail maintenance 

activities are expected to benefit watershed hydrology in the long-term 

by maintaining drainage efficiency through crossing structures, 

thereby reducing potential sources of stream sedimentation. Activities 

associated with the above-described projects are not expected to have a 

long-term negative effect on fish populations or habitat. While there 

may be incidental death of fish due to these projects, fish populations 

in the project area are expected to remain viable and maintained at 

current levels. 

Rates of timber harvest on Kupreanof Island have varied among 

watersheds but were generally higher in the 1980s. Research suggests 

timber harvest may have caused non-permanent increases in landslide 

potential and water yield during certain time periods, and that recovery 

to pre-harvest conditions is ongoing. Cumulatively, there is a general 

trend toward recovery of slope stability and pre-harvest rates of 

canopy interception and evapotranspiration in the two watersheds with 

the highest levels of proposed harvest (Tables 3-30 and 3-31). 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 127 

Effects by Alternative 

Table 3-30. Summary of Proposed Timber Harvest by 

Alternative 

ALT 1 ALT 2 ALT 3 ALT 4 

Watershed ADF&G 

Number 

Watershed 

Size (ac) 

Harvest 

(ac) 

Harvest 

(ac) 

Harvest 

(ac)1

Harvest 

(ac) 

Hamilton 

Creek 

109-42-

10100 49,810 0 1,031 1,078 651 

McNaughton 

Point 

105-32-

10185 10,212 0 509 587 314 

Big John 

Creek 

105-32-

10160 12,977 0 303 336 164 

W Duncan 

Canal 

106-43-

10350 43,817 0 375 913 82 

Keku Creek 105-32-

10120 30,796 0 72 72 0 

Castle River 106-43-

10210 33,060 0 62 465 59 

Tunehean 

Creek 

105-32-

10040 24,734 0 153 153 56 

Total 0 2,505 3,604 1326 

1

 There is an additional 41.8 acres proposed in Alt 3, located in Towers Arm 

Watershed near the SE corner of Hamilton Watershed in Unit 217. This watershed 

was not analyzed separately. 

None of the project area watersheds have cumulative harvest levels 

approaching 20 percent in the past 30 years (Table 3-31). Under the 

action alternatives, proposed harvest levels would cause increases in 

the 30-year cumulative harvest in all watersheds if implemented in 

2009. The greatest increase in cumulative harvest levels would occur 

in the McNaughton Point watershed, from 8.8 percent to 14.5 percent 

in Alternative 3. Cumulative watershed effects are described below 

under each alternative. 
3 Environment and Effects 

128  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-31. 30-year Cumulative Harvest Percentage by 

Alternative1 

Watershed Watershed 

Size (Acres) 

Existing 

(2008) 

ALT 

12

ALT 

2 

ALT 

3 

ALT 

4 

Hamilton 

Creek 49,810 3.2 1.9 5.3 5.4 4.6 

McNaughton 

Pt 10,212 8.8 2.9 13.8 14.5 11.9 

Big John Creek 12,977 4.5 4.5 6.8 7.1 5.8 

West Duncan 

Canal 43,817 0.4 0.4 1.3 2.5 0.6 

Keku Creek 30,796 0.2 0.2 0.4 0.4 0.2 

Castle River 33,060 1.3 1.3 1.5 2.7 1.5 

Tunehean 

Creek 24,734 1.2 1.2 1.9 1.9 1.5 

1

Assumes a 2009 implementation date, and that all proposed acres are harvested. 2

 Cumulative percentage values under Alternative 1 reflect hydrologic recovery trend 

by 2009 in these watersheds. 

Alternative 1 

In the no action alternative, no commercial timber harvest would occur 

and no roads would be built. Selection of this alternative would not 

preclude regular maintenance of existing roads, including erosion 

control measures and removal or replacement of culverts. The risk of 

landslides associated with previously-built roads is ongoing and is 

considered an indirect effect, because if landslides do occur, they may 

or may not deliver sediment to streams. Sediment delivery to streams 

from periodic road maintenance is expected to be minor and within 

water quality standards set by the State of Alaska. 

Cumulative effects associated with the no action alternative are limited 

to the growth of trees in managed stands harvested in the past and the 

reestablishment of more natural drainage patterns and vegetation on 

closed roads. Silvicultural thinning and pruning treatments for 

precommercial and wildlife habitat enhancement purposes may occur, 

and are not expected to alter hydrologic function on the watershed 

scale. Under this alternative, no changes in hydrologic function, 

sediment delivery to streams, or fish passage are expected beyond 

Direct and 

Indirect, Effects 

Cumulative 

Effects 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 129 

those discussed in “Effects Common to all Action Alternatives,” and 

naturally occurring events. Hydrologic function in all watersheds is 

expected to improve in the long-term under this alternative with the 

continued regrowth of vegetation and maintenance of roads and stream 

crossings. Effects of road closures proposed under the District ATM 

were discussed previously and are expected to benefit watershed 

hydrology and fish passage in the long-term. The Irish and Keku fish 

pass project is expected to continue providing habitat to support fish 

populations in the Project Area above naturally occurring levels. 

Alternative 2 

Alternative 2 proposes harvesting 2,505 acres (Table 3-30). Harvest 

systems would include ground-based cable, shovel yarding, and 

helicopter. Two thousand sixty-three acres are proposed to be clearcut, 

of which 266 acres are on slopes with a high mass movement index 

(MMI-3) (Table 3-32). These areas are assumed to have an increased 

susceptibility to potential landslides (see Soils report). 

Table 3-32. Proposed clearcut acreage1 in Alternative 2 on High 

(MMI-3) or Very High (MMI-4) Hazard Soils 

Watershed Proposed 

Clearcut MMI-3 MMI-4 

Hamilton Creek 914 128 0 

McNaughton Pt. 442 56 0 

Big John Creek 181 5 0 

West Duncan 240 62 0 

Keku Creek 72 8 0 

Castle River 61 7 0 

Tunehean 

Creek 153 0 0 

Total 2,063 266 0 

1

 Acres in Proposed Clearcut column include clearcut, clearcut with 10 percent, and 

clearcut with 50 percent reserve prescriptions. There are approximately 30 acres in 

McNaughton Point Watershed with a 10 percent reserve prescription in MMI-3 soils. 

Alternative 2 proposes clearing approximately 112 acres of timber for 

approximately 14.0 miles of newly constructed, reconstructed, and 

temporary roads (Table 3-33). Road building would result in an 

additional 59 stream crossings in project area watersheds, with 41 on 

Direct and Indirect 

Effects 
3 Environment and Effects 

130  Chapter 3 Central Kupreanof Timber Harvest FEIS 

NFS roads and 18 on temporary roads. New NFS road construction 

would require one Class I crossing. NFS road reconstruction would 

require the replacement of one Class I crossings and four Class II 

crossings. Temporary road construction will require one Class I and 

one Class II crossing. Both crossings on the temporary roads will be 

log stringer bridges. The above NFS roads may remain open up to 10 

years following timber harvest as discussed in the Transportation 

section of this chapter. An additional 1.7 miles of roads 6327, 45805, 

and 45807, including removal of four red fish crossings, will be closed 

within 10 years of timber harvest. All temporary roads will be 

decommissioned after timber harvest is complete. 

Table 3-33. Road Related Changes Proposed in Alternative 2 

 

Watershed New NFS Reconstruct Temporary New Stream 

Crossings 

Road 

Density 

% 

Basin 

as 

Roads 

Hamilton Creek 4.1 0.1 0.7 22 0.7 0.6 

McNaughton Point 1.2 0.0 1.4 14 1.2 1.0 

Big John Creek 0.0 1.3 0.8 6 1.0 0.8 

W Duncan Canal 1.4 1.0 0.4 5 0.3 0.3 

Keku Creek 0.1 0.0 0.3 4 0.1 0.1 

Castle River 0.1 0.4 0.1 4 0.3 0.2 

Tunehean Creek 0.4 0.0 0.2 4 0.2 0.1 

Total 7.3 2.9 3.9 59 

Harvest of 2,505 acres within the project area would increase 

cumulative harvest levels from current levels in all watersheds (Table 

3-30). The McNaughton Point watershed has the highest current 

cumulative harvest level at 8.8 percent, and would continue to have the 

highest cumulative percent harvest with this alternative. Cumulative 

effects of previous and proposed timber harvest and road-related 

activities were discussed above. In this alternative, the extent of these 

effects would be greater than those in Alternative 4 and lesser than 

Alternative 3 due to the relative amounts of activities proposed. 

Cumulative effects associated with ongoing activities are the same as 

those described in Alternative 1. 

Cumulative 

Effects 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 131 

Alternative 3 

Alternative 3 proposes harvesting 3,647 acres via ground-based cable, 

shovel yarding, and helicopter logging systems (Table 3-30). There are 

3,126 acres of proposed clearcut, of which 482 acres are on slopes 

with a high mass movement index (Table 3-34). These areas are 

assumed to be more susceptible to potential landslides (see Soils 

report). Streams in two units proposed under this alternative were not 

field verified. GIS and aerial photo interpretation was used in 

conjunction with field data collected by the road engineer and forestry 

technicians to assess the likelihood of additional streams in these units. 

The likelihood of additional Class I or II streams is very low due to the 

position of the Unit 248 on relatively steep slopes (~ 48%) located 

higher on the hillside, and a low risk of additional Class III streams 

based on photo interpretation and field notes. Unit 280 in the Castle 

River watershed has a moderate risk for a Class II stream near the 

southern boundary due to the proximity to a known Class II stream. 

There is also a moderate risk for an additional Class III stream in the 

northeast portion of the unit based on aerial photography, although no 

streams with significant notches were indicated by the road engineer 

when traversing the unit. These units will be field verified by a 

fisheries biologist during layout, with appropriate RMA buffers 

applied. The direct and indirect effects of harvest activities were 

discussed under “Effects Common to all Action Alternatives” and 

would occur to the greatest extent in this alternative due to the highest 

number of proposed harvest acres and road miles. 

Direct and Indirect 

Effects 
3 Environment and Effects 

132  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-34. Proposed Clearcut Acreage1 in Alternative 3 on High 

(MMI-3) or Very High (MMI-4) Hazard Soils 

Watershed Proposed 

Clearcut MMI-3 MMI-4 

Hamilton River 984 140 0 

McNaughton 

Point 520 56 0 

Big John Creek 299 54 0 

W Duncan 

Canal 664 217 0 

Keku Creek 72 8 0 

Castle River 434 7 0 

Tunehean Creek 153 0 0 

Total 3,126 482 0 

1

 Acres in Proposed Clearcut column include clearcut, clearcut with 10 percent, and 

clearcut with 50 percent reserve prescriptions. There are approximately 30 acres in 

McNaughton Point Watershed with a 10 percent reserve prescription in MMI-3 soils. 

Alternative 3 proposes clearing approximately 341 acres of timber for 

approximately 40.4 miles of newly constructed, reconstructed, and 

temporary roads (Table 3-35). Road building would result in an 

additional 139 stream crossings in project area watersheds, with 101 

on NFS roads and 34 on temporary roads. Most of these crossings 

occur on Class III and IV streams. New NFS road construction would 

require two Class I and five Class II crossings. There are portions of 

roads 45897 and 45803 proposed under this alternative with 

incomplete field information regarding stream crossings. Both roads 

have stream information along segments within proposed units, but 

stream crossing data has not been verified in those portions between 

units on 45897. The same is true for segments of road 45803 outside 

proposed units between the southern boundary of Unit 261 and the 

northeastern boundary of Unit 265. The most recent GIS stream layer 

and aerial photo interpretation were used to determine stream class 

along these segments. There is therefore an increased risk of 

underestimating the total number of crossings and potential Class I and 

II fish crossings on these roads. The potential effects of road building 

activities to fisheries and hydrology were discussed under “Effects 

Common to all Alternatives”, and these effects could increase should 

additional streams be found along these segments. These road 

segments will be field verified by a fisheries biologist during layout 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 133 

should this alternative be chosen, and the State of Alaska will conduct 

Title 16 review of all proposed fish crossings prior to implementation. 

NFS road reconstruction would require the replacement of one Class I 

and four Class II crossings. Temporary road construction would 

require one Class I and three Class II crossings. All the crossings on 

the temporary roads will be log stringer bridges. Road crossings on 

Class I and II fish streams are typically more susceptible to impacts 

caused by sediment, since these streams tend to occur lower in the 

watershed, and are predominantly characterized as sediment deposition 

reaches. The effects of increased sediment delivery to the stream on 

individual fish and the direct hydrological effects of timber harvest and 

road building were previously described, and would occur to the 

greatest extent in this alternative due to higher levels of these 

activities. An indirect effect of this alternative would be the closure of 

1.7 miles total of NFS Roads 6327, 45805, and 45807 within 10 years 

of harvest, including removal of four red fish crossings. All of the new 

and reconstructed NFS roads will be closed within ten years of timber 

harvest. All temporary roads will be decommissioned after timber 

harvest. Effects of road closures were described previously, and are 

expected to benefit fish passage and hydrologic function in the longterm. This alternative would have the greatest potential for bark 

accumulation at the Hamilton Bay LTF because it harvests the most 

volume of timber. 

Table 3-35. Road-Related Changes Proposed in Alternative 3 

Watershed New NFS Reconstruct Temporary New Stream Crossings 

New 

Stream 

Crossings

%Basin 

as 

Roads 

Hamilton Creek 5.2 0.9 0.7 31 0.7 0.6 

McNaughton Point 1.2 0.0 1.8 14 1.2 1.0 

Big John Creek 2.5 2.5 1.0 13 1.0 1.0 

W Duncan Canal 10.8 2.2 0.9 43 0.5 0.5 

Keku Creek 0.1 0.0 0.3 4 0.1 0.1 

Castle River 4.9 2.6 1.2 29 0.4 0.4 

Tunehean Creek 0.4 1.0 0.2 5 0.2 0.2 

Total 25.1 9.1 6.1 139 

Harvest of 3,647 acres within the project area would increase 

cumulative harvest levels in all watersheds (Table 3-30). The 

cumulative effects of previous and proposed timber harvest and road 

building are the same as those described in “Effects common to all 

Cumulative 

Effects 
3 Environment and Effects 

134  Chapter 3 Central Kupreanof Timber Harvest FEIS 

action Alternatives” and Alternative 2, but would occur to the greatest 

extent in this alternative due to higher levels of these activities. 

Alternative 4 

Alternative 4 proposes harvesting 1,326 acres, all of which would be 

clearcut using ground-based cable and shovel yarding. One hundred 

nineteen of these acres are on slopes with a high mass movement index 

(MMI-3) (Table 3-36). 

Table 3-36. Proposed Clearcut Acreage1 in Alternative 4 on High 

(MMI-3) or Very High (MMI-4) Hazard Soils 

Watershed Proposed 

Clearcut MMI-3 MMI-4 

Hamilton 651 73 0 

McNaughton 

Pt. 314 10 0 

Big John Creek 164 5 0 

W Duncan 

Canal 82 31 0 

Keku Creek 0 0 0 

Castle River 59 0 0 

Tunehean 

Creek 56 0 0 

Total 1326 119 0 

1

 Acres in Proposed Clearcut column include clearcut, clearcut with 10 percent, and 

clearcut with 50 percent reserve prescriptions. There are no reserve prescriptions in 

the high and very high hazard soils in this Alternative. 

Alternative 4 proposes clearing approximately 35 acres for 

approximately 4.8 miles of temporary and reconstructed NFS roads 

(Table 3-37). Road building would result in an additional 8 stream 

crossings with 6 on reconstructed NFS roads and 2 on temporary 

roads. There are no new road crossings on Class I streams. Temporary 

road construction would require one log stringer bridge over a Class II 

stream, and NFS road reconstruction will require 3 Class II stream 

crossings. Direct and indirect effects to watershed hydrology and 

fisheries related to timber harvest and road building were described 

under “Effects common to all action Alternatives,” and would occur to 

the least extent in this alternative due to the lowest levels of these 

activities among action alternatives. All of the new and reconstructed 

NFS roads plus the 1.7 miles total on NFS Roads 6327, 45805, and 

Direct and Indirect 

Effects 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 135 

45807 including four red fish crossings, would be closed within ten 

years of timber harvest. All temporary roads will be decommissioned 

after timber harvest is complete. Effects of road closures were 

described previously. This alternative would have the least potential 

for bark accumulation at the Little Hamilton Bay LTF if the logs are 

rafted because it harvests the least volume of timber. 

Table 3-37. Road-Related Changes Proposed in Alternative 4 

Watershed New NFS Reconstruct Temporary New Stream Crossings 

Road 

Density

% 

Basin 

as 

Roads

Hamilton Creek 0.0 0.9 0.4 2 0.7 0.5 

McNaughton Point 0.0 0.0 1.0 1 1.1 0.8 

Big John Creek 0.0 1.3 0.5 1 1.0 0.8 

W Duncan Canal 0.0 0.0 0.2 0 0.3 0.2 

Keku Creek 0.0 0.0 0.0 0 0.1 0.1 

Castle River 0.0 0.4 0.1 4 0.3 0.2 

Tunehean Creek 0.0 0.0 0.0 0 0.2 0.1 

Total 0.0 2.6 2.2 8 

Cumulative harvest levels would increase in all but Keku Creek 

Watershed if this alternative were implemented by 2009 (Table 3-30). 

Cumulative effects of timber harvest and road building, as well as 

those activities occurring in the foreseeable future were described 

previously and are expected to be the same for this alternative, but to 

the least extent of all action alternatives due to the lowest proposed 

levels of these activities. 

Cumulative 

Effects 
3 Environment and Effects 

136  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Essential Fish Habitat Assessment 

The 1996 amendments to the Magnuson-Stevens Fishery Conservation 

and Management Act require the Forest Service to consult with the 

National Marine Fisheries Service (NMFS) regarding actions that 

“may adversely affect” essential fish habitat (EFH) for federally 

managed marine and anadromous fish species. EFH consultation has 

been combined with the Forest Service NEPA process. Consultation 

procedures have been documented in an attachment to the June 26, 

2007 NMFS letter to the Regional Forester. 

Federally managed fish species are those species under the jurisdiction 

of the North Pacific Management Council, managed by the NMFS, 

and included in a fishery management plan (FMP). These common 

managed species include: Chinook, chum, pink, and sockeye salmon: 

Walleye pollock; Pacific cod; arrowtooth flounder; yellowfin, rock, 

rex, dover, and flathead sole; Alaska plaice; sablefish, Pacific Ocean 

perch; shortraker, rougheye, northern, thornyhead, yelloweye, and 

dusky rockfish; sculpin; skates; squid; octopus; forage fish; and 

weathervane scallop. Several common species not managed under 

FMP include halibut, ling cod, Pacific herring, Dungeness crab, 

cutthroat trout, steelhead, and Dolly Varden char. 

EFH is defined as “those waters and substrates necessary for fish 

spawning, breeding, feeding, or growth to maturity.” Marine EFH in 

Alaska includes estuarine and marine areas from tidally submerged 

habitat to the 200-mile exclusive economic zone (EEZ). Freshwater 

EFH includes streams, rivers, lakes, ponds, wetlands and other bodies 

of water currently and historically accessible to salmon. EFH for 

Pacific salmon recognizes six critical life history stages: (1) spawning 

and incubation of eggs, (2) juvenile rearing, (3) winter and summer 

rearing during freshwater residency, (4) juvenile migration between 

freshwater and estuarine rearing habitats, (5) marine residency of 

immature and maturing adults, and (6) adult spawning migration. 

Habitat requirements within these periods can differ significantly and 

any modification of the habitat within these periods can adversely 

affect EFH. 

The four main steps in the consultation process are the following: 

 The Forest Service determines if the proposed action will have 

“no adverse effect” or if it “may adversely affect” EFH. Only 

the “may adversely affect” determination triggers consultation. 

 An EFH Assessment is prepared by the Forest Service as a 

component of the NEPA and forwarded to the NMFS to initiate 

formal consultation. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 137 

 The NMFS will respond in writing as to whether it concurs 

with the conclusion in the EFH Assessment and may provide 

conservation recommendations to further minimize effects of 

the action on EFH. 

 The Forest Service must provide a written response to NMFS 

within 30 days explaining its evaluation of the conservation 

recommendations. The response may include reasons for not 

following the recommendation. 

The formal consultation begins when NMFS receives a copy of the 

draft environmental impact statement (DEIS) with the EFH 

Assessment. 

This EFH Assessment satisfies the requirements by providing 1) a 

description of the proposed action; 2) an analysis of the potential 

adverse effects of the action on EFH and the managed species; 3) the 

Forest Service’s conclusions regarding the effects of the action on 

EFH; and 4) a discussion of proposed mitigation, if applicable. 

Potential Adverse Effects on Freshwater 

EFH 

There are approximately 369 miles of Class I streams in the 7 

watersheds discussed above in the Hydrology and Fisheries section. 

Within the project area there are populations of federally managed 

species of pink, chum, coho, and sockeye salmon as well as 

populations of Dolly Varden, cutthroat trout, and steelhead. 

Potential effects on freshwater EFH include changes in water yield, 

peak flow volume and timing of flow delivery, sediment delivery, and 

fish passage at road crossings. A complete discussion of potential 

adverse effects, including cumulative effects, of the proposed action is 

in the Hydrology and Fisheries section. 

Alternatives 2 and 3 require new Class I road crossings on new NFS, 

reconstructed NFS, and temporary roads. 

Potential adverse effects to freshwater EFH will be minimized due to 

the following: 

 All Class I and II streams within the project area will be 

protected by a no-harvest buffer of 100 feet or more (see Unit 

Cards in Appendix B of the DEIS for site-specific activities). 

 All Class III streams will be protected by no-harvest buffers 

according to the Forest Plan. This minimizes the potential 

impact to downstream Essential Fish Habitat (see Unit Cards in 

Appendix B of the DEIS for site-specific activities). 
3 Environment and Effects 

138  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 All proposed Class I and Class II road crossings on temporary 

roads will be log stringer bridges. Temporary roads will be 

decommissioned after timber harvest is complete. 

 BMPs will be implemented to protect water quality and aquatic 

habitat for all freshwater streams within the project area. 

 The Forest Plan has specific Standards and Guidelines for 

riparian resources (pp 4-50 – 4-54), and riparian buffer criteria 

(Appendix D) (USDA Forest Service, 2008). 

Potential Adverse Effects on Marine EFH 

All alternatives use the Little Hamilton Bay LTF. The LTF is located 

on Little Hamilton Island and is connected to Kupreanof by a land 

bridge road. Hamilton Bay was placed on the Section 303(d) list of 

impaired water bodies in 1996 for bark accumulation. This water body 

was removed from the impaired list in 2002 when the dive survey 

reports showed that the bark accumulation was 0.6 acres. 

Barging the logs would minimize the effect on marine species. One 

potential effect of rafting logs at the LTF on marine species may be 

diminished habitat for managed species and their prey due to bark 

accumulation. Another effect of log rafting is reduced rearing 

capability for juvenile salmon due to potentially reduced water quality 

from bark leachates and shading beneath log rafts and equipment 

floats. 

According to the North Pacific Fisheries Management Council 

database (http://www.fakr.noaa.gov), NMFS has identified Hamilton 

Bay as EFH for arrowtooth flounder, Atka mackerel, capelin, Dover 

sole, eulachon, flathead sole, rex sole, rock sole, sand lance, Greenland 

turbot, octopus, yelloweye rockfish, dusky rockfish, Pacific Ocean 

perch, walleye pollock, sculpin, skates, shark, squid, weathervane 

scallop, yellowfin sole, Pacific cod, Sablefish, shortraker and rougheye 

rockfish, Chinook, chum, coho, sockeye, and pink salmon. 

By following the Standards and Guidelines in the Forest Plan and 

implementing the Best Management Practices (BMPs), the effects on 

EFH will be minimized due to the following: 

All activities at the Little Hamilton LTF will abide by State and 

Federal permit stipulations. 

The Forest Service believes that the Central Kupreanof Timber Sale 

may adversely affect EFH. However, by following the Standards and 

Guidelines in the Forest Plan and implementing the Best Management 

Practices (BMPs), the effects on EFH will be minimized. Impacts to 

Conclusions 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 139 

EFH are likely to occur only from unforeseen events. A copy of the 

DEIS was given to NMFS as stated in the agreement. 

NMFS concurred with the EFH findings and made conservation 

recommendations. The Forest Service responded to their comments 

and consultation was completed. See Appendix D for the letter from 

the NMFS and the Forest Service’s response. 

Unavoidable adverse impacts associated with this project include 

short-term increases in sediment delivery to streams from road 

construction and maintenance activities. 

This project does not propose any irreversible or irretrievable 

commitments of watershed resources. 

Unavoidable 

Adverse Impacts 

Irreversible and 

Irretrievable 

Commitments of 

Resources 
3 Environment and Effects 

140  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Timber and Vegetation 

Resource Analysis Area 

The analysis area covered by this report is the Central Kupreanof 

Project Area (VCUs 4260, 4271, 4290, 4360, and 4380) and land 

immediately adjacent to the VCUs. Silviculture responds to land 

management activities within the project boundary and is sometimes 

affected by land management activities immediately adjacent to the 

project area. 

Affected Environment 

Initial project area information was obtained from the Petersburg 

District’s Geographic Information System (GIS) library, aerial photos, 

and the Forest Service Activities Tracking System (FACTS). 

During the 2006 and 2007 field seasons, the Petersburg Ranger 

District’s Integrated Resource Inventory (IRI) Crew performed an 

inventory of the Central Kupreanof Project Area. Information 

collected contributed to the development of site specific Silvicultural 

Diagnosis, Logging Systems and Transportation Analysis by timber 

stand for the area. This analysis included stream surveys, wildlife 

information and identification of soils that have a high potential for 

mass wasting. Copies of this information are located within the 

project record. 

The Central Kupreanof Project Area is a mosaic of coniferous forests 

interspersed with muskeg, scrubland, and alpine plant communities. 

The forests are primarily western hemlock with a Sitka spruce 

component, scattered Alaska yellow-cedar and western red cedar. 

Higher percentages of Sitka spruce are found along streams and other 

well-drained sites. The understory shrubs are primarily blueberry, 

huckleberry, and rusty menziesia. Many species of vascular plants, 

lichens, and mosses occur throughout all habitat types. Forested 

muskeg with a high percentage of yellow-cedar occurs throughout the 

project area especially in the lower elevations. Alder is found on 

disturbed sites such as roadsides, managed stands and along stream 

banks. Muskegs support shore (lodgepole) pine. 

National Forest System lands are defined by vegetative cover, soil type 

and administratively designated land use. This classification scheme is 

intended to show the amount of land that is covered by forested 

vegetation with further divisions to show the amount of that land that 

is capable of timber production (Table 3-38). 

Methods 

Forest Land 

Classification 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 141 

Forested Land comprises about 94% of the National Forest Land in the 

Central Kupreanof Project Area. Forested land has at least ten percent 

of the area occupied by forest trees of any size or formerly having had 

such a tree cover and not developed for non-forest use. 

Non-Forest Land comprises about 6% of the National Forest Land in 

the Central Kupreanof Project Area. Non-forested land has fewer than 

ten percent of the area occupied by forest trees of any size, or formerly 

had such a tree cover and is now developed for non-forest use. 

Productive Forest Land comprises about 32% of the National Forest 

Land in the Central Kupreanof Project Area. Productive forest lands 

have timber volumes of greater than or equal to 8,000 board feet/acre 

or have the potential to achieve this volume and are capable of 

maintaining that volume. This land is capable of producing 20 cubic 

feet/acre/year of industrial wood per year or having a site index of 40. 

Productive Forest Land does not necessarily mean that the stand is 

within the timber base that is available for commercial timber harvest. 

Non-Productive Forest Land comprises about 68% of the National 

Forest Land in the Central Kupreanof Project Area. Non-productive 

forest land is forested land that does not support enough timber 

volume to meet the criteria for productive forest land. 

Suitable Forest Land is 73% of the productive forest land in the project 

area that is physically suitable for timber harvest, can be adequately 

restocked in five years, not withdrawn from timber production, and has 

been identified in the 2008 Forest Plan (USDA Forest Service 2008) as 

within a Land Use Designation that has timber available for timber 

management. 

Unsuitable Forest Land includes areas within riparian, beach and 

estuary buffers, land on slopes greater than 72% that have unstable 

soils (harvest is allowed on slopes exceeding 72%, but requires an onsite slope stability analysis to determine suitability), and other lands 

withdrawn from timber production by the 2008 Forest Plan (USDA 

Forest Service 2008). Approximately 27% of the unsuitable forest 

land is in the productive forest land base. 
3 Environment and Effects 

142  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-38. Land Classification Acres (National Forest Land) 

Within the Project Area 

 

National Forest System

152,517 

 

Non-forest Land

9,188 acres 

 

Forest Land 

143,329 acres

 Productive Forest 

Land 

49,121 acres 

 

Non-productive Forest Land 

94,208 acres 

 

Suitable Forest Land

35,855 acres 

 

Unsuitable Forest Land

13,266 acres 

 

Harvested Acres

4,233 acres 

Acres Harvested before 

Forest Plan designations

382 acres 

Suitable and Available for 

Harvest 

 31,622 acres

Central Kupreanof Timber 

Sale Project Area 

152,517 acres 

Non-National Forest 

Land 

0 acres 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 143 

Forest Health and Natural Disturbance 

Wind is the major natural disturbance agent affecting forest dynamics 

in Southeast Alaska. It recycles forest stands and maintains and renews 

the forest ecosystem. However, timber harvest has the potential to 

exacerbate the rate of windthrow in adjacent forest stands. The 

severity and frequency of wind disturbance is determined by many 

interrelated factors. These influencing factors include tree size and 

vitality, slope aspect, soil characteristics stand composition, canopy 

structure and the characteristics of the surrounding topography which 

may influence wind flow (Harris 1989). 

Riparian buffers have been monitored on the Tongass for the past 

seven years. “The 2006 Tongass Monitoring and Evaluation Report” 

(USDA Forest Service 2007), states that post harvest windthrow 

within 183 monitored stream buffers is highly variable and ranges 

from 0 to 73 percent. Post harvest windthrow is present in 25 percent 

of the buffers and the average and median cumulative amount of 

windthrow within these buffers is 12 percent and 6 percent 

respectively. 

Survey crews examined leave trees and unit edges of previous harvest 

units and stands within the proposed harvest units for windthrow and 

found only scattered trees. There were no large sections of windthrow 

found in the project area. The risk of significant wind disturbance as a 

result of timber harvest in the project area was determined to be low 

due to the insignificant amount of pre-existing windthrow and an 

analysis of contributing risk factors. Additional wind protection 

measures are not planned for any of the proposed harvest units. 

Alaska yellow-cedar decline is a disease causing considerable 

mortality in Southeast Alaska. Mortality can be in small patches or 

can cover expansive areas. Affected trees may die more quickly (2 or 

3 years), or more slowly over a 15-year period or longer with crowns 

progressively thinning. The cause of yellow-cedar decline is not 

completely understood but the disease generally occurs on wet poorly 

drained sites at lower and middle elevations. Recent studies theorize 

that mortality could be caused by freeze damage to fine roots (Hennon 

and Shaw). There is approximately 84,000 acres of mapped yellowcedar decline on Kupreanof Island and the majority of it occurs at 

elevations below 1,000 feet (Forest Health Protection Report 2008). 

All alternatives are consistent with current Forest Plan Standards and 

Guidelines for their respective Land Use Designations. Currently 

there is no direction to modify harvest activities based on Alaska 

yellow-cedar decline which is naturally occurring on approximately 

Wind Disturbance 

Alaska yellowcedar Decline 
3 Environment and Effects 

144  Chapter 3 Central Kupreanof Timber Harvest FEIS 

22,000 acres (Forest Health Protection Report 2008) of the project 

area. 

Table 3-4 of the FEIS displays the amount of timber volume harvested 

by species by alternative. Details are available for individual units and 

are currently stored in the Natural Resource Information System and 

are available upon request. 

On the Tongass National Forest, Alaska yellow-cedar and Western 

redcedar are found in mixed conifer stands, usually as a component of 

the more shade tolerant western hemlock type. The cedars are more 

typically found in the lower volume class strata since they cannot 

compete with Western hemlock on higher sites. By volume, Alaska 

yellow-cedar represents about 10 percent of the growing stock volume 

and is found throughout Southeast Alaska. Western redcedar 

represents about 6 percent of the growing stock volume and is limited 

to the southern half of the Tongass National Forest. 

The Central Kupreanof Timber Harvest project area encompasses 

152,517 acres and of these acres 143,329 acres are forested. Of the 

forested acres 4,233 are in existing young growth and the project area 

has been determined to contain 31,622 acres that are currently suitable 

and available for timber harvest. Alaska yellow-cedar and Western 

redcedar occurs in the areas suitable and available for timber harvest 

and also occurs on both unsuitable and non-productive forested lands, 

lands where large commercial timber sales cannot be planned. Alaska 

yellow-cedar regeneration is being found in newly regenerated units 

within the project area (regeneration stand exam records are on file at 

the Petersburg District Office) and is favored during precommercial 

thinning operations. 

Minor amounts of Western redcedar are scattered across the project 

area and some incidental trees will be harvested along with the rest of 

the stand. Some of the previously harvested units in the area have 

Western redcedar in the regeneration and it is favored during 

precommercial thinning operations. The North Hamilton River 

Redcedar Area that is approximately 80 acres in size is within the 

project area boundary in the northwestern section and is not part of the 

volume being considered for harvest. This area is identified as being 

unique because of the high proportion of redcedar it contains and the 

young growth stand adjacent to this area also has a high proportion of 

redcedar. 

Dwarf mistletoe reduces the vigor and growth rate of hemlock and 

often produces a low quality of timber. Cankerous swellings often 

occur at the point of infection on limbs and main stems. These cankers 

offer an entrance for wood-destroying fungi, which can lead to heart 

rot. 

Cedar 

Composition 

Dwarf Mistletoe 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 145 

Dwarf mistletoe progresses relatively slowly in Southeast Alaska; 

however, with stands which are partially harvested, there may be some 

infected trees. Clearcut harvesting is an effective method of 

controlling hemlock dwarf mistletoe if reduction or eradication of the 

disease is consistent with management objectives (USDA Forest 

Service, 2001). Dwarf mistletoe infestation is found in low levels 

throughout the Central Kupreanof project area. 

Wood decay fungi play an important role in the structure and function 

of coastal old-growth forests where fire and wind disturbance are 

uncommon. In addition to creating canopy gaps and wildlife habitat, 

decay fungi play an important role in nutrient cycling. The importance 

of wood decay fungi in young managed stands is less well understood. 

There is evidence of decay fungi existing at an endemic level 

throughout the project area. Approximately one third of the oldgrowth timber volume is defective in Southeast Alaska old-growth 

stands (Forest Health Protection Report 2008). Although decay 

develops slowly, the longevity of individual trees allows ample time 

for significant amount of decay to develop. 

Reference Condition 

Prior to 1954 no large scale timber harvest had occurred in the project 

area. 

Existing Condition 

The first timber harvest occurred within the Central Kupreanof Timber 

Harvest Project Area in 1967 on a beach unit on the west side of 

Duncan Canal. Large-scale industrial logging began in the project 

area in the 1970s and introduced the area to road construction. During 

the 1970s until the early 1980s timber harvest in the project area was 

used to supply the long-term contract held by Alaska Pulp 

Corporation. From the early 1980s until the present, timber in the 

project area has been sold as independent timber sales. 

Decay Fungi 

Past Timber 

Harvest 
3 Environment and Effects 

146  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-39. Acres of Suitable and Non-suitable Timber 

Harvested in the Central Kupreanof Timber Harvest 

Project Area by Decade 

Harvest 

Period 

Suitable Acres 

Harvested 

Non-suitable Acres 

Harvested 

1960-1969 0 54 

1970-1979 620 40 

1980-1989 1,781 83 

1990-1999 861 153 

2000-present 971 55 

TOTAL 4,233 382 

Note: The numbers in Table 3-39 are from the Petersburg GIS library and differ 

from the catalog of past NEPA events by 11 acres due to rounding. 

Volume Strata 

A volume strata was used for estimating the timber volumes and 

providing correlations for determining vegetation structure on the 

Central Kupreanof Project Area. This volume strata combines the 

existing timber inventory with additional information on soils and 

slope to group the strata. These volume strata are grouped as follows: 

 High Volume Stratum. Areas within mapped timber inventory 

volume classes 5, 6, and 7 on non-hydric soils, and on hydric 

soils with slopes greater than 55 percent. 

 Medium Volume Stratum. Areas within mapped timber 

inventory volume classes 5, 6, and 7 on hydric soils with slopes 

less than or equal to 55 percent and areas within 

mapped timber inventory volume class 4 that are either on nonhydric soils, or are on hydric soils with slopes greater than 55 

percent. 

 Low Volume Stratum. Areas within mapped timber inventory 

volume class 4 on hydric soils with slopes less than or equal to 

55 percent. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 147 

Table 3-40. Volume Strata on Suitable Forest Acres in the 

Central Kupreanof Project Area 

Strata Suitable Forest Acres

Low 4,762 

Medium 14,308 

High 16,354 

Non Volume Strata 431 

Total 35,855 

Silvicultural Systems 

Silvicultural systems are used to manage, harvest, and re-establish 

stands of forest trees for the purpose of meeting defined objectives. 

Silvicultural prescriptions have been developed to produce more 

valuable commercial timber at a faster rate, maintain wildlife habitat, 

and either maintain or enhance scenery values. No single silvicultural 

system for a forest stand can be used to achieve all the desired 

combinations of amenities and products. Instead a variety of 

treatments applied over the Central Kupreanof Timber Harvest project 

area results in a mosaic of stands of different structures. By harvest of 

timber or other treatments such as thinning or pruning, the existing 

stands would be altered by proposed management actions. 

The 2008 Forest Plan (Timber Standards and Guidelines) and USDA 

Forest Service Manual 2400 (Timber Management) provides detailed 

information about the silvicultural systems recommended for the 

Tongass National Forest. Two-aged management will result in a 

seedling stand with varying levels of older-aged residual trees. 

Uneven-aged management will result in a stand with younger trees 

interspersed with older trees, either in clumps or distributed across the 

stand. Even-aged management will result in the conversion of mature 

stands to faster growing stands of a single age. The post-harvest 

conditions of the forest stand for all systems will be dependent upon 

the existing plant community, the retained canopy structure, and 

advanced regeneration. Species composition will be monitored to 

ensure that the mix of species is roughly the same as on the existing 

site. 
3 Environment and Effects 

148  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The Central Kupreanof Timber Harvest project area analysis used a 

variety of silvicultural systems tailored to site-specific objectives. The 

objectives include: 

 retaining stand structure to maintain biodiversity 

 economics and logging feasibility 

 protection of the soil, watershed, wildlife habitat, and scenery 

characteristics of the project area 

 production of wood-fiber for future human use 

A complete silvicultural prescription for the entire length of the 

rotation will be written for each stand selected for harvest. These 

prescriptions provide guidance for treatments following the proposed 

timber harvest for this project, including subsequent entries, thinning, 

and pruning. Table 3-41 shows acres by silviculture system and 

regeneration method for each alternative. 

All or the majority of the merchantable trees will be harvested leaving 

10 percent or less of the original stand’s basal area. The objectives of 

this system are to create a fast-growing stand of trees to maximize 

wood fiber production, improve timber sale harvest economics and 

logging feasibility. These stands would regenerate into a mostly 

single-aged stand. Where this treatment is recommended, it has been 

determined that it is optimal for the site and the created openings 

would not exceed 100 acres. The regeneration method chosen to 

achieve the goals of this system is clearcutting. 

Clearcutting- The cutting of all or the majority of the trees leaving 10 

percent or less of the original stand’s basal area in one harvest entry, 

producing a fully exposed microsite for the development of a new age 

class. 

Reason for clearcutting – The Forest Plan (p. 4-71) directs the use of 

clearcutting where such a practice is determined to be the best system 

to meet the objectives and requirements of the Land Use Designation 

(LUD). Even-aged management, clearcutting, in the Timber 

Production LUD is a way to increase commercial timber productivity 

of the site. Forest Service Manual (FSM) 2470-R-10-2400-2005-1 

further clarifies limitations on clearcutting and states it may be used to 

minimize the occurrence of diseases (dwarf mistletoe), windthrow, 

logging damage, and to provide for the establishment and growth of 

desired trees. Even-aged management has not been prescribed where 

it conflicts with other resources. 

Even-aged 

System 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 149 

This system is designed to maintain and regenerate a stand with twoage classes. The resulting stand may be two-aged or tend towards the 

uneven-aged condition as a consequence of both an extended period of 

regeneration establishment and the retention of reserve trees that may 

represent one or more age classes. This remaining structure provides 

wildlife habitat and reduces visual impacts. These stands will not be 

reentered until the next rotation in approximately 100 years. The 

regeneration method chosen to achieve the goals of this system is 

clearcutting with reserves. 

Clearcutting with reserves – Stands proposed for this system would 

have a minimum of 50 percent of the basal area of the stand remaining 

after harvest. Merchantable trees (trees greater than 9 inches in 

diameter) would be harvested in patches or individually. This will 

create a stand of two or more distinct age (size) classes. 

Reasons for clearcutting with reserves – This system will provide 

foraging areas interspersed with cover. The large trees provide habitat 

for cavity nesters. The appearance of the residual stand mimics natural 

blowdown patches and single trees. Damage to leave trees and lower 

commercial stand productivity are acceptable resource tradeoffs to 

achieve these goals. 

This system regenerates and maintains a multi-aged structure by 

removing some trees in all size classes either singly, in small groups, 

or in strips. The objective of uneven-aged management is to maintain 

a stand with trees of three or more distinct age (size) classes, either 

intimately mixed or in small groups. This remaining structure 

provides wildlife habitat and reduces visual impacts. The next entry 

into these stands will be in approximately 75 years when 30 percent of 

the stands basal area will be removed in patches or in single trees. The 

regeneration method chosen to achieve the goals of this system is 

single tree selection. 

Single tree selection – Stands proposed for this system would have a 

minimum of 60 percent of the basal area of the trees remaining after 

harvest. This will regenerate and maintain a multi-aged structure by 

removing some trees in various size classes distributed across the 

stand. Trees to be harvested would be selected by species and 

diameter limit. A range of diameters generally between 16” and 36” 

DBH (diameter at breast height) is used to define the trees selected for 

harvest. Exact harvest diameter limits are based on a timber cruise 

preformed prior to the actual sale of the harvest units. The resulting 

stand may have small openings plus individual trees harvested 

throughout the stand. This will maintain or create a stand of three or 

Two-aged System 

Uneven-aged 

System 
3 Environment and Effects 

150  Chapter 3 Central Kupreanof Timber Harvest FEIS 

more distinct size classes distributed throughout the stand, resulting in 

an uneven-aged stand. 

Reasons for single tree selection – Removing trees throughout the 

stand would retain a continuous large tree canopy following harvest. 

The residual stand would have structural diversity that would provide 

wildlife habitat and maintain scenic quality. When these stands are 

harvested with conventional cable logging systems damage to the 

residual trees and lower commercial stand productivity are acceptable 

resource tradeoffs to achieve these goals. 

Table 3-41. Acres of Silviculture System and Regeneration 

Method Chosen for the Central Kupreanof Units by 

Alternative 

Regeneration 

System 

Basal Area 

Retention Alt. 2 Alt. 3 Alt. 4 

Even-aged Management Silviculture System 

Clearcut 

None 1,915 3,011 1,288 

10% 116 116 39 

Total Acres of Even-aged 

Management 2,031 3,127 1,327 

Two-aged Management Silviculture System 

Clearcut 

with 

Reserves 

50% 33 0 0 

Total Acres of Two-aged 

Management 33 0 0 

Uneven-aged Management Silviculture System 

Single-tree 

Selection 60% 442 520 0 

Total Acres of Unevenaged Management 442 520 0 

Total Acres of Harvest by all Silviculture Systems 

Total Acres of Harvest by 

Alternative 2,506 3,647 1,327 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 151 

Intermediate Treatments 

Following timber harvest, the managed forest goes through distinctive 

developmental stages. Removal of the forest overstory alters the 

microsite conditions that influence density and species composition of 

the understory vegetation. Natural regeneration is used to restock the 

harvest units; areas must be reforested with a minimum of 300 trees 

per acre by the fifth year following harvest. This is monitored with 

regeneration surveys and certification of successful reforestation. 

Different components dominate the stand at different stages, and the 

overall forest structure will change as the new stand develops. The 

level of change will depend on the type of silvicultural treatment 

applied during harvest and subsequent treatments applied during stand 

development. Characteristics such as tree height, diameter, and overall 

stand productivity will vary according to site class. However, younggrowth stands commonly show less variability in tree diameter and 

height than the old-growth stands they are replacing. Young-growth 

timber has a stand size ranging from seed-saplings, pole-timber, up to 

saw-timber. It is usually the result of clearcut harvest. Currently, 

about 13 percent of the suitable forestland in the Central Kupreanof 

Project Area is young-growth timber. Management of these harvested 

acres will improve stand conditions for future timber production and 

increase forage for deer and moose. Young-growth stands are 

candidates for thinning and pruning. 

Following timber harvest, natural regeneration often results in stands 

with too many trees per acre, reducing individual tree growth and 

shading out understory vegetation that may be valuable to some 

wildlife species. Thinning is designed to improve future tree growth 

by reducing stand density, thus reducing the competition between trees 

for sunlight. Increased sunlight as a result of thinning also allows for 

greater shrub and forb growth, thereby increasing wildlife forage. 

In older harvested stands (35 to 45 years or older), as the canopy 

progressively closes and sunlight is virtually absent, the understory 

vegetation becomes suppressed. In general if stands are not thinned by 

the age of 40 years, the thinning slash is extremely thick due to the 

size of the cut trees (some as large as 6 inches in diameter and 30 feet 

in height). The slash does not come into contact with the ground, and 

decomposes slowly. Consequently, sunlight would still be limited due 

to the accumulation of thinning slash, and germination of forage 

species would be limited for an extended period of time. 

Conversely, it is too early to thin when canopy cover is relatively 

sparse with many open spaces between trees. At this stage, there is 

probably abundant forage, and thinning would probably not provide 

much more forage. In addition, new hemlock regeneration could 

Thinning 
3 Environment and Effects 

152  Chapter 3 Central Kupreanof Timber Harvest FEIS 

become established after the thinning and suppress some release of the 

forage. When thinned too early, trees have not expressed dominance, 

making it difficult to select which trees to cut while thinning. 

The first thinning program for harvested stands in the Central 

Kupreanof Project Area began in 1987, when stands were 

approximately 10 to 15 years old. Currently stand thinning is 

prescribed at 25 – 30 years of age. Since 1986, stands have been 

periodically surveyed to determine the need for thinning. 

Approximately 1,110 acres of the 4,616 acres (this includes historical 

harvest that took place on land not classified as suitable) that have 

been harvested on all lands in the Central Kupreanof Project Area have 

been thinned to date. The remaining unthinned acres are not eligible 

for thinning at this time because the stands are either too young for 

thinning to be effective or between tree competition has not yet 

developed enough to warrant thinning, due to site conditions. 

It is not known if thinning will have an application in uneven-aged 

stands resulting from partial harvest. Stocking surveys and additional 

analysis will be done as these stands develop. 

As a harvested stand develops to the point where the trees are too large 

to thin and the understory is stressed but able to be released, pruning 

may be considered. It may provide enough indirect sunlight 

penetration through the canopy to maintain the understory vegetation 

for wildlife forage. Pruning also increases the value of each tree, by 

providing knot-free wood as the tree grows. Pruning will allow the 

maximum volume to be produced in the stand while still maintaining 

the vegetative understory. 

Effects of Alternatives and Environmental 

Consequences 

The structure of the forest will be affected by timber harvest. The 

effects will vary by the silvicultural prescription and the number of 

acres harvested. Removal of trees in patches will result in small 

openings that will regenerate to second-growth forest. Removal of 

trees dispersed throughout the stand will result in older trees 

interspersed with the regeneration of young trees. Clearcut harvest 

will result in the creation of primarily second-growth stands with or 

without older residual trees. Forest health concerns, including the 

removal of trees with disease or that face imminent mortality, can be 

used as factors determining which trees to harvest. The removal of 

trees that are dead or in poor health from the effects of Alaska yellowcedar decline, dwarf mistletoe or other diseases can improve the health 

and vigor of stands. Some minor windthrow will likely occur in and 

around harvested stands. 

Pruning 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 153 

Current levels of timber harvest on the Tongass are not expected to 

have an adverse affect on the quantity or composition of cedar (or any 

species) in the future. Where single tree selection or two-aged 

management is applied, the amount of residual cedar left is 

proportional to the amount prior to harvest. Since both cedars are 

shade intolerant, removal of a portion of the overstory could release 

cedar if advanced regeneration is present. Silvicultural treatments in 

young growth stands, such as precommercial thinning, pruning, and 

commercial thinning, favor the release of cedars to maintain cedar 

species composition and because they are valuable crop trees for future 

harvest. 

Currently there are approximately 325 acres of precommercial 

thinning to accomplish in young growth stands that could potentially 

be done under a stewardship contract on the Kake road system. These 

stands are approximately 25 years old and an individual prescription 

will be written for each stand to identify species and spacing of the 

leave trees to improve future tree growth and increase sunlight to the 

forest floor and in turn increasing wildlife forage production. Other 

proposed projects should have no effect on the vegetation resource on 

the suitable forest acres within the project area. 

The implementation of a Microsale program would have no significant 

effect on Silviculture. 

Vegetation and forest health would not be affected by management 

activities. Tree growth and mortality would continue to progress 

naturally. Other forestlands with land use designations that allow 

timber harvest would be needed to meet the objective of providing 

timber for public consumption to meet market demand. 

In this alternative, 2,031 acres would be converted to even-aged 

management. Forest health and commercial productivity would be 

improved by the removal of dwarf mistletoe-infected trees, trees 

infected by disease, and by creating younger, faster-growing forests. 

Two-aged management will be prescribed on 33 acres in this 

alternative in Unit 315. A minimum of 50 percent of the basal area 

will be retained in patches or individual trees generally located along 

boundaries and setting breaks. This will create a stand of two or more 

distinct age (size) classes, and provide a wildlife travel corridor 

through the unit. 

An additional 442 acres would be managed with an uneven-aged 

system by removing up to 40 percent of the basal area in individual 

trees dispersed throughout the stand. This would improve helicopter 

yarding economics, and retain some of the old-growth characteristics 

of the forest (older trees, wider variation in tree sizes and spacing, 

Projects Common 

to all Action 

Alternatives 

Alternative 1 

Alternative 2 
3 Environment and Effects 

154  Chapter 3 Central Kupreanof Timber Harvest FEIS 

decadent trees, multiple canopy layers), but result in a forest with 

lower net commercial volume. 

In this alternative, 3,127 acres would be converted to even-aged 

management. Forest health and commercial productivity would be 

improved by the removal of dwarf mistletoe-infected trees, trees 

infected by disease, and by creating younger, faster-growing forests. 

An additional 520 acres would be managed in an uneven-aged system 

by removing up to 40 percent of the basal area in individual trees 

dispersed throughout the stand. This would retain some of the oldgrowth characteristics of the forest (older trees, wider variation in tree 

sizes and spacing, decadent trees, multiple canopy layers), but result in 

a forest with lower net commercial volume. 

In this alternative, 1,327 acres would be converted to even-aged 

management. Forest health and commercial productivity would be 

improved by the removal of dwarf mistletoe-infected trees, trees 

infected by disease, and by creating younger, faster-growing forests. 

Alternative 3 

Alternative 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 155 

Table 3-42. Previous and Proposed Timber Harvest for Each 

Alternative 

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

Proposed Timber Harvest for this Project and Cumulative Effects 

Acres of 

harvest 

units 

proposed 

for this 

project 

Even-aged 

Management 0 2,031 3,127 1,327 

Two-aged 

Management 0 33 0 0 

Uneven-aged 

Management 0 442 520 0 

Effects on Suitable Forest Land 

Acres of Suitable Forest 

31,622 31,622 31,622 31,622 

Acres of Previous 

Harvest on Suitable 

Forest 

4,233 4,233 4,233 4,233 

% of Suitable Forest 

Acres Proposed for this 

Project 

0 8 12 4 

Cumulative % of Suitable 

Forest Acres Managed 13 21 25 17 
3 Environment and Effects 

156  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Cumulative Effects 

The catalog of past events documents a conversion of 4,622 acres from 

old-growth forest to second-growth forest within the Central 

Kupreanof Project Area and approximately 4,233 acres of these lands 

are on forested land within the suitable timber base. Forest-wide, 

existing second-growth forest within the suitable timber base has been 

scheduled as part of the timber supply. Thinning of second-growth or 

conversion to uneven-aged management may occur. All of the 

proposed harvest units that have an uneven-aged management 

prescription have subsequent entries planned. The Central Kupreanof 

EIS is the only EIS on the current five-year timber sale plan for VCUs 

4260, 4271, 4290, 4360, and 4380. 

Since 1910 there has been approximately 41,511 acres of timber 

harvested on National Forest and Private Lands on Kupreanof Island. 

The Tongass Five Year Sale Plan shows a potential for two additional 

planned EISs on Kupreanof Island. One EIS is planned for the 

Lindenberg Peninsula and the other is planned for the Bohemia 

Mountain area. 

The recommendation from the ATM EA includes road closures. The 

road segment that is recommended for decommissioning will return to 

natural vegetation over time. These recommendations will are 

analyzed in the District’s ATM EA. 

Past Timber 

Harvest within the 

Study Area 

Past and Future 

Timber Harvest 

on Kupreanof 

Island 

Access and 

Travel 

Management 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 157 

Soils and Geology 

Introduction 

Soils form the foundation of the forest ecosystem and have evolved 

with the climate and vegetation. The integrity and stability of a soil 

determine the long-term productivity of the vegetation. The region’s 

cool growing season and abundant rainfall greatly influence soil 

characteristics. Under these conditions, organic material decomposes 

slowly and tends to accumulate. Soils are formed in either mineral 

materials (sand, silt, and clay) or organic material (decayed plant 

materials). 

The parent material on Kupreanof Island is largely dominated by 

basaltic and andesitic volcanic materials. Rocks identified include 

breccia, tuff, rhyolite, minor carbonates, and also include 

metamorphosed rocks such as gneiss, greenstone, and greenschist 

(Nowacki et al. 2001). 

The Bureau of Land Management’s mining claim report documents 

many prospects and claims identified on Kupreanof Island. The project 

area has four known prospects or lode sites: an area east of Big John 

Bay, an area south of Kupreanof Mountain, Taylor Creek and Upper 

Taylor Creek, and Indian Point. Within these areas minor amounts of 

precious and base metals have been identified. Included are low levels 

of gold, silver, lead, mercury, pyrite, copper, molybdenum, nickel, 

cobalt, and zinc (Still et al. 2002). 

Using the USFS GIS database 2,685 acres of karst have been identified 

on Kupreanof Island. Ten percent (279 acres) of those acres exist 

within the project area. Twelve acres occur in three proposed units 

(309, 310, and 312). Field reconnaissance found no signs of karst 

features (sink holes or caves) in these units; therefore these karst areas 

are classified as low vulnerability and require no special management 

(Forest Plan 2008, Standards and Guidelines, pg 4-23). 

In Southeast Alaska, where sunlight is often limited and temperatures 

are cool, it is not uncommon for 250 years to elapse before a weak soil 

horizon forms (Krosse 1993, pg 39). 

Four soil orders exist in the project area: histosols, spodosols, 

inceptisols, and entisols. Histosols dominate, covering over half of 

the project area. Spodosols account for a third of the area, leaving a 

fraction identified as inceptisols and entisols. 

Histosols are organic soils that are typically poorly drained. Many 

histosols fall within the wetland category. Although these soils 

Geology 

Minerals 

Karst 

Soil 
3 Environment and Effects 

158  Chapter 3 Central Kupreanof Timber Harvest FEIS 

contain deep organics and nutrients, timber productivity is generally 

low due to poor drainage and anaerobic conditions (Cowardin et al. 

1992). 

From a resource management perspective, soil productivity (i.e., a 

soil’s ability to support vegetative growth) and the potential loss of 

soils or off-site effects from erosion and landslides are the principle 

concerns. The productivity of soils directly or indirectly affects the 

productivity of other forest resources. Tree growth, wildlife and fish 

habitat quality, and recreation uses and potentials depend in part on the 

quality of soils. In Southeast Alaska, soil productivity, in terms of tree 

growth, is high on well-drained soils (e.g., on steep slopes and in karst 

areas) and decreases as latitude and elevation increase and as drainage 

becomes poorer. 

In this project area the most productive sites are associated with 

mineral soils (spodosols, entisols and inceptisols) found on welldrained floodplains. They are also located where slope gradients are 

above 35 percent in the mid and southern sections of the project area. 

Soil disturbance is an unavoidable consequence of timber harvest and 

road construction. The level of disturbance varies with management 

practices and site characteristics. 

Surface erosion occurs when soil is detached and transported by water. 

Most undisturbed soils in the project area are resistant to surface 

erosion due to a relatively thick, organic surface layer, which absorbs 

large quantities of water and protects the soil from displacement. If 

this layer is removed, the underlying soil may be subject to erosion. 

Where vegetation management is proposed in the project area, the 

soils are relatively rich in organic matter and carbon. These are not 

soils at risk of losing productivity through biomass removal. 

Erosion can occur on a minute scale (raindrop splash erosion) or on a 

large scale (mass movement) such as a landslide. The type of yarding 

equipment used will influence the erosion potential. Helicopteryarding causes the least amount of disturbance to the soil surface. 

Shovel-yarding usually does not disturb the soil surface if slash is used 

under the tracks of the machine. Cable-yarding may expose some 

mineral soil where trees are partially suspended, but the effects are 

minimized through log suspension requirements and the application of 

BMP 13.9. 

Mass movement is the dominant process of natural erosion and slope 

reduction in Southeast Alaska (Swanston 1969). Mass movement 

occurs where the topography is steep and the soil materials are 

weakened to the point that they can no longer resist the downslope 

component of gravity. In Southeast Alaska, areas of natural mass 

Soil productivity 

Soil Disturbance 

Mass Movement 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 159 

wasting are associated with steep slopes within narrow V-notch 

tributary drainages and the steep, upper sideslopes of U-shaped 

valleys. 

A slope’s stability is influenced by soil strength, soil depth, 

groundwater accumulation, slope gradient, and vegetation 

characteristics. Visible field indicators of unstable soils include slide 

scarps, jack-strawed trees, and a distinct change to relatively young 

plants or pioneer species. 

Mass movement indices (MMIs) have been assigned to each soil 

mapping unit in the project area according to the relative potential for 

mass movement. The indices are based primarily on slope, but other 

factors such as drainage, bedrock characteristics, soil characteristics, 

existing landslides, and vegetation are also considered. Very high 

hazard soils are subject to additional investigation prior to or during 

the sale preparation. Identified unstable soils are avoided during sale 

preparation. Table 3-43 displays acres of proposed harvest by soil 

mass movement index for each alternative. 

At the Forest Plan level, slope gradients of 72 percent or more are 

removed from the tentatively suitable timber base due to high risk of 

soil mass movement. At the project planning level, the Forest 

Supervisor or District Ranger may approve timber harvest on slopes 

greater than 72 percent or more on a case-by-case basis. Their decision 

is based on the results of a Soil Stability Investigation Report, an onsite analysis of slope stability and an assessment of potential impacts 

of accelerated erosion on downslope and downstream fish habitat. 

To meet Forest Plan requirements, Soil Stability Investigation Reports 

for proposed harvest units with slopes greater than 72 percent have 

been completed and are filed in the project record. As a result of these 

investigations, two unit boundaries were adjusted (Units 6 and 502), 

full suspension was recommended for one proposed timber harvest 

unit (Unit 261), a minimum of partial suspension was recommended 

for three proposed timber harvest units (Units 5, 900 and 901) and 

road locations in or adjacent to four proposed timber harvest units 

were modified (Units 233, 234, 275 and 276). Other field 

investigations resulted in the modification of eleven additional unit 

boundaries (Units 219, 229, 230, 231, 235, 246, 263, 264, 266, 285 

and 286), the modification of seven additional proposed road locations 

(Units 243, 246, 260, 263, 264, 268, and 280), recommendations for 

no road construction in two proposed harvest units (216 and 217), 

additional management recommendations for proposed units that have 

evidence of landslides (217 and 277) and a specification of 

silvicultural prescription or yarding method to protect soils in twelve 

units (207, 216, 217, 219, 231, 235, 249, 260, 261, 265, 266 and 285). 
3 Environment and Effects 

160  Chapter 3 Central Kupreanof Timber Harvest FEIS 

These changes were made to address slope stability, the presence of 

landslides and access concerns. 

Table 3-43. Acres1 of MMI in Proposed Units by Alternative 

MMI Class Alt. 1 Alt. 2 Alt. 3 Alt. 4 

1– Low 0 764 1,295 631 

2 – Moderate 0 1,288 1,701 577 

3 – High 0 442 634 119 

4 – Very High2 0 10 17 0 

Total Acres 0 2,504 3,647 1,327 

1 Variations in acres are the result of rounding. 

 2 Soil stability analyses determined these soils to be stable. 

Landslides 

In the project area 16 landslides were identified using the USFS GIS 

landslide database. The slides identified occupy 0.03 percent (42 

acres) of the project area and are inventoried as having occurred 

between 1960 and 1995. Fourteen of the slides are not associated with 

timber harvest and occurred on all MMIs. The two slides that did 

occur after a harvest are smaller in size (traveling less distance) and on 

lower gradients than the naturally induced slides (less than 52 percent 

gradient) (Table 3-44). 

Most landslides occur during or after heavy rainfall when soils become 

saturated (Swanston 1995). The areas typically considered hazardous 

or most prone to landslides are those with steep slopes and soils with 

distinct slip-planes, such as when compacted glacial till or bedrock are 

sloping parallel to the surface (Rib and Liang 1978). During heavy 

rainfall these areas can fail, especially if previously disturbed by 

blasting for rock pits, road pioneering, side casting of excavated 

material, or ground-based logging. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 161 

Table 3-44. Comparison of Landslides within the Central 

Kupreanof Project Area that are associated with 

Harvested Areas and those that Occurred Naturally 

Number 

of 

Slides 

Total 

Acres 

from 

Slides 

Average 

Acres 

per 

Slide 

For the 

Central 

Kupreanof 

Project Area

Harvest associated 

slides 2 1.4 0.7 Natural 

slides are 4.1 

times larger 

than those 

associated 

with 

harvests. 

Natural slides 

(non-harvest) areas 14 40.9 2.9 

Soil quality standards are a means to quantify detrimental soil 

conditions which in turn have long-term effects on soil productivity. 

The Forest Service Manual states that the total acreage of all 

detrimental soil conditions should not exceed 15 percent of an activity 

area (FSM 2554). The activity area for this analysis includes the 

proposed harvest units. 

The number of acres disturbed by timber harvest is estimated at three 

percent of the total acres harvested where partial suspension or shovel 

yarding was used (Landwehr and Nowacki 1999). Disturbance due to 

temporary roads is based on a 40-foot road corridor (to account for 

both cutslope and fillslope) and is equivalent to 4.85 acres per mile of 

road. Soil disturbances associated with system (NFS) road 

construction are not considered part of the productive land base and 

therefore are not included in the calculation of detrimental soil 

conditions (Soil Quality Standards). 

Harvest has occurred on three percent of the project area (4,615 acres). 

Assuming that the soil on three percent of these acres is disturbed due 

to previous harvest, approximately 139 acres of disturbed soils exist in 

the project area. 

Resource Analysis Area 

The proposed harvest units are the spatial analysis area used to analyze 

direct and indirect effects on soil. The project area (VCUs 426, 427.1, 

429, 436, and 438) is the spatial analysis area used to analyze 

cumulative effects. 

Soil Quality 

Standards 
3 Environment and Effects 

162  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The unit of measure used to assess direct, indirect and cumulative 

effects to the soil resource is acres of long-term soil disturbance. Soil 

disturbance may be a result of timber harvest, temporary road 

construction, mass movement or landslides. 

To summarize, effects are estimated based on the following measures: 

 Estimated acres of detrimental soil conditions in harvest units 

due to temporary road construction and yarding activities, 

 Acres of timber harvest on slopes over 72 percent, acres of 

timber harvest by MMI Class and an estimate of future 

landslides acres as a result of management activities, and 

 Cumulative acres of soil removed from productivity by roads, 

detrimental soil conditions within harvest units, and landslides. 

Direct and Indirect Effects 

Soil productivity would decrease due to construction of roads because 

land is taken “out of production” (i.e., removed, covered over, or 

compacted). Erosion would increase from the construction of roads 

because of the destabilizing effect of cuts, fills, and drainage 

alterations, and the lack of protective vegetation cover on road 

surfaces and other disturbed areas. However, the area of detrimental 

soil disturbance from new temporary road construction within the 

proposed units (16.1 acres) and timber harvest (109 acres) is estimated 

to be three percent of the harvest unit acres - well below the 15 percent 

standard (FSM 2554).1 

Rock quarries, similar to system roads, are part of the long-term 

infrastructure and are not considered detrimental soil disturbances. 

However, it is recognized that any new rock quarries developed or 

expanded to support new construction and road maintenance will 

result in an irretrievable loss of soil resources. The area footprint 

created by existing quarry expansion, or the development of a new 

quarry, will not exceed 5 acres. 

The short-term risk of erosion and loss of soil productivity associated 

with temporary road construction and logging would be minimized in 

all alternatives by avoiding unstable slopes and implementing best 

management practices. These practices include: (1) logging system 

 

1

 This is assuming that the alternative proposing the most road construction and 

harvest is selected (Alternative 3) and 3,647 acres are harvested using partial 

suspension or shovel yarding. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 163 

designs specific to each unit to minimize soil disturbance and (2) 

intensive timber sale contract administration to ensure compliance. 

Table 3-45. Estimated Acres of Detrimental Soil Conditions 

within the Proposed Harvest Units as a result of 

Project Implementation 

Soil disturbance 

activity Alt 1 Alt 2 Alt 3 Alt 4 

Ground yarding1 0 75 109 40 

Proposed temporary 

road construction 2 0 13.8 16.1 8.6 

Estimated acres of 

landslides3 0 28 38.5 14 

Total acres of new 

detrimental soil 

conditions 

0 116.8 163.6 62.6 

1

 Estimated disturbance acres from ground yarding are calculated by multiplying 

total harvest acres by 3 percent (Landwehr and Nowacki 1999). 

2

 Estimated disturbance acres from temporary road construction is calculated by 

multiplying proposed temporary miles by 4.85 (to account for a 40-foot road corridor 

including cutslope and fillslope). 

3

Landslide totals are an estimate for the next 35 years. 

All alternatives exceed Forest Plan Soil Standards and Guidelines. In 

other words, greater than 85 percent of the harvest units and the 

project area would be left in a condition of acceptable productivity 

potential for trees and other managed vegetation following harvest 

activities. 

Table 3-46. Miles of Proposed NFS and Temporary Road by 

Alternative and MMI Class within the Central 

Kupreanof Project Area 

MMI Class Alt. 1 Alt. 2 Alt. 3 Alt. 4 

1 – Low 0 4.6 11.9 1.5 

2 - Moderate 0 5.6 13.8 0.7 

3 – High 0 1.5 5.3 0.1 

4 – Very high1 0 0 0.2 0 

1 Soil stability analyses determined these soils to be stable. 
3 Environment and Effects 

164  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Under Alternative 1 no timber harvest or road building would take 

place and no soil disturbances would result from new management 

activities. Landslides would continue to occur in unharvested areas and 

existing harvested areas. Vegetation in harvested areas would continue 

to grow and increase soil stability on those sites. Detrimental soil 

conditions would remain within Region 10 Soil Quality Standards. 

Of the three action alternatives, this alternative would have the second 

greatest effect to soil productivity. 

The total area of detrimental soil disturbance within the proposed 

harvest units would be approximately 117 acres due to timber harvest, 

temporary road construction and landslides that result from timber 

harvest activities (Table 3-45). All harvest units would meet Region 10 

Soil Quality Standards. 

Approximately 10 acres of harvest is proposed on very high hazard 

soils in Unit 901 (Table 3-43). A slope stability investigation found 

these acres within the unit boundary to be stable. Helicopter yarding is 

proposed on these soils. 

No temporary road construction is proposed on MMI-4 soils and 1.5 

miles are proposed on MMI-3 soils (Table 3-46). 

Of the three action alternatives, this alternative would have the greatest 

effect to soil productivity. 

The total area of detrimental soil disturbance would be about 164 acres 

due to timber harvest, temporary road construction and landslides that 

result from timber harvest activities (Table 3-45). All harvest units 

would meet Region 10 Soil Quality Standards. 

Approximately 17 acres of timber harvest is proposed on very high 

hazard soils in Units 261 and 901. Slope stability investigations found 

these acres within the unit boundaries to be stable. Helicopter yarding 

is proposed on these soils. 

Approximately 0.2 mile of temporary road construction is proposed on 

MMI-4 soils and 5.3 miles are proposed on MMI-3 soils (Table 3-46). 

Of the three action alternatives, this alternative would have the least 

effect to soil productivity. 

The total area of detrimental soil disturbance would be about 63 acres 

due to timber harvest, temporary road construction and landslides that 

result from timber harvest activities (Table 3-45). All harvest units 

would meet Region 10 Soil Quality Standards. 

Alternative 1 

Alternative 2 

Alternative 3 

Alternative 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 165 

No harvest or temporary roads are proposed on MMI-4 soils in this 

alternative. One-tenth of a mile of temporary road is proposed on 

MMI-3 soils (Table 3-46). 

Cumulative Effects 

The cumulative effects analysis area for soils is the project area. The 

Catalog of Events for Kupreanof Island (a list of projects by year and 

VCU that have been implemented on Kupreanof Island) was a tool 

used for this analysis (Appendix C). Cumulative effects of the 

proposed actions on long-term soil productivity are directly related to 

the amount of soil disturbance that occurs through time as a result of 

natural events, temporary road construction, and resource 

management. 

Detrimental soil disturbance incurred from past management activities 

(temporary road construction and timber harvest) and natural events 

(landslides) cover approximately 253 acres or less than one percent of 

the project area. Existing NFS roads have disturbed about 310 acres of 

soil, also less than one percent of the project area (Table 3-47). 

Alternative 1 

Alternative 1 proposes no new timber harvest or construction of roads. 

No additional acres of detrimental soil are expected to result from the 

implementation of reasonably foreseeable future actions. The project 

area meets R10 Soil Quality Standards (FSM 2554.03-10). 

Based on landslide rates from Swanston and Marion (1991), landslide 

disturbance would continue at an estimated rate of 1.2 acres/year, 

totaling 42.3 acres, over a 35-year period in the project area (Table 3-

47). Vegetation in previously harvested areas would continue to grow 

and add root mass and stability to the soil, thus landslide frequency 

would likely decline over time in the harvested areas (Brardinoni et al. 

2002). 

In addition to the impacts described for Alternative 1, the 

implementation of Alternative 2 would include the effects described in 

the Direct and Indirect Effects section. Cumulative detrimental soil 

conditions from all past, present and future activities would be about 

386 acres (detrimental soil conditions for Alternative 2 plus the 

existing condition) (Table 3-47). All harvest units and the project area 

would meet R10 Soil Quality Standards as proposed. 

Based on landslide rates from Swanston and Marion (1991) landslide 

disturbance in the harvested areas would occur at an estimated rate of 

0.02 acre/year, totaling about 0.8 acres over a 35-year period. For the 

entire project area landslide disturbance is estimated at 1.22 acres/year 

and 43.1 acres over a 35-year period. 

Existing 

Condition 

Alternative 2 
3 Environment and Effects 

166  Chapter 3 Central Kupreanof Timber Harvest FEIS 

In addition to the impacts described for Alternative 1, the 

implementation of Alternative 3 would include the effects described in 

the Direct and Indirect Effects section. Cumulative detrimental soil 

conditions from all past, present and future activities would be about 

430 acres (detrimental soil conditions for Alterative 3 plus the existing 

condition) (Table 3-47). All harvest units and the project area would 

meet R10 Soil Quality Standards as proposed. 

Based on Landslide rates from Swanston and Marion (1991) landslide 

disturbance in the proposed harvest areas would occur at an estimated 

rate of 0.03 acre/year, totaling about 1.1 acres over a 35-year period 

cumulatively landslide disturbance for the entire project area is 

estimated at 1.23 acres/year and 43.4 acres over a 35-year period. 

In addition to the impacts described for Alternative 1, the 

implementation of Alternative 4 would include the effects described in 

the Direct and Indirect Effects section. Cumulative detrimental soil 

conditions from all past, present and future activities would be about 

346 acres (detrimental soil conditions for Alterative 4 plus the existing 

condition) (Table 3-47). All harvest units and the project area would 

meet R10 Soil Quality Standards as proposed. 

Based on landslide rates from Swanston and Marion (1991) landslide 

disturbance in the proposed harvest areas would continue at an 

estimated rate of 0.01 acre/year, totaling about 0.4 acre over a 35-year 

period ). Cumulatively landslide disturbance for the entire project area 

is estimated at 1.21 acres/year and 42.4 acres over a 35-year period. 

By implementing the BMPs outlined on the unit and road cards, all 

units will meet Forest Plan Standards and Guidelines and Regional 

standards. 

Alternative 3 

Alternative 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 167 

Table 3-47. Cumulative Effects - Summary of Existing Soil 

Disturbance within the Central Kupreanof Project 

Area and Disturbance that May Result from Project 

Implementation 

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

Detrimental Disturbance (acres) 

Temporary 

road 731

 0 19 30 11 

Yarding 

disturbances2 138 0 71 104 40 

Landslides3 42 42 43 43 42 

Total 

detrimental 253 42 133 177 93 

Other disturbance (acres) 

NFS road 3104

 0 34 122 0 

Total 

disturbance 563 42 167 299 93 

1

Estimate is based on 15 miles of closed road within the project area x 4.85 

acres/mile. 

2

Shovel and cable yarding estimated at 3 percent disturbance and helicopter yarding 

estimated at 2 percent based on Landwehr and Nowacki’s work (1999). Existing 

yarding disturbance is acres of past harvest x 3 percent. 

3

 Landslide totals for Alternatives 1-4 are an estimate for the next 35 years. 

4 Estimate includes 64 miles of existing open road within the project area x 4.85 

acres/mile. 

In conjunction with the analysis of the project area for timber harvest, 

the Petersburg Ranger District is conducting a road analysis on the 

Kake road system to identify the minimum road system needed for 

safe and efficient travel and for administration, utilization and 

management of National Forest System lands. Recommendations for 

road storage, decommissioning, closure and maintenance schedules 

will be analyzed in the PRD ATM EA. 

No other actions, other than Projects Common to all Action 

Alternatives (see the next section), are planned in the foreseeable 

future within the project area. 

Projects Common 

to all Alternatives 
3 Environment and Effects 

168  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Effects of Projects Common to all Action 

Alternatives 

The storage of roads and the associated removal of culverts and 

bridges on the Kake road system will help improve drainage patterns 

and eliminate plugged culverts, stream diversions and the risk of road 

failures at stream crossings. Implementation of these projects is 

dependent on the analysis and decisions made in another NEPA 

analysis, the District’s ATM plan. 

The maintenance of four recreational hiking trails should not have any 

negative effects on soil. In contrast, they will likely reduce erosion and 

soil loss. 

No effects to soils are expected as a result of maintenance work on Big 

John Bay Cabin. 

Handpulling invasive plants will disturb soil in the immediate 

proximity of the activity, but no long-lasting negative effects are 

expected. 

Precommerical thinning 325 acres of young growth stands to benefit 

wildlife is not expected to negatively affect soil resources. 

Any new rock quarries developed or expanded to support road 

maintenance will result in an irretrievable loss of soil resources. With 

the expansion of an existing quarry, or the development of a new one, 

the area footprint will not exceed 5 acres. In general, scheduled road 

maintenance will be benefit soil resources by maintaining drainage and 

reducing the risk of road failures. 

The implementation of a Microsale program will have no effect on 

soils due to the program’s limited scale. 

Fisheries/ 

Hydrology 

Projects 

Recreation 

Invasive Plants 

Silviculture and 

Wildlife 

Transportation 

Microsales 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 169 

Wetlands 

Introduction 

Wetlands are sites which generally have both saturated soils for a 

portion of the growing year and vegetation that is adapted to wet sites. 

They are valued for their physical, chemical and biological functions. 

Wetlands moderate flooding, reduce runoff and sedimentation, provide 

wildlife and plant habitat, and may help sustain stream flow during dry 

periods. Physical functions may include flood conveyance, surface and 

ground water regulation, sediment retention, and temperature 

moderation. Chemical functions may include nutrient storage, pH 

moderation, and carbon storage. Biological functions include habitat 

for terrestrial, aquatic, and marine plants and animals. In addition, 

forested wetlands are an important component of the forest land base. 

The Forest Service is required by Executive Order 11990 and Section 

404 of the Clean Water Act to preserve the natural and beneficial 

values of wetlands wherever practicable when carrying out its land 

management responsibilities. Executive Order 11990 and subsequent 

regulations also require federal agencies to avoid new road 

construction on wetlands whenever there is a practicable, 

environmentally-preferred alternative. 

Due to the extensive nature of wetlands in Southeast Alaska, it is 

impossible to avoid all wetlands during road planning and 

construction. Instead the strategy is to avoid wetland types that are 

scarce in the immediate landscape, and/or those wetlands recognized 

as having high value, such as estuaries and tall sedge fens (TLMP 

2008, 4-88). Where a wetland cannot be avoided, the impacts are to be 

minimized. Best Management Practices (BMP) 12.5 provides guidance 

for wetland identification, evaluation and protection. 

Affected Environment 

The Central Kupreanof project area contains a larger proportion of 

wetlands than much of Southeast Alaska, about 66 percent. Five 

different wetland types make up the project area’s 100,333 wetland 

acres (Table 3-48). Resource values associated with these wetlands 

vary, depending on biological qualities, proximity to water bodies, and 

the position on the landscape. 

Specific descriptions for the wetland categories are briefly described 

below. 
3 Environment and Effects 

170  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Regionally, estuarine wetlands are considered high-value wetlands. 

Estuaries are intertidal zones where brackish saltwater mixes with 

fresh water from rivers or streams. They provide high value habitat for 

vegetation, fish and wildlife. There are two types of estuarine 

wetlands: emergent wetlands in the upper tidal zone, and intertidal, 

regularly flooded zones. The emergent wetlands are characterized by 

grasses and sedges, especially tufted hairgrass, Lynghy’s sedge and 

dune wild rye in the upper tidal zone. The intertidal, regularly flooded 

zone is comprised largely of aquatic algal beds and rocky or 

unconsolidated shore. The Forest Service only manages the wetlands 

above mean high tide, as it is not chartered to manage ocean area 

(TLMP 2008). 

Sedge fens, dominated by Sitka sedge but characterized by a diverse 

community of sedges with a variety of forbs and occasional stunted 

trees (usually spruce or hemlock) are considered high-value wetlands. 

Soils are typically deep organic muck, often with thin layers of alluvial 

soil material. They occur in landscape positions where they receive 

nutrient-rich runoff from adjacent slopes creating somewhat richer 

conditions than bogs or sphagnum muskegs. These wetlands function 

as areas for recharge of groundwater and streams, deposition and 

storage of sediment and nutrients, and for waterfowl and terrestrial 

wildlife habitat, including black bear, mink, river otter, and beaver. 

Many sedge fens contain beaver ponds that often provide high quality 

waterfowl and salmon rearing habitat. 

Forested wetlands include a number of forested plant communities 

with hemlock, cedar, or mixed conifer overstory, and a young tree, 

shrub, and herbaceous layer understory. Forested wetlands are 

typically on poorly or very poorly drained hydric mineral soils, but 

generally have woody vegetation that exceeds 20 feet in height. They 

are most common on broad glacial valley bottoms and on gently 

sloping hill slopes or benches. These wetlands function as recharge 

areas for groundwater and streams, and for deposition of sediment and 

nutrients. Some forested wetlands support merchantable timber 

stands. 

These wetlands are characterized by small patches of muskegs and 

forested wetlands (as described above) arranged in a mosaic pattern on 

the landscape. These areas have vegetative properties of both muskegs 

and forested wetlands, but function somewhat differently with respect 

to habitat due to their small size and spatial arrangement. 

Moss muskeg wetlands are most commonly found in broad valley 

bottoms and on rounded hilltops. They are dominated by sphagnum 

moss, with a wide variety of other plants adapted to very wet, acidic, 

organic soils and typically contain stunted lodgepole pine and western 

hemlock less than 15 feet tall. These wetlands function as areas for 

Estuarine 

Wetlands 

Emergent Short 

Sedge Wetlands 

Forested 

Wetlands 

Muskeg/Forested 

Wetland Mosaic 

Moss Muskeg 

Wetlands 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 171 

recharge of groundwater and streams and for deposition and storage of 

sediment and nutrients. They are a valuable source of biological and 

vegetative diversity. 

Table 3-48. Wetland Habitat Types in the Central Kupreanof 

Project Area. 

Wetland Type Acres in Project 

Area 

Percent of Project 

Area 

Muskeg/forested wetland 

mosaic 62,327 40.9 

Moss muskeg 22,396 14.7 

Forested 14,983 9.8 

Emergent short sedge 605 0.4 

Estuarine 22 0.01 

Total Wetland Acres 100,333 65.81 

Management Activities on Wetlands 

Many of the forested wetland soils are capable of supporting forests 

suitable for timber production and were included in the suitable timber 

base during the analysis of the Forest Plan. However, site productivity 

for tree growth is generally lower than on sites with better drainage. 

Regeneration is expected to occur within five years, just as with other 

forested sites. 

Harvesting timber from forested wetlands causes a temporary increase 

in soil moisture until equivalent transpiration and interception surfaces 

are reestablished. Table 3-49 displays the number of wetland acres 

previously harvested within the project area as well as the number of 

acres proposed in the harvest units. 

Timber Harvest 
3 Environment and Effects 

172  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-49. Wetland Acres Previously Harvested and those 

Proposed for Harvest within the Central Kupreanof 

Project Area 

Wetland Type Existing 

Managed 

Stands 

Alt 

1 

Alt 2 Alt 3 Alt 4 

Emergent short sedge 0 0 0 0 0 

Forested 

wetland/moss muskeg 

mosaic 

163 0 14 14 8 

Forested 391 0 174 310 101 

Moss muskeg 2 0 0 0 0 

Total Harvest 556 0 188 324 109 

Of the 79 existing miles of road in the project area, 37 miles (47 

percent) cross wetlands (Table 3-50). This equates to approximately 

179 acres of wetland being replaced by roads within the project area, 

assuming a 40-foot road corridor includes cutslope and fillslope (Table 

3-51). The existing roads do not cross any estuary or tall sedge fen 

areas (i.e., high value wetlands). However, 0.05 mile and 0.3 mile 

sections of existing road cross an emergent short sedge fen (totaling 

1.7 acres of this high value wetland type lost to road construction). 

The amount, frequency and distribution of wetlands in the project area 

make it impossible to avoid new road construction across forested 

wetlands. Wetland avoidance is discussed on the individual road cards. 

Table 3-50 displays the miles of proposed road that would cross 

wetlands by alternative and Table 3-51 shows the same data as acres 

lost to road construction. 

Road 

Construction 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 173 

Table 3-50. Miles of Road Crossing Wetlands within the Project 

Area 

Road Type Wetland type Existing Alt 

1 

Alt 

2 

Alt 

3 

Alt 

4 

Reconstructed

Emergent short 

sedge - 0 0 0.07 0 

Forested - 0 0.27 0.6 0.26

Muskeg/forested 

wetland mosaic - 0 0.41 1.44 0.41

Moss muskeg - 0 0.15 0.15 0.15

Temporary 

Emergent short 

sedge - 0 0 0 0 

Forested - 0 0.31 0.68 0.18

Muskeg/forested 

wetland mosaic - 0 0.36 0.36 0.17

Moss muskeg - 0 0 0 0 

System 

Emergent short 

sedge 0.35 0 0 0 0 

Forested 8.87 0 0.49 1.1 0 

Muskeg/forested 

wetland mosaic 24.97 0 0.36 1.95 0 

Moss muskeg 2.78 0 0.47 0.71 0 

Total miles of road crossing 

wetlands1 36.97 0 2.83 7.06 1.17

1

Numbers may not total exactly due to rounding.
3 Environment and Effects 

174  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-51. Past, Proposed and Future Foreseeable Acres of 

Wetlands lost to Road Construction1. 

Road Type Wetland type Past 

losses

Alt 

1 

Alt 

2 

Alt 

3 

Alt 

4 

Foreseeable 

losses 

Reconstructed 

Emergent short 

sedge - 0 0 0.34 0 0 

Forested - 0 1.3 2.9 1.3 0 

Muskeg/forested 

wetland mosaic - 0 2.0 7.0 2.0 0 

Moss muskeg - 0 0.7 0.7 0.7 0 

Temporary 

Emergent short 

sedge - 0 0 0 0 0 

Forested - 0 1.5 3.3 0.9 0 

Muskeg/forested 

wetland mosaic - 0 1.7 1.7 0.8 0 

Moss muskeg - 0 0 0 0 0 

System 

Emergent short 

sedge 1.7 0 0 0 0 0 

Forested 43 0 2.4 5.3 0 0 

Muskeg/forested 

wetland mosaic 121.1 0 1.7 9.5 0 0 

Moss muskeg 13.5 0 2.3 3.4 0 0 

Total acres of wetlands lost to 

road construction2 179.3 0 13.7 34.2 5.7 0 

1

Estimated disturbance acres from road construction is calculated by multiplying 

miles by 4.85 (to account for a 40-foot road corridor including cutslope and 

fillslope). 

2

Numbers may not total exactly due to rounding.

Executive Order 11990 and subsequent regulations require federal 

agencies to avoid new road construction on wetlands whenever there is 

a practicable, environmentally-preferred alternative. For instance, 

building road across wetlands is environmentally preferred when 

compared to road construction across steep slopes. The forested 

wetland acres on the Central Kupreanof project area often include 

Wetland 

Avoidance 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 175 

stands of commercial timber and are managed for their timber 

resources. The most economical way to access this timber involves 

building road. 

All action alternatives and individual road locations avoid wetlands to 

the extent practicable, proposing less than 25 percent of the project 

area’s reconstructed, temporary and NFS road construction on 

wetlands. More specifically, 20 percent, 17.5 percent and 24.4 percent 

of all proposed roads cross wetlands in Alternative 2, 3 and 4, 

respectively. Site specific wetland avoidance is documented on the 

road cards for NFS road segments and the unit cards for temporary 

road segments. 

Resource Analysis Area 

The spatial analysis area for direct, indirect and cumulative effects is 

the project area (VCUs 426, 427.1, 429, 436, and 438). 

Direct and Indirect Effects 

Each action alternative includes wetlands within proposed harvest 

units (Table 3-49). The effects of timber harvest on the beneficial 

functions of wetlands, in most cases, are expected to be temporary. 

Harvest has occurred and is planned in all but one of the wetland types 

(emergent short sedge) present in the project area. The wetland type 

with the most proposed harvest is forested wetlands (Table 3-49). 

The greatest direct effect to wetlands would be the placement of fill 

material and drainage structures associated with the construction of 

new roads. This is a long-term effect on the wetland area covered by 

the road prism. Considerations of road location include, cost, existing 

technology, and logistics as they apply to a project (TLMP 2008, pg 4-

88). When possible, roads are located to avoid wetlands. 

Another direct effect of road building on wetlands is the slight 

alteration of soil drainage for several feet on either side of the prism 

evidenced by vegetation changes in these areas. Drainage ditches 

collect and divert overland flow and shallow surface flow to the 

nearest stream channel. This has minimal effect on soil wetness in the 

wetlands above and below the road prism (McGee 2000). 

Expanding existing or creating new rock pits, and selecting logs for 

stringer bridges needed in construction may be necessary to complete 

transportation plans for this project. These activities will follow Forest 

Plan direction with regards to location, design, and construction 

(TLMP 2008, pgs 4-80 through 4-88). 

Proposed roads would cross forested wetlands and muskeg/forested 

wetland mosaics in all three action alternatives (Table 3-50). Forested 
3 Environment and Effects 

176  Chapter 3 Central Kupreanof Timber Harvest FEIS 

wetlands and muskeg/forested wetland mosaics would be crossed by 

new temporary road construction in Alternatives 2, 3 and 4. Proposed 

system roads would cross forested wetlands, muskeg/forested wetland 

mosaics and moss muskeg in Alternatives 2 and 3 (Table 3-50). No 

system roads are proposed for Alternative 4. Changes in wetland flows 

resulting from road construction are expected to be minimal. 

No wetland would be impacted under Alternative 1 as a result of 

harvest or road construction. Vegetation on forested wetlands 

harvested in the past would continue to grow toward hydrologic 

maturity. Wetlands impacted by roads in the past would receive 

minimal use. Vegetation will occupy ditchlines and in the case of 

closed roads the roadbed may be occupied by red alder with eventual 

establishment of conifers. The road prism would remain in an upland 

condition. Road ditches, where present, will support a variety of 

upland and wetland vegetation depending on local conditions and seed 

sources. Hydrologic and vegetation effects would remain limited 

beyond the road prism (Glaser 2000). 

Effects Common to all Action Alternatives 

Timber harvest is proposed on wetlands in all action alternatives. 

Harvest activities are expected to have a minimal and short-term effect 

on wetland soil moisture. Removal of timber would lead to a shortterm increase in soil saturation until second-growth establishes 

evapotranspiration surfaces similar to pre-harvest conditions. Effects 

on soil moisture would likely be less in areas where partial cutting is 

utilized. The proposed harvest in all action alternatives would not pose 

a long-term negative impact to wetlands in the project area. 

The effects of road construction on wetland hydrology and vegetation 

depend largely on the landscape position of and the substrate (soil) 

within the wetland. Wetlands located on ridgetops serve to donate 

water downslope. Soils in these landscape positions are typically peat 

soils that are shallow (less than 20 inches thick) over bedrock. Because 

these landscape positions receive more rain than lower slope positions 

and the soils have a higher water holding capacity, the effects of 

constructing a shot rock road across these wetlands is usually limited 

to the area of wetland buried by the shot rock, and effects to vegetation 

are limited to within a few meters of the shot rock (Glaser 2000). 

Road crossings mid-slope and lower slope landscape positions have a 

greater chance of intercepting soil and surface water as the water 

moves downslope. While application of BMPs provide some assurance 

that surface water streams will not be diverted by roads, soil water is 

sometimes captured and diverted to the nearest stream or drainagerelief culvert. However, due to the high levels of precipitation and high 

Alternative 1 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 177 

moisture contents, the intercepted soil water does not translate into 

drier soils downslope. 

In mid-slope and lower slope landscape positions, the effects of roads 

on wetlands can extend just beyond the road prism and substrate plays 

an increasingly important role. Thicker peat and mineral soils occur in 

these landscape positions. Thick peat soils permeate slowly and have 

an extremely high water-holding capacity. Effects on these soils are 

limited to within a few meters of the cutbank and toe of fill (Kahklen 

and Moll 1999). Although soil moisture levels beyond the road cut 

slopes and fill slopes would change, the soil moisture levels are not 

expected to change so much that the wetland (outside the disturbed 

soil corridor) would develop into an upland site. 

Alternative 2 proposes to harvest timber from approximately 188 acres 

of wetland with the majority of those acres being forested wetland 

(174 acres) (Table 3-49). Trees growing on these wetlands would 

likely grow slower than trees on upland sites. Soil moisture would 

temporarily increase as described in Effects Common to All Action 

Alternatives. 

Road construction under Alternative 2 would convert approximately 

14 acres of wetland habitat to road (Table 3-51). 

Alternative 3 proposes to harvest timber from approximately 324 acres 

of wetland with the majority of those acres being forested wetland 

(310 acres) (Table 3-49). Trees growing on these wetlands would 

likely grow slower than trees on upland sites. Soil moisture would 

temporarily increase as described in Effects Common to All Action 

Alternatives. 

Road construction under Alternative 3 would convert approximately 

34 acres of wetland habitat to road and has the potential to affect the 

most wetland acres of all the action alternatives (Table 3-51). 

Alternative 4 proposes to harvest timber from approximately 109 acres 

of wetland with majority of those acres being forest wetland (101 

acres) (Table 3-49). Trees growing on these wetlands would likely 

grow slower than trees on upland sites. Soil moisture would 

temporarily increase as described in Effects Common to All Action 

Alternatives. 

Road construction under Alternative 4 would convert approximately 

six acres of wetland habitat to road (Table 3-51). 

Alternative 2 

Alternative 3 

Alternative 4 
3 Environment and Effects 

178  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Cumulative Effects 

The cumulative effects analysis area is the project area. The Catalog of 

Events for Kupreanof Island (a list of projects by year and VCU that 

have been implemented on Kupreanof Island) was referenced to 

determine cumulative effects on wetlands in the Central Kupreanof 

project area (Appendix C). 

The cumulative effects analysis considers the past, proposed and future 

foreseeable conversion of wetland to roads. The effects of past wetland 

harvest (approximately 556 acres) and currently proposed harvest 

discussed above are expected to be temporary with wetland function 

and habitat characteristics being restored through the natural processes 

of vegetation growth and succession. The effects to wetlands from 

road construction may be long lasting; however, they are expected to 

be limited due to the relatively low number of wetland acres planned 

for conversion to road and the extensive nature of wetlands in the 

project area. If the alternative with the most acres of wetland 

conversion were implemented (Alternative 3), a total of 213.5 acres of 

wetland would be converted to road (34.2 acres of new construction in 

addition to the existing condition). 

In conjunction with the analysis of the project area for timber harvest, 

the Petersburg Ranger District is conducting a road analysis on the 

Kake road system to identify the minimum road system needed for 

safe and efficient travel and for administration, utilization and 

management of National Forest System lands. Recommendations for 

road storage, decommissioning, closure and maintenance schedules 

will be analyzed in the District’s ATM EA. 

No other actions, other than Projects Common to all Action 

Alternatives (see the section after next), are planned in the foreseeable 

future within the project area. 

Mitigation

Section 313 of the Clean Water Act and Executive Order 12088 

require that Best Management Practices (BMPs) are consistent with 

State Forest Practices and other applicable State Water Quality 

Regulations be used to mitigate the impacts of land-disturbing 

activities. Site-specific application of these BMPs are designed with 

consideration of geology, land type, hydrology, soil type, erosion 

hazard, climate, cumulative effects, and other factors in order to 

protect and maintain soil, water and water-related beneficial uses. 

BMPs considered necessary, that were identified during the planning 

process, are shown on the unit cards. Additional protective measures 

Projects Common 

to all Alternatives 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 179 

may be applied during timber sale layout or during harvest activities, 

as needed. 

Effects of Projects Common to all Action 

Alternatives 

The storage of roads and the associated removal of culverts and 

bridges on the Kake road system are not expected to negatively affect 

wetlands. 

The maintenance of four recreational hiking trails should not have any 

negative effects on wetlands. 

No negative effects to wetlands are expected as a result of 

maintenance work on the Big John Bay Cabin. 

Handpulling invasive plants is not expected to have any negative 

effects on wetlands. 

Precommerical thinning 325 acres of young growth stands to benefit 

wildlife is not expected to negatively affect wetlands. 

Road maintenance and associated rock quarries are not expected to 

have deleterious effects on wetlands. 

The implementation of a Microsale program will have no effect on 

wetlands due to the limited scale of the program. 

Fisheries/ 

Hydrology 

Projects 

Recreation 

Invasive Plants 

Silviculture and 

Wildlife 

Transportation 

Microsales 
3 Environment and Effects 

180  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Scenery 

Resource Analysis Area 

The Central Kupreanof project area is located on Kupreanof Island, 30 

air miles west of Petersburg, of approximately 152,517 acres in size 

and situated between upper Duncan Canal and Rocky Pass. An 

existing road system accesses the central portion of the project area. 

The analysis area boundaries include those portions of the project area 

visible from Visual Priority Travel Routes and Use Areas identified in 

the Forest Plan where scenic quality is emphasized. 

Affected Environment 

Southeast Alaska scenery generally includes mountains, glaciers, 

water, sky, weather, trees, animals, boats, people, and development. 

While there are an infinite number of personal interpretations of 

scenery, general preferences are predictable based upon cultural norms 

and the predominant values of society. Recreational visitors expect 

the forest to display natural appearing character from major travel 

routes and use areas. 

Methods 

The methods used to evaluate scenic quality for the Central Kupreanof 

project area is described in the Landscape Aesthetics, A Handbook for 

Scenery Management (U.S. Forest Service 1995). The Scenery 

Management System provides the framework for the inventory of the 

scenery resource and provides measurable standards for its 

management. 

The Forest Plan has identified specific locations where scenery is 

viewed from locations of high visitor use and where a greater concern 

for scenic quality exists. Visual priority travel routes and use areas are 

used to identify these locations and assess scenic conditions potentially 

affected by management activities. Locations visible from priority 

travel routes and use areas are described in scenery resource terms as 

the “seen area,” while “seldom seen” or “not seen” areas are defined as 

those locations not viewed from any position along a Visual Priority 

Travel Route or Use Area. 

Sensitive viewing locations within the project area where scenic 

quality will be emphasized include the saltwater use area/small boat 

route of Duncan Canal and Towers Arm, Rocky Pass from Beacon 

Island south to Meadow Island, Big John Bay and Big John Bay cabin, 

the dispersed recreation use areas along Hamilton Creek and at Goose 

Visual Priority 

Travel Routes and 

Use Areas 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 181 

Marsh Lake, and the Cathedral Falls, Hamilton Creek, and Big John 

Bay trails. 

All the priority travel route and use area destinations surrounding the 

project area receive intermittent to moderate use over the course of the 

year, much of which is seasonal in nature. Those viewing the 

landscapes are primarily individuals involved in activities such as 

camping, hunting, fishing, or subsistence. 

Visibility, mapped in terms of distance zones, is a measure of how 

visual changes are perceived in the landscape. Changes in form, line, 

color, and texture become less perceptible with increasing distance. 

Landscape visibility can also be affected by considerations such as 

how the viewer perceives the landscape, the duration of view, the 

degree of discernible detail, seasonal variations including weather, and 

the number of viewers. The Forest Service Scenery Management 

Handbook describes visibility in terms of three distance zones: 

foreground, middleground, and background. Areas not visible from 

Visual Priority Travel Routes and Use Areas are termed “not seen.” 

Each distance zone describes the level of detail or change that can 

typically be perceived when viewing the landscape. 

The seen area or what is visible of the Central Kupreanof project 

landscape from Visual Priority Travel Route and Use Areas are 

classified into the following categories: 

 Foreground: (0 - 1⁄2 mile) – The portion of the seen area in 

which detail in the landscape becomes noticeable. Foliage and 

fine textural details of vegetation are normally perceptible 

within this zone. Foreground viewing locations include the 

trails, trailheads, and dispersed use areas in the Hamilton 

Creek, Cathedral Falls, Goose Lake, and Big John Bay vicinity. 

 Middleground : (1⁄2 - 3 to 5 miles) - The portion of the seen area 

in which details of foliage and fine textures cease to be 

perceptible and objects in the landscape are perceived mainly 

by their form. Vegetation appears as outlines or patterns. 

Middleground views of the project area are confined to a 

prominent forested ridgeline visible from portions of Big John 

Bay and Rocky Pass. 

 Background: (3-5 miles and greater) - The portion of the seen 

area where texture and color are weak, and landforms become 

the most dominant element. Background views of the 

mountain ranges frame the horizon in this landscape. The 

visual elements of line and form are dominant. Strong color 

contrasts of sufficient size may still be noticeable. Background 

viewing locations within the project area would be prominent 

ridge tops visible from Rocky Pass and Duncan Canal. 

Landscape 

Visibility/Distance 

Zones 
3 Environment and Effects 

182  Chapter 3 Central Kupreanof Timber Harvest FEIS 

 Not Seen: Landscapes that are not visible from Visual Priority 

Travel Routes and Use Areas. Approximately 89% of the 

project area is categorized as not seen from Visual Priority 

Travel Routes or Use Areas. 

Table 3-52. Project Area Visibility from Visual Priority Travel 

Routes or Use Areas 

Visibility Acres 

Seen 12,868 

Not Seen 139,649 

Central Kupreanof Project 

Area 152,517 

Scenic Integrity Objectives 

Scenic Integrity Objectives (SIOs) provide measurable standards to 

assess the scenery resource based on the landform characteristics and 

the level of public concern, and are established by incorporating the 

previously defined scenery characteristics: scenic attractiveness, 

landscape visibility, priority viewing locations, and existing scenic 

integrity. In providing a measure by which to describe scenic effects 

these objectives include: 

 High: Changes in the landscape are not visually evident to the 

average forest visitor. 

 Moderate: Changes in the landscape may be evident to the 

casual observer but appear as natural occurrences when 

contrasted with the appearance of the surrounding landscape. 

 Low: Changes in the landscape appear very evident but 

incorporate natural patterns of form, line, color, and texture 

when contrasted with the appearance of the surrounding 

landscape. 

 Very Low: Changes in the landscape appear highly evident 

and may visually dominate the surrounding landscape, yet 

when viewed in the background distance these activities appear 

as natural occurrences. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 183 

Table 3-53. Project Area Acres by Scenic Integrity Objective 

Scenic Integrity Objective Acres 

High 19,084 

Moderate 16,177 

Low 2,995 

Very Low 114,261 

Central Kupreanof Project Area 152,517 

Existing Scenic Condition 

Existing Scenic Integrity describes the deviation of a landscape from a 

natural forest condition. It excludes the context of whether the 

landscape is seen or not seen from Visual Priority Travel Routes and 

Use Areas and indicates the amount of change that has occurred in the 

past, and what level of change may be acceptable in the future. The 

relevance of Existing Scenic Integrity for this analysis is to use the 

present reference condition of the project area as a baseline to evaluate 

the acceptable desired scenic condition and cumulative effects outlined 

in the Forest Plan management prescription criteria. Six levels are 

used to describe the landscapes existing visual condition ranging from 

pristine to intensively modified: 

 Appears Unaltered: Landscapes where development is not 

typically noticed by the average forest visitor. These 

landscapes have been altered but changes are not perceptible. 

For the purposes of this analysis this represents the reference 

condition from which change can be quantified. 

 Slightly Altered: Landscapes where development is noticeable 

by the average forest visitor, but are natural in appearance. 

Changes appear to be minor disturbances. 

 Moderately Altered: Landscapes where changes are easily 

noticed by the average forest visitor and may attract attention. 

Changes appear as disturbances but resemble natural patterns 

in the landscape. 

 Heavily Altered: Landscapes where changes are very 

noticeable and would be obvious to the average forest visitor. 

Changes tend to stand out, dominating the view of the 

landscape, but are shaped to resemble natural patterns. 

Existing Scenic 

Integrity 
3 Environment and Effects 

184  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The Existing Scenic Integrity of the project area is primarily unaltered 

in appearance, as most of the project area remains in an undeveloped 

condition. The heavily altered landscapes surrounding the Hamilton 

Creek drainage is more a result of the extent of harvest than the direct 

visual appearance of the trees when viewed in close proximity or from 

visual priority viewing locations, and is reflective of the desired 

condition of the Timber Production land use designation. 

Table 3-54. Project Area Acres by Existing Scenic Integrity 

Existing Scenic Integrity Acres 

Appears Unaltered 103,137 

Slightly Altered 4,824 

Moderately Altered 12,250 

Heavily Altered 32,306 

Central Kupreanof Project 

Area 152,157 

Desired Scenic Condition 

The desired scenic condition for scenic quality is indicated by 

management prescriptions in the Forest Plan. All acres of land within 

the National Forest are assigned a LUD, each have varying degrees of 

acceptable alteration assigned by a Scenic Integrity Objective. Seven 

LUDs are located within the project area: Timber, Modified 

Landscape, Semi-Remote Recreation, Remote Recreation, Special 

Interest Area, and Old-growth Habitat Preserve and Wilderness. 

Approximately 72 percent of the project area is allocated to the Timber 

Production LUD. The resulting appearance would reflect activities 

that may appear heavily altered in those areas maximizing timber 

production while maintaining a mostly natural appearing condition 

within the Modified Landscape management prescriptions. The 

Remote and Semi-Remote Recreation, Special Interest Area, and OldGrowth Habitat Reserve will retain their unaltered appearance where 

no harvest would occur. The Modified Landscape LUD area is located 

in the northeastern portion of the project area and includes the 

landscapes visible from portions of Big John Bay and Rocky Pass. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 185 

Environmental Consequences 

Timber harvest within the project area visible from Visual Priority 

Routes and Use Areas will be designed and implemented to meet the 

Forest Plan adopted scenic integrity objectives. The future scenic 

condition of the affected landscape will be predominantly reflective of 

the Timber Production land use designation, where the primary goal is 

to manage land for the sustained long-term yield of wood. 

The scenic effects will portray a greater visibility of the development 

associated with timber harvest than that characteristic of a natural 

appearing forest environment. Factors contributing to the visual 

magnitude associated with timber harvest include: the size of the unit, 

slope and aspect, distance at which it is observed, time of day and 

lighting conditions, prevailing weather, and the vegetative composition 

of the surrounding landscape. Green tree retention within units will 

reduce the visual effects. Additionally, all of the proposed timber 

harvest of any given alternative will not be seen at one time from a 

single location. Impacts to scenery for all alternatives will remain 

relatively constant over time as harvested areas regenerate and existing 

stands are removed. 

All alternatives would meet the level of scenic quality for the affected 

landscapes desired condition as outlined in the Forest Plan. 

The analysis boundaries for the direct, indirect, and cumulative effects 

includes areas where timber harvest, roads, and other associated 

activities resulting from the implementation of the proposed EIS are 

potentially viewed from any Forest Plan Visual Priority Travel Route 

and Use Area. Landscapes within the project area that are not seen 

from Visual Priority Travel Routes or Use Areas are also included in 

the analysis but have a lesser expectation for scenic quality. 

The unit of measure for direct and indirect effects is the Forest Plan 

scenic integrity objectives, which represent a quantifiable measure of 

change to the natural appearance of the landscape. The unit of 

measure for cumulative effects is the total visual disturbance within a 

viewshed or Value Comparison Unit (VCU). The visual appearance of 

landscapes changes over time, previously harvested areas regenerate 

and return to a more natural appearing condition. It is expected that 

over a period of 30 years timber harvest has visually recovered to 

resemble a natural appearing forest condition and no longer is 

considered a cumulative effect. 

Methods 
3 Environment and Effects 

186  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Direct Effects of Timber Harvest and 

Summary of Effects by Alternative 

Each of the action alternatives proposed includes a different selection 

of harvest units that utilizes an existing road system and the 

construction of new and temporary roads. Visibility of harvest units 

from sensitive viewing areas also varies by alternative. The following 

table displays the comparative difference between the alternatives as 

measured by the greatest potential visibility from Visual Priority 

Travel Route or Use Areas. 

Table 3-55. Acres of Harvest in Distance Zones1 by Alternative 

Distance Zone Alt 1 Alt 2 Alt 3 Alt 4 

Foreground 0 0 0 0 

Middleground 0 316 384 55 

Background 0 117 336 63 

Not Seen 0 2,073 2,927 1,009 

Total Harvest Acres

0 

2,506 3,647 1,327 

1

Foreground: (0 - 1⁄2 mile) – The portion of the seen area in which detail in the 

landscape becomes noticeable. 

Middleground : (1⁄2 - 3 to 5 miles) - The portion of the seen area in which details of 

foliage and fine textures cease to be perceptible and objects in the landscape are 

perceived mainly by their form. 

Background: (3-5 miles and greater) - The portion of the seen area where texture and 

color are weak, and landforms become the most dominant element. 

Not Seen: Landscapes that are not visible from Visual Priority Travel Routes and 

Use Areas. 

The overall scenic effect of the alternatives will vary in comparison to 

the visible harvest area as seen from sensitive viewing locations. 

Alternatives 2 and 3 are nearly identical in effects and would create the 

greatest amount of visible change to the landscape from the 

development of harvest units. Alternative 4 would have the least 

effect, harvesting approximately 118 acres potentially visible from 

priority viewing areas. Both Alternatives 2 and 4 would not harvest 

timber visible from Duncan Canal. 

This alternative defers timber harvest in the project area and maintains 

the existing visual character of the landscape. Previously harvested 

units within the project area would continue to mature and develop the 

visual characteristics of a more natural appearing and undeveloped 

forest. 

Alternative 1 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 187 

Alternative 2 proposes 2,506 acres of timber harvest by clearcut and 

single tree selection methods, utilizing both conventional and 

helicopter yarding. Eleven of the 61 units proposed totaling 

approximately 433 acres would be potentially visible in varying 

degrees from priority travel routes and use areas. Not all units 

however are seen from one location or at one time. Portions of Units 

284 and 285, which have a Very Low Scenic Integrity Objective, 

would be potentially visible at a distance greater than 5 miles from 

locations in the southern end of Rocky Pass. The effects would 

achieve a Very Low SIO adopted under the Forest Plan for Timber 

Production area and likely would not be highly discernable due to the 

distance from Rocky Pass, typical weather conditions, and screening 

by foreground vegetation. From locations along the mid-point of 

Rocky Pass Units 216 and 229 also within a Timber Production LUD 

and a Very Low SIO designation would be potentially visible at a 

distance of three to five miles. Both Units 216 and 229 would likely 

not be highly discernable to most viewers due to the distance at which 

potentially visible, typical weather conditions, and screening by 

foreground vegetation along the shoreline of Rocky Pass. 

In areas of the upper Rocky Pass and Big John Bay, Units 2, 208, 209, 

313, 316, 901 and 905 would be potentially viewed at a distance of 2 

to 5 miles within a Modified Landscape LUD. This designation has a 

slightly higher degree of acceptable alteration having a Low scenic 

integrity objective, where change may appear very evident but 

resemble natural patterns in the landscape. The overall effect of these 

combined units would be lessened by harvest methods of single tree 

selection and helicopter yarding of the most visible locations which 

would achieve the Forest Plan Low SIO designation. 

The remaining units in this alternative are not visible from any Visual 

Priority Travel Route and Use Area and would achieve a Very Low 

scenic integrity or higher degree of scenic quality than adopted under 

the Forest Plan. 

Alternative 3 proposes 3,647 acres of timber harvest by clearcut and 

single tree selection, utilizing both conventional and helicopter yarding 

methods. This Alternative proposes the greatest amount of harvest 

with approximately 384 acres potentially viewed from Visual Priority 

Travel Routes and Use Areas. Units 2, 208, 209, 313, 316, and 901 

would be all or partially visible at a distance of 2 to 5 miles from the 

waters of upper Rocky Pass and Big John Bay. These units would all 

achieve a Low SIO adopted in the Forest Plan, where timber harvest 

may appear very evident but resemble natural patterns in the 

landscape. 

From locations in upper Duncan Canal north of Indian Point, Units 

258, 260, 261, 262, 263, 264, and 265 may be partially evident at a 

Alternative 2 

Alternative 3 
3 Environment and Effects 

188  Chapter 3 Central Kupreanof Timber Harvest FEIS 

distance of 3 to 5 miles. At this distance these units would not draw 

attention from the viewer and resemble natural patterns in the 

landscape achieving a higher degree of visual quality than the Very 

Low scenic integrity objective adopted in the Forest Plan. 

Portions of Units 284 and 285, which have a Very Low SIO, would be 

potentially visible at a distance greater than five miles from locations 

in the southern end of Rocky Pass. The effects would achieve a Very 

Low SIO adopted under the Forest Plan for Timber Production area 

and likely would not be highly visible due to the distance from Rocky 

Pass, typical weather conditions, and screening by foreground 

vegetation. From locations along the mid-point of Rocky Pass Units 

216 and 229 also within a Timber Production LUD and a Very Low 

SIO designation would be potentially visible at a distance of three to 

five miles. Both Units 216 and 229 would likely not be highly visible 

to most viewers due to the distance at which potentially visible, typical 

weather conditions, and screening by foreground vegetation along the 

shoreline of Rocky Pass. 

The remaining units in this alternative are not visible from any Visual 

Priority Travel Route and Use Area and would achieve a Very Low 

scenic integrity or higher degree of scenic quality than adopted under 

the Forest Plan. 

Alternative 4 proposes 1,327 acres of timber harvest by clearcut using 

conventional yarding methods. This Alternative would have the least 

effect upon scenery in harvesting approximately 118 acres potentially 

visible from priority viewing areas. Units 2, 208, 209, 313, 316 901, 

and 905 would be potentially viewed from locations within upper 

Rocky Pass and Big John Bay. A reduction of the total visible acres of 

harvest would be reduced by no helicopter yarding in this alternative. 

These units would all achieve a Low SIO adopted in the Forest Plan, 

where timber harvest may appear very evident but resemble natural 

patterns in the landscape. 

Portions of Units 284 and 285, which have a Very Low SIO, would be 

potentially visible at a distance greater than five miles from locations 

in the southern end of Rocky Pass. The effects would achieve a Very 

Low SIO adopted under the Forest Plan for Timber Production area 

and likely would not be highly visible due to the distance at which 

viewed, typical weather conditions, and screening by foreground 

vegetation. Unit 229, also within a Timber Production LUD with a 

Very Low SIO designation, would be potentially visible at a distance 

of three to five miles from locations along the mid-point of Rocky 

Pass. These units would all achieve a Very Low scenic integrity 

objective as adopted in the Forest Plan 

Alternative 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 189 

The remaining units in this alternative are not visible from any Visual 

Priority Travel Route and Use Area and achieve a Very Low scenic 

integrity or a higher degree of scenic quality than adopted under the 

Forest Plan. 

Direct and Indirect Effects of Related 

Timber Harvest Activities 

Utilization of the existing Little Hamilton LTF for log transfer, 

storage, and camp operations would result in the developed appearance 

and modification of the scenic environment. The marine access 

facility is visible in the foreground distance zone near the end of the 

45006 spur on the Kake to Seal Point road (FS Road 6040) and in 

Hamilton Bay. For those traveling the inside waters of Hamilton Bay, 

the logging operations at the LTF site would not likely be noticed 

outside of a close proximity to Little Hamilton Island. The sort yard, 

area for log storage, and most equipment at the sites would be partially 

screened from view by foreground vegetation and the island itself. 

Contractors harvesting timber would continue to support their 

operations with either a land or floating camp. Visibility of these 

activities would be a distraction from the natural scenic environment 

but confined to a relatively small area. Camp operations are required 

to obtain and follow the necessary state and federal environmental 

permitting requirements. 

Some of the effects of new and temporary road construction borrow 

pits, and other ground disturbing activities necessary to implement the 

Central Kupreanof project would be visible from Visual Priority 

Travel Routes and Use Areas; however these effects would be far less 

visible than that of timber harvest and would meet the adopted scenic 

integrity objectives of the Forest Plan. Development of new rock 

sources, expansion of existing pits for road construction, and the 

removal of logs within 200 feet on either side of bridge locations for 

use as stringers would also meet scenic integrity objectives. Pit 

Development Plans would be approved prior to implementation and 

mitigation measures for the scenic resource applied if applicable. 

Direct and Indirect Effects of Projects 

Common to All Action Alternatives 

The direct or indirect effects resulting from the proposed Projects 

Common to all Action Alternatives would all meet the Forest Plan 

Scenic Integrity Objectives. Maintenance of the Cathedral Falls, 

Goose Lake, Hamilton Creek, and Big John Bay trails, which are 

identified Travel Routes, would provide for their continued function as 

intended. Annual maintenance of the Big John Bay cabin, an 
3 Environment and Effects 

190  Chapter 3 Central Kupreanof Timber Harvest FEIS 

identified Use Area, would also provide for the continued function of 

the cabin as a base for recreational activities. Other identified 

activities such as pre-commercial thinning, control of invasive plants, 

vegetative treatment for wildlife, and road maintenance, would have 

no negative effects upon scenery. 

The effects upon Scenery as a result of the Microsale program would 

meet the Forest Plan scenic integrity objectives of low and very low. 

Access Travel Management 

Access Travel Management (ATM) would have no effect as no roads 

proposed for closure are identified visual priority travel routes. The 

section of Forest Road 6040 from Kake to Seal Point is the only Public 

Use Road designated as a Visual Priority Travel Route within the 

project vicinity and will remain open for public use. 

Cumulative Effects 

Cumulative effects consider the overall scenic effects expected as a 

result of past, present, and foreseeable future development. These 

effects include timber harvest, roads, borrow pits, associated 

construction activities, and existing effects of adjacent non-National 

Forest lands. Previous development in the project area has modified 

the scenic environment from a natural condition to a condition where 

landscapes appear heavily altered. The past development considered 

with this analysis and listed in the project Catalog of Events 

contributing the overall scenery cumulative effects for the affected 

project area viewsheds are the Pipeline Timber Sale EA, Cathedral 

Timber Sale EA, Hamilton Creek South Timber Sale EA, North Irish 

Creek Timber Sale EIS, and The Shamrock Timber Sale EIS. effects 

of past timber harvest would continue to grow to more natural 

appearing conditions during the period of reasonably foreseeable 

future and no longer be considered a cumulative effect. 

The scale (spacial extent) from which to consider cumulative effects 

for the scenery resource can be represented as a viewshed, or for the 

purpose of this analysis the Value Comparison Units which have 

similar boundaries. Reasonable foreseeable activities such as the small 

sale program, thinning, and road maintenance would not would not 

add additional scenic effects to the point of changing the overall scenic 

integrity as cumulative effects continually change over time (temporal 

extent) through the regrowth of vegetation. Previously harvested areas 

visually recover over time and after a period of 30 years are no longer 

considered to have a cumulative impact. 

Percent of Allowable Visual Disturbance represents a measurement of 

cumulative effects modeled as the expected visual consequences of 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 191 

timber harvest during the Forest Plan analysis, and is described in 

Appendix B of the Forest Plan, Final EIS (p. B-23). Visual 

disturbance outcomes vary by the scenic objectives for each of the 

land use designations available for timber harvest. Using this model it 

was assumed for viewsheds within the Timber Production land use 

designation, that up to 50 percent may be under development at one 

time. For viewsheds within the Modified Landscape land use 

designation, up to 25 percent may be under development at one time. 

This is calculated by adding the past, present, and reasonably 

foreseeable harvest acres and dividing by the acres of a viewshed or 

VCU. The following table represents a comparison of the expected 

cumulative visual disturbance by alternative. As shown, all 

alternatives are below the total allowable visual disturbance threshold 

of 50% for Timber Production areas and 25% for Modified Landscape 

areas specified under the Forest Plan. 

Table 3-56. Acres of Past and Proposed Cumulative Visual 

Disturbance 

VCU/Viewshed Alt 1 Alt 2 Alt 3 Alt 4 

4260 

(Hamilton) 

1,931 

(5%) 

2,948 

(7%) 

3,028 

(7%) 

2,561 

(6%) 

4271 (Big John 

Bay) 

1,116 

(15%) 

1,695 

(22%) 

1,781 

(23%) 

1,505 

( 20%) 

4290 (Rocky 

Pass) 

943 

(2%) 

1,533 

(3%) 

1,567 

(3%) 

1,151 

(2%) 

4360 (Upper 

Castle) 

400 

(2%) 

455 

(2%) 

859 

(4%) 

459 

(2%) 

4380 (Upper 

Duncan) 

225 

(1%) 

489 

(2%) 

1,027 

(4%) 

266 

(1%) 

* (excludes past harvest greater than 30 years old as visually recovered) 

The visual effects of timber harvest are greatest immediately following 

completion of the project. Within 5 years, vegetation would begin to 

grow transitioning a change in color from brown to light green. Green 

tree retention retained in the harvested areas would reduce the overall 

contrast of new growth with the surrounding forest. From 5 to 20 

years after tree removal, young trees become established reaching a 

height of approximately 15 feet and further reducing the color contrast 

with adjacent forested areas. After 50 years, the emerging forest 

would achieve a height of approximately 50 feet. Color contrast at this 

point is near that of a mature forest and only textural differences are 

apparent. Edge lines forming the boundary of harvested areas also 

become less apparent, with the appearance further reduced by 
3 Environment and Effects 

192  Chapter 3 Central Kupreanof Timber Harvest FEIS 

asymmetrical design. At 80 years after a harvest, stand vegetation 

achieves 75 percent of its mature height. At 100 years, the stand 

would reach approximately 100 feet in height and appearance of the 

past harvest would not be evident. 

Assuming a continuation of the present harvest levels through 

successive Forest Plans, removal of all suitable timber within the 

Central Kupreanof project area is expected to occur within the next 

100 to 120 years. During this period, the forest would be in a 

continuous state of transition towards meeting the desired condition of 

the Timber Production management prescription objectives. The 

landscape would be characterized by regenerating harvested areas of 

mixed age classes from young stands to trees of mature height, 

typically in 40 to 100 acre groups. The appearance of the activities 

associated with timber harvest will present a landscape highly 

modified by this change. 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 193 

Unroaded Areas 

The Forest Roadless Inventory was updated with the 2003 Forest Plan 

SEIS analysis. Unroaded areas were defined as less than 5,000 acres. 

The Central Kupreanof project area includes 366 acres of an unroaded 

area (2,420 total acres in size), which was not recommended in the 

2003 Forest Plan SEIS for wilderness consideration. This area is 

approximately located in the northwest corner of the project area, and 

nearly surrounded on all sides by previously harvested units and 

logging roads. The vegetation is predominantly forest wetland and 

muskeg. No characteristics or values which would be considered 

unique are present. The 2008 Forest Plan Land Use Designation 

encompassing the unroaded area is Timber Production. 

In all alternatives no timber harvest, road construction, or rock quarry 

development is being proposed within the unroaded area. The area 

would remain unaffected. 
3 Environment and Effects 

194  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Recreation 

The analysis area for recreation includes the project area plus nearby 

recreation destinations including Cathedral Falls Trail, Hamilton Creek 

Trail, Goose Lake Trail, Big John Bay Trail and Big John Bay cabin. 

The project area was examined in the field during the summers of 

2006 and 2007. Trails were walked and general recreation trends were 

observed. Recreation use data was obtained from the special use 

coordinator, trails manager, and cabin manager on the Petersburg 

Ranger District. Mapping data and acreage numbers were obtained 

from the GIS coordinators on the District. 

Affected Environment 

The existing road system in the Central Kupreanof area connects to 

Kake, Alaska, which is a stop on the Alaska Marine Highway. This 

connection creates relatively easy access to the area for local residents 

and also visitors from other places in Alaska and out of state visitors. 

Most recreation in the project area centers around vehicle access, but it 

also includes some shoreline in Duncan Canal. The Forest Service 

maintains four trails and one public recreation cabin that are accessible 

from the Kake road system. Five other cabins in Duncan Canal are 

located east of the project area but within the vicinity. These are only 

accessible by boat and plane and cannot be reached from the Kake 

road system. The road system is used commonly by local Kake 

residents and visitors. Recreational activities that involve using the 

road system for access include sightseeing, picnicking, hiking, fishing, 

and black bear, moose, and deer hunting. 

Recreation Opportunity Spectrum in the 

Central Kupreanof Project Area 

To describe, identify, and quantify recreation settings, the Forest 

Service uses the Recreation Opportunity Spectrum (ROS). The ROS 

categorizes areas by their activities, remoteness, access, and 

experiences in a spectrum of classes from Primitive to Urban. The 

Central Kupreanof Project Area has five of the seven ROS classes: 

Roaded Modified, Roaded Natural, Semi-primitive Motorized, Semiprimitive Non-motorized, and Primitive (Table 3-57). The two classes 

not found in the project area are Rural and Urban. See the Glossary 

for definitions of each ROS class. 

Almost half (47%) of the project area is in the Semi-primitive Nonmotorized ROS class. These areas are generally at least half a mile 

from any roads or shorelines and relatively isolated from the sights and 

Resource 

Analysis Area 

Methods 

Characterization 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 195 

sounds of human activities. Most of the rest of the area is split 

between Roaded Modified (24%) and Primitive (25%) which are on 

opposite ends of the development scale in the project area. The 

Roaded Modified area encompasses the areas immediately 

surrounding existing units and roads in the area. The Primitive areas 

are the farthest from roads and units in the area and have little if any 

evidence of human presence. 

Minor components of the ROS within the project area are the Semiprimitive Motorized area and the Roaded Natural area. The Semiprimitive Motorized area (2%) is a narrow strip in the eastern part of 

the project area along the shoreline of Duncan Canal. This area is 

away from roads but it is within the sight and sound of boat traffic 

(and floatplanes landing) in a portion of Duncan Canal. The Roaded 

Natural ROS class (2%) is located on a six-mile portion of Road 6030 

in the northern part of the project area that is very natural appearing 

since it does not have any timber harvest along it. 

Table 3-57. Existing Recreation Opportunity Spectrum (ROS) 

Classes in the Central Kupreanof Project Area 

ROS Class 

Acres Percent 

Roaded Modified (RM) 

36,984 24% 

Roaded Natural (RN) 

2,833 2% 

Semi-primitive Motorized 

(SPM) 2,666 2% 

Semi-primitive Nonmotorized (SPNM) 71,427 47% 

Primitive (P) 

38,607 25% 

TOTAL ACRES 152,517 100% 
3 Environment and Effects 

196  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Recreation Places and Sites 

Recreation Places are specific areas identified by the Forest Plan that 

are used for recreation activities. They are geographical areas having 

one or more physical characteristics that are particularly attractive to 

people for recreation activities. These activities can be dispersed 

throughout the Recreation Place or concentrated at specific Recreation 

Sites. A Recreation Site is a specific site and/or facility occurring 

within a Recreation Place. Recreation Sites generally refer to specific 

points like anchorages or developed facilities such as recreation cabins 

and trailheads. Since the majority of the Tongass National Forest is 

undeveloped, it is primarily used for dispersed recreation activities. 

Viewing scenery and wildlife, boating, fishing, beachcombing, hiking 

and hunting are the primary dispersed recreation activities that take 

place. 

In theory, all acres of National Forest have the potential of providing 

recreation opportunities. However, due to terrain considerations (very 

steep, inaccessible areas), user preferences, and presence of certain 

amenities (scenery, good fishing), some areas are more highly valued. 

These key sites are termed “recreation places.” Their selection and 

identification was done by noting what characteristics or qualities of a 

site attract and influence visitor use. A knowledge of these key sites 

aids in the future evaluation of potential effects within the broader 

ROS concepts. The following discussion describes existing recreation 

places and sites in the vicinity of the project area. 

Trail classes range from Class 1, which is the least developed and most 

challenging to hike, to Class 5, which is the most developed and 

easiest to hike. 

This recreation access trail is popular with hunters and anglers. The 

trail is easy (Class 4) with good conditions, dropping 100 feet in 

elevation along the one-mile length. It is good access to trout, salmon, 

and char fishing, and waterfowl hunting. Bears frequently fish there 

during the summer and fall. Picnic tables and fire rings are provided. 

The trailhead is 13 miles from Kake on Forest Road #6314. The trail 

leads from the road to Hamilton Creek. To the west lie the tidal flats 

of Hamilton Bay. The trail continues southeast, meandering upstream 

along the banks of the creek and leading to many fishing and 

waterfowl hunting sites. The trail is suitable for bicycles and there 

was observed bicycle use in 2006. The trailhead is outside the project 

area but about 1.25 miles from the nearest proposed unit. 

 This easy (Class 4) trail is 0.6 miles long and rises 75 feet along its 

length. The trail is good access for trout fishing, waterfowl hunting, 

and cross-country skiing. A boat is provided for fishing at Goose 

Hamilton Creek 

Trail 

Goose Lake Trail 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 197 

Lake. The trail can be used all year and takes about one hour for 

roundtrip hike. It is located about 11 miles from Kake on NFS Road 

6030. The trailhead is located about 3 miles outside the project area 

and 3.25 miles from the nearest proposed unit. Goose Lake itself is 

about 3.5 miles from the project area. 

This recreation access trail leads to the spectacular falls on Cathedral 

Falls Creek. It is only about 0.25 miles and drops sharply 100 feet in 

that distance. It is moderate difficulty (Class 3) and takes about 30 

minutes to hike roundtrip. The trailhead is about nine miles from 

Kake, eight miles on Road 6314 and one mile on Road 6312. The trail 

first passes through a small area thick with berries, then descends 

steeply to the creek. Cathedral Falls is a beautiful spot and popular for 

fishing. Many local Kake residents enjoy spending time there. No 

facilities are provided. The trail accesses trout and salmon fishing and 

photo opportunities at Cathedral Falls. The trail is approximately 2.25 

miles from the project area and 2.5 miles from the nearest proposed 

unit. 

This trail is often used by hunters and leads to Big John Bay and the 

recreation cabin there. It is 1.75 miles long and takes about two hours 

to hike roundtrip. It is moderate difficulty (Class 3) and accesses 

excellent waterfowl, grouse, and black bear hunting. The trailhead is 

about 16 miles from Kake on NFS Road 6314. It starts in a secondgrowth stand and then winds its way through old-growth spruce and 

hemlock forest. The trail ends at the beach on the north end of Big 

John Bay where the recreation cabin is located. This trail starts in the 

project area and ends west of the project area. About 0.25 miles are 

within the project area. The nearest proposed unit is 0.25 miles from 

the trailhead. 

Irish Lakes and Kluane Lake have no developed recreation facilities 

but are popular destinations for day use and camping often associated 

with hunting activities. Kluane Lake is not an official U. S. 

Geological Survey name but it is sometimes referred to as Kluane by 

the Forest. It is close to the main road so it is easily accessible without 

a developed trail. Irish Lakes is farther from the road but adventurous 

hikers can reach the lake by hiking about a mile cross-country from 

Road 45806. Actual use data is not available, but it is not believed 

people hike into the lake very often. More commonly, Irish Lakes is 

reached by float plane, either private or chartered. One permitted 

Special Use tent platform sits on the northwest edge of the lake. It is 

used seasonally for hunting and fishing. 

Cathedral Falls 

Trail 

Big John Bay 

Trail 

Irish Lakes and 

Kluane Lake 
3 Environment and Effects 

198  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The Kake road system is used to access recreational activities 

including sightseeing, picnicking, hiking, fishing, as well as hunting 

for black bear, moose, and deer. Black bear hunting on the road 

system in the last 10 years has resulted in harvests from 7 to 37 bears 

(Pers. Communication, Lowell 2008). 

Recreation Opportunities outside the 

Project Area 

Duncan Canal to the east of the project area is a popular recreation 

area for boaters, fishers, hunters, and campers. Several Forest Service 

cabins are located here including: Castle Flats Cabin, Castle River 

Cabin, (Castle River Trail connects the two cabins), Breiland Slough 

Cabin, Towers Arm Cabin, and Salt Chuck East Cabin. 

Towers Arm is about five miles from the nearest proposed unit; the 

Castle cabins are about six miles away; Salt Chuck East is about 7.5 

miles and Breiland Slough is over 10 miles from the nearest unit. 

Towers Arm is the least used cabin in Duncan Canal because of its 

limited access due to tides and lack of high quality fishing 

opportunities. 

Rocky Pass to the west of the project area is also popular with boaters, 

kayakers, fishers, and campers. The one recreation cabin there is 

Devils Elbow which is about 3 miles from the project boundary and 

about 9 miles from the nearest proposed unit. 

Bohemia Lake (locally known as Jamaica Lake) is located near the end 

of Road 6030 north of the project area. It has some local day use, as 

well as camping and hunting opportunities. 

Towers Lake, east of the project area, had a Forest Service cabin until 

recently when it was decommissioned. The site had very low use with 

few attractions and the cabin was seasonally threatened with flooding 

from the lake. 

Special Use Permits and Outfitter Guides 

One Special Use permit exists within the project area at Irish Lakes for 

a tent platform. It is permitted for personal recreation and hunting 

activities. Other intermittent hunting camps are found in the area but 

they are not permitted for year round storage of gear or materials. No 

permits have been issued for outfitter and guide activities within the 

project area. 

Kake Road 

System 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 199 

Big John Bay and Big John Bay Creek, just outside the project area, 

are popular areas for black bear outfitter/guide activities. In 2004, four 

black bear guides took hunters to Big John Bay and Big John Bay 

Creek. In 2007 and 2008, four guides operated in those areas. 

Environmental Consequences 

All of the action alternatives would modify the Recreation Opportunity 

Spectrum to some degree. In all three action alternatives, some areas in 

the Semi-primitive non-motorized setting would change to Roaded 

Modified with the proposed units and roads. In Alternatives 2 and 4, 

the effects would be minimal and the change in acres from a semiprimitive setting to a roaded setting would be less than one percent of 

the project area. 

Alternative 3 proposes some harvest units and roads in a currently 

primitive setting, so there would be decreases in both semi-primitive 

and primitive areas as well as expanded areas of roaded settings. The 

increase in the Roaded Modified setting would be 5.4% of the project 

area. The semi-primitive and primitive areas would decrease by 1.1% 

and 4.3% respectively. See Tables 3-58 and 3-59 below for changes in 

acres and percentages for each alternative. See Appendix A, in the 

Recreation Resource report, located in the project record, for maps 

showing where the changes would occur to ROS for each alternative. 

Effect to 

Recreation 

Opportunity 

Spectrum (ROS) 
3 Environment and Effects 

200  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Table 3-58. Recreation Opportunity Spectrum (ROS) Class 

Acres in the Project Area 

ROS Class Alt. 1 

 Acres 

Alt. 2 

Acres 

Alt. 3 

Acres 

Alt. 4 

Acres 

Roaded Modified (RM) 

36,984 

38,409 

(+1,425)

45,347 

(+8363) 

37,088 

(+104) 

Roaded Natural (RN) 2,833 2,833 2,833 2,833 

Semi-primitive 

Motorized (SPM) 2,666 2,666 2,666 2,666 

Semi-primitive 

Non-motorized (SPNM) 

71,427 

70,002 

(-1,425) 

69,617 

(-1,810) 

71,323 

(-104) 

Primitive (P) 38,607 38,607 

32,054 

(-6,553) 

38,607 

TOTAL ACRES 152,517 152,517 152,517 152,517
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 201 

Table 3-59. Recreation Opportunity Spectrum (ROS) 

Percentages in the Project Area 

ROS Class 

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

Roaded Modified 

(RM) 24.3% 25.2% 29.7% 24.3% 

Roaded Natural (N) 1.9% 1.9% 1.9% 1.9% 

Semi-primitive 

Motorized (SPM) 1.7% 1.7% 

1.7% 

1.7% 

Semi-primitive 

Non-motorized 

(SPNM) 

46.8% 45.9% 45.7% 46.8% 

Primitive (P) 

25.3% 

25.3% 21.0% 25.3% 

TOTAL 

PERCENTAGES 100% 100% 

 

100% 

 

100% 

Effects to Recreation Places and Sites 

within the Project Area 

The Big John Bay trailhead and approximately 1⁄4 mile of the trail are 

within the Central Kupreanof project area. Alternatives 2, 3, and 4 all 

propose harvest within a half-mile of the trailhead on Road 45001. 

Unit 313 would be about 0.25 miles from the trailhead and Units 310, 

312, and 314 are about 0.5 miles away from the trailhead. Trail users 

and cabin users that access the cabin by the trail would be affected by 

the sights and sounds of logging from these units for several weeks to 

a couple months. 

Alternatives 3 and 4 propose to harvest Unit 271 (22 acres) which is 

approximately 1.5 miles northeast of Irish Lakes. During the actual 

Big John Bay 

Trail and Cabin 

Irish Lakes 
3 Environment and Effects 

202  Chapter 3 Central Kupreanof Timber Harvest FEIS 

logging of Unit 271, the sound of machinery may be heard at Irish 

Lakes and at the permitted tent platform located on the northwest side 

of the lake. This would be a short-term effect lasting approximately 2-

3 weeks. 

Alternatives 2, 3, and 4 all propose units within a mile of the lake. 

Alternative 4 would have the least effect with only two units proposed 

near the lake; a 10-acre unit a half mile away (Unit 253) and a 41-acre 

unit one mile away (Unit 250). Alternative 2 would have a moderate 

effect with four units within one mile. Alternative 3 would have the 

most effect on recreation at the lake with seven units proposed within a 

mile and a new road proposed north of the lake. The sounds of 

logging and road building would be most apparent in Alternative 3, 

with nearly 300 acres of timber harvest proposed within one mile of 

the lake. Alternative 2 proposes about 220 acres within one mile of 

the lake and Alternative 4 proposes about 50 acres within one mile of 

the lake. 

During timber harvest and road construction activities in Alternatives 

2, 3, and 4, recreational activities that use the road system may be 

temporarily displaced to areas where no harvest activities are taking 

place. 

Effects to Recreation Opportunities 

outside the Project Area 

The three trails outside the project area (Cathedral Falls, Goose Lake, 

and Hamilton River) would not be directly affected by any of the 

alternatives, but hikers would notice an increase in traffic, especially 

log trucks, as they traveled the roads to the trailheads. This would be a 

short-term effect that would end when logging was complete. The 

increased log truck traffic would also affect access to the Big John Bay 

trail which is partially inside the project area. 

Visitors at Big John Bay Cabin would not be directly affected by the 

proposed timber harvest, especially if they accessed the cabin by water 

and did not use the trail. At the cabin, they may occasionally hear 

some distant sounds of logging. If the cabin users did hike the trail 

then the above effects to the trail could affect them. 

No outfitter/guides currently operate within the project area. The 

black bear hunting guides that operate out of Big John Bay and Big 

John Bay Creek would not be directly affected by any of the proposed 

harvest activities because they primarily operate from the water and 

shoreline. The distant sound of logging equipment or trucks may be 

apparent occasionally, but it would not noticeably change the 

recreation experience in Big John Bay and Creek. 

Kluane Lake 

Kake Road 

System 

Trails/Cabins 

 Outfitter/Guides 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 203 

Effects by Alternative 

For all alternatives, some Recreation Opportunity Spectrum (ROS) 

classes would not change. The Semi-primitive Motorized setting 

along the shoreline of Duncan Canal and the Roaded Natural setting 

along Road 6030 in the northern part of the project area would remain 

the same in all alternatives, including the No Action Alternative. 

Alternative 1 (No Action) proposes no new timber harvest or road 

building in the project area. The recreation in the area would remain 

as it is with no changes to existing Recreation Opportunity Classes 

(ROS). The settings at the existing Recreation Places at Irish Lakes 

and Kluane Lake would remain unchanged as well as the trails and 

cabin in the area. Roaded access in the area would not change from the 

current condition. 

Alternative 2 would have little effect to recreation. Most proposed 

units are within the Roaded Modified setting so the ROS class would 

not change. A few units are located just outside the roaded setting, 

however, causing about 1% of the area to change from a semiprimitive setting to a roaded setting. This alternative would not 

harvest any units near Irish Lake, but would harvest four units within a 

mile of Kluane Lake. This would detract from the recreation 

experience during the few months the logging was taking place. There 

would be 7.3 miles of new NFS road constructed, 2.9 miles of 

reconstructed road, and 3.9 miles of temporary road construction in 

this alternative. This would result in a moderate increase in roaded 

access in the area. However, the increase in motorized access would 

be temporary. All temporary roads would be decommissioned after 

timber harvest and all new and reconstructed NFS roads would be 

closed within ten years of timber harvest activities. An additional 1.1 

miles of existing NFS road would also be closed at this time. 

Alternative 3 proposes the most timber harvest and road building and 

would have the most effect to recreation. Some proposed units are 

within existing semi-primitive and primitive recreation settings, so the 

roaded setting would increase by about 5.5% and the semi-primitive 

and primitive settings would decrease by that amount. Recreationists at 

Kluane Lake would be affected by the nearby sights and sounds of 

timber harvest and road building for several months. Unit 254 (14 

acres) is a few hundred feet from the lake and would be the closest unit 

to the lake. Timber harvest of that unit would be very apparent to 

recreationists at the lake. Four other units within a mile of the lake 

would add to the sights and sounds of logging. One timber harvest 

unit (Unit 271) is also proposed about 1.5 miles from Irish Lakes. The 

sound of logging would most likely be heard at the lake during harvest 

of that unit also. 

Alternative 1 

Alternative 2 

Alternative 3 
3 Environment and Effects 

204  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The overall experience in the project area would still include a lot of 

semi-primitive and primitive opportunities as well as a slightly 

expanded roaded setting. 

There would be 25.1 miles of new NFS road constructed, 9.1 miles of 

reconstructed road and 6.1 miles of temporary road constructed. This 

alternative proposed the greatest increase in roaded access in the area. 

However, the increase in motorized access would be temporary. All 

temporary roads would be decommissioned after timber harvest and all 

new and reconstructed NFS roads would be closed within ten years of 

timber harvest activities. An additional 2.0 miles of existing NFS road 

would also be closed at this time. 

Alternative 4 would have the least effect to recreation of the three 

action alternatives. 

The recreation settings in the project area would remain essentially the 

same (less than 1/10 of 1% change) with only 104 acres changing from 

a semi-primitive setting to a roaded setting. Irish Lakes would not be 

affected by nearby timber harvest and Kluane Lake would only be 

minimally affected by two small nearby units. Recreationists at the 

lake would be aware of nearby activities for only a few weeks. 

This alternative proposes no new NFS road construction, 2.6 miles of 

road reconstruction and 2.2 miles of temporary road construction. 

This would result in the least increase in roaded access in the area. 

However, the increase in motorized access would be temporary. All 

temporary roads would be decommissioned after timber harvest and all 

new and reconstructed NFS roads would be closed within ten years of 

timber harvest activities. An additional 2.0 miles of existing NFS road 

would also be closed at this time. 

Cumulative Effects 

The Catalog of Past Events for Kupreanof Island was referenced in 

determining cumulative effects. The area analyzed for cumulative 

effects includes the project area plus the nearby recreation destinations 

of the four trails and one cabin. 

Recreation settings in Central Kupreanof Island have changed since 

timber harvest activities began in the late 1960’s (Kupreanof Catalog 

of Past Activities). The area now has numerous roads and timber in 

various age classes. Many of the original primitive and semi-primitive 

recreation settings have changed to more developed settings. People 

expect to see timber harvest in the area now. New harvest would add 

to the developed feel of the area, but would not be a big change from 

its current condition. The proposed activities for this project would 

not significantly change the existing recreation opportunities. 

Alternative 4 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 205 

Past projects that have enhanced recreation in the central Kupreanof 

vicinity include four trails: Goose Lake, Cathedral Falls, Hamilton 

River, and Big John Bay. The cabin at Big John Bay, although outside 

the project area, has enhanced recreation in the area because the 

trailhead to the cabin is within the project area on the road system to 

Kake. Cabin users sometimes use the road system and trail to access 

the cabin. Probably more often cabin users arrive at the Big John Bay 

cabin by boat or floatplane, especially out-of-town visitors. The 

construction of logging roads near Kluane Lake has increased 

recreation use at the lake because of the close access. 

The upcoming road project to reconstruct and improve the Kake to 

Seal Point road is outside the project area, but will enhance recreation 

on the whole road system by improving that section of road which is 

currently in very poor condition. The road improvements include 

paving the road and replacing two bridges on the seven-mile section of 

road. The Kake to Seal Point road is used to access all of the trails in 

the area and also the Big John Bay cabin. 

The Petersburg Ranger District is currently reanalyzing recreation 

carrying capacity and outfitter/guide allocations across the district. No 

significant changes are anticipated; however any effects will be 

analyzed in the Petersburg Outfitter Guide EA. 

The 6367 Small Timber Sale project planned for 2008 is just outside 

the project area on Road 6367. It would not noticeably add to the 

cumulative effects for recreation because it is on an existing road 

within a roaded modified recreation setting. 

The ongoing Access Travel Management process which is analyzing 

which roads to keep open, which roads to close, and which roads to 

allow Off-road Vehicle (ORV) use on, could have some effects on 

recreation in the project area. The current recommendations for the 

Central Kupreanof project area would have minimal effect on 

recreation because the 10 miles of road recommended for closure have 

little or no recreation use. These roads would be closed to vehicle 

traffic but would still allow foot traffic. Road management objective 

recommendations will be analyzed in the District’s ATM process. 

Environmental Consequences for Projects 

Common to All Action Alternatives 

The direct effect from the proposed trail maintenance projects would 

be to maintain and improve the recreation experience on the four trails 

in the area. It would also help maintain the safety of the trails for the 

public. Indirect effects could include an increase in traffic on the 

roads with well-maintained trails. 

Trail Maintenance 
3 Environment and Effects 

206  Chapter 3 Central Kupreanof Timber Harvest FEIS 

The effect of maintaining the Big John Bay cabin would also be to 

improve the recreation experience and safety of the cabin users. 

There would be no effects to recreation from the proposed invasive 

plant control project. 

There would be little effect to recreation from the proposed 

fisheries/hydrology project of pulling culverts on fish streams on 

closed roads. Walking the roads after the culverts were pulled would 

be somewhat more difficult, but still a likely activity. 

There would be no effects to recreation from the proposed 

silviculture/wildlife project of pre-commercial thinning second-growth 

stands. 

The proposed transportation project of maintaining the Kake area 

roads would enhance the recreation experience in the area and increase 

the safety of all drivers. 

There would be no significant effects to recreation from the proposed 

Microsales program. 

Cabin 

Maintenance 

Invasive Plant 

Control 

Fisheries/ 

Hydrology 

Silviculture/ 

Wildlife 

Transportation 

Microsales 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 207 

Heritage Resources 

Heritage resources include an array of historic and prehistoric 

archaeological sites and traditional cultural properties. The National 

Historic Preservation Act (NHPA) sets forth Government policy and 

procedures regarding these "historic properties" -- that is, districts, 

sites, buildings, structures and objects included in or eligible for the 

National Register of Historic Places. Section 106 of the NHPA 

requires that Federal agencies consider the effects of their actions on 

such properties, following regulations issued by the Advisory Council 

on Historic Preservation (36 CFR 800). 

The Section 106 review process seeks to consider historic preservation 

concerns with the needs of federal actions. Review occurs through 

consultation with Alaska State Historic Preservation Officer (SHPO), 

the Advisory Council on Historic Preservation (ACHP), Indian Tribes, 

and other parties with an interest in the effects of the undertaking on 

historic properties. One of the goals of consultation is to identify 

historic properties that potentially may be affected by the undertaking, 

assess potential effects and seek ways to avoid, minimize, or mitigate 

any adverse effects on historic properties. Forest Service 

archaeologists consulted with the Organized Village of Kake (OVK) 

and the Wrangell Cooperative Association (WCA), the tribal groups 

that are culturally affiliated with the project area. As part of our open 

working relationship with tribal groups regarding the protection of 

heritage resources, we met with OVK about the planned project and 

supplied both tribes with a copy of our Heritage Resource Report for 

comment (Esposito 2006). 

Forest Service archaeologists also conducted a heritage resource 

investigation of the Central Kupreanof project area to ensure that the 

procedural requirements of 36 CFR 800 were met. In accordance with 

the 2002 Programmatic Agreement among the Forest Service Alaska 

Region, the ACHP, and the SHPO, resource reports were submitted 

under modified 36 CFR 800 regulations implementing Section 106 of 

the National Historic Preservation Act. Heritage resource surveys did 

not result in the identification of any new sites and no known historic 

properties would be affected by project activities. 

Area of Potential Effects 

The Area of Potential Effect (APE) is the geographic area within 

which the effects of timber harvest and road construction may cause 

changes in the character or use of historic properties, if such properties 

exist. The APE was defined using the Central Kupreanof Timber 

Harvest’s project area boundary. 
3 Environment and Effects 

208  Chapter 3 Central Kupreanof Timber Harvest FEIS 

Existing Condition 

According to oral tradition and various ethnographic accounts, the 

Tlingit are the dominant native group of southeast Alaska. A majority 

of the Central Kupreanof project area lays within the traditional 

territory of the Kake Tlingit, who occupied the north half of Kuiu 

Island, the western portion of Kupreanof Island, with sporadic 

occupation along the mainland shore of Frederick Sound as well as 

parts of Baranof Island and Prince of Wales Island. The east side of 

the project area also lies within the traditional territory of the Stikine 

Tlingit, who occupied the mainland coast from Cape Fanshaw to the 

midpoint of Cleveland Peninsula, as well as the eastern portion of 

Kupreanof Island, the east coast of Prince of Wales Island from Red 

Bay to Thorne Bay, and all of Mitkof, Etolin, and Zarembo Islands. 

Prehistoric site types in the region include villages, seasonal camps, 

stone and wood stake fish weirs, as well as pictographs and 

petroglyphs. 

Kupreanof Island archaeological sites represent the typical array of site 

types in central southeast Alaska. These include both prehistoric and 

historic period sites some of which may date to several thousand years. 

Prehistoric site types on the island include camps, villages, forts, 

petroglyphs, as well as fish traps and weirs. Historic period sites 

include cabins, mining claims, fur farms, gardens, canneries, salteries, 

a driftwood canoe, and culturally modified trees (CMTs). Records 

show that there are no sites within the Central Kupreanof Project Area. 

Analysis and Survey Methods 

Prior to field investigation, various historical records and ethnographic 

accounts were examined to determine previous cultural use in the 

project area and its vicinity. We also researched prior heritage 

resource surveys, Petersburg/Wrangell Area heritage files and atlases, 

the Alaska Heritage Resource Survey (AHRS) listings, GIS 

archaeological site covers, and the Tongass Site database. OVK was 

consulted and queried about known or suspected sites in the area. 

There have been 75 heritage resource surveys on Kupreanof Island 

since 1974, five of which were conducted within the Central 

Kupreanof project area. These surveys were conducted between 1974 

and 2000, and include several investigations of proposed timber sales 

as well as a survey for a small mineral exploration project. 

In addition to the background research, archaeologists conducted a 

pedestrian survey of 251 acres of various types of terrain in search of 

undiscovered sites and other heritage resources. Proposed timber 

harvest units, proposed road locations were surveyed while paying 

special attention to fish streams, lake edges, and stands of Alaska 
Environment and Effects 3

Central Kupreanof Timber Harvest FEIS Chapter 3 209 

yellow cedar, resources that were used by the Tlingit people. Survey 

methods are based on a probability model developed over the past 

several decades. It is further described in the 2002 Programmatic 

Agreement. 

Direct and Indirect Effects by Alternative 

Heritage resource surveys did not result in the identification of any 

new sites and no known historic properties will be affected by project 

activities (Esposito 2006). None of the proposed action alternatives 

will have a direct or indirect effect upon known heritage resources 

within the APE. All of the planned timber harvest units and proposed 

roads are inland and on relatively steep terrain, making them within 

the low sensitivity zone for cultural resources. The existing log 

transfer facility (LTF) at Little Hamilton Bay will be used, and its use 

will not affect any known archaeological sites. 

Cumulative Effects 

Cumulative impacts to heritage resources on the Tongass may result 

from natural erosion, weathering, sedimentation and wind events as 

well as cultural processes such as public use, commercial 

development, timber harvest, and road construction. Logging and road 

access for hunting, subsistence use, and recreation are the primary 

activities that have occurred within the Central Kupreanof project area. 

The project area lies just 10 miles southeast of the city of Kake and is 

easily accessible to Kake residents and visitors via an extensive road 

system. As most of the recorded archaeological sites on the island are 

concentrated near the marine shore, outside of the project area 

boundary, the activities associated with the Central Kupreanof project 

will not have any cumulative effects to heritage resources. Timber 

harvest and increased road access would take place inland and on steep 

terrain. Heritage resource surveys for the project revealed there are no 

sites within the project area, and that site probability in this area is 

low. 

Additional foreseeable activities within the project area include 

Projects Common to all Action Alternatives, timber salvage 

Microsales, and the Kake roads analysis process (RAP). The Projects 

Common to all Action Alternatives are proposed to occur within 

previously disturbed areas, such as along the existing road and trail 

system or in harvested timber units, and will not affect heritage 

resources. 

Microsales are not expected to cause effects to heritage resources as 

they would target dead and/or downed trees adjacent to the existing 

road system. In accordance with 36 CFR 800.13(a) and (b)(1), should 
3 Environment and Effects 

210  Chapter 3 Central Kupreanof Timber Harvest FEIS 

any surface or subsurface heritage resources be encountered during 

land use activities, such activities shall cease immediately and the 

District Ranger shall be notified. If such properties are determined 

potentially eligible for the National Register of Historic Places and the 

project is determined to have adverse effects on the property, the 

Petersburg Ranger District archaeologist will address project effects 

and comply with Section 106 procedures before the project may 

proceed. 

The current RAP recommendations would have minimal effect on 

heritage resources, as there are no known sites within the project area. 

Future recommendations for road storage, decommissioning, closure 

and maintenance schedules will be analyzed in the District’s ATM EA. 

Intensive heritage resource surveys and site monitoring have been 

implemented since the 1980s. Current archaeological research and 

survey designs are based on the results of this work as well as more 

modern methodology and technology. These methods are designed to 

preserve and protect significant sites and provide information that will 

help guide future research and resource management. In addition, 

continued public education by the Forest Service to increase awareness 

concerning cultural resources and site stewardship assists the agency 

in effectively managing the region’s heritage sites. 

The Tongass Land Management Plan addresses the desired condition 

of heritage resources through a monitoring and evaluation plan. As 

specified in the Programmatic Agreement (2002), we monitor selected 

areas of direct impact during and/or after the actual ground 

disturbance. If inadvertent discoveries are made during project 

implementation, the Forest Service shall fulfill its consultation 

requirements in accordance with 36 CFR 800.13. Mitigation measures 

would be agreed upon and implemented before project activities may 

proceed. 
Chapter 4 

References and Lists
 Chapter 4 

Table of Contents 

Glossary ..........................................................1 

List of Preparers................................................33 

List of Recipients...............................................35 

References ......................................................39 

Index.............................................................52 
Glossary 

Access 

The opportunity to approach, enter, and make use of public lands.

Access Management 

Acquiring rights and developing and maintaining facilities needed 

by people to get to and move through public lands (physical 

attributes). 

Alaska National Interest Lands Conservation Act (ANILCA) 

Passed by Congress in 1980, this legislation designated 14 

National Forest Wilderness areas in Southeast Alaska. The Alaska 

National Interest Lands Conservation Act of December 2, 1980, 

Public Law 96-487, 96th Congress, 94 Stat. 2371-2551, Section 

810 requires evaluations of subsistence impacts before changing 

the use of these lands. 

Alaska Native Claims Settlement Act (ANCSA) 

Public Law 92-203, 92nd Congress, 85 Stat. 2371-2551. Approved 

December 18, 1971, Alaska Native Claims Settlement Act 

(ANCSA) provides for the settlement of certain land claims of 

Alaska Natives and for other purposes. 

All-terrain Vehicle (ATV) 

A gasoline powered, off-road vehicle used for accessing remote 

areas for recreational and work related activities: all terrain 

vehicles generally have high clearance, high traction, high 

maneuverability and low speed. See off-road vehicle. 

Alluvial Fan 

A cone-shaped deposit of organic and mineral material made by a 

stream where it runs out onto a level plain or meets a slower 

stream. 

Alternative 

One of several plans or projects proposed for decision making. 

Anadromous Fish 

Anadromous fish (such as salmon, steelhead, and sea-run cutthroat 

trout) that spend part of their lives in freshwater and part of their 

lives in saltwater. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 1
Annualized Job 

An annualized job is a full–time job lasting one year, or its 

equivalent. 

Annual Maintenance 

Work perfomred to maintain serviceability, or repair failures 

during the year in which they occur. Includes preventive and/or 

cyclic maintenance performed in the year in which it is scheduled 

to occur. Unscheduled or catastrophic failures of components or 

assets may need to be repaired as a part of annual maintenance. 

Background 

The distant part of a landscape. The seen or viewed area located 

from 3 or 5 miles to infinity from the viewer. (See "Foreground" 

and "Middleground".) 

Basal Area 

Total cross-sectional area of a tree or stand of trees. This is 

measured in diameter at breast height (DBH) and can be expressed 

in either square feet per acre or square meters per hectare. 

Beach Fringe 

The area inland from saltwater shorelines, which is typically 

forested. 

Best Management Practice (BMP) 

Practices used for the protection of water quality. BMPs are 

designed to prevent or reduce the amount of pollution from 

nonpoint sources or other adverse water quality impacts while 

meeting other goals and objectives. BMPs are standards to be 

achieved, not detailed or site- specific prescriptions or solutions. 

BMPs as defined in the USDA Forest Service Soil & Water 

Conservation Handbook are mandated for use in Region 10 under 

the Tongass Timber Reform Act. 

Biogeographic Province 

Twenty-one ecological subdivisions of Southeast Alaska that are 

identified by generally distinct ecological, physiographic, and 

biogeographic features. Plant and animal species composition, 

climate, and geology within each province are generally more 

similar within than among adjacent provinces. Historical events 

(such as glaciers and uplifting) are important to the nature of the 

province and to the barriers that distinguish each province. 

2 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Biological Diversity (Biodiversity) 

The variety of life in all its forms and at all levels. This includes 

the various kinds and combinations of: genes; species of plants, 

animals, and microorganisms; populations; communities; and 

ecosystems. It also includes the physical and ecological processes 

that allow all levels to interact and survive. The most familiar level 

of biological diversity is the species level, which is the number and 

abundance of plants, animals, and microorganisms. 

Blowdown 

See Windthrow. 

Board Foot (BF) 

A unit of wood 12" x 12" x 1". One acre of commercial timber in 

Southeast Alaska on the average yields 28,000-34,000 board feet 

per acre (ranging from 8,000-90,000 board feet per acre). One 

million board feet (MMBF) would be the volume of wood 

covering 1 acre 2 feet thick. One million board feet yields 

approximately enough timber to build 120 houses or 75,555 

pounds of dissolving pulp. 

Buffer 

An area of vegetation of varying size, shape, and character 

managed to mitigate effects on a particular resource.

Capability 

An evaluation of a resource's inherent potential for use. 

Clearcut 

Harvesting method in which all trees are cleared in one cut. It 

prepares the area for a new, evenaged stand. The area harvested 

may be a patch, stand, or strip large enough to be mapped or 

recorded as a separate age class in planning. 

Code of Federal Regulations (CFR) 

A codification of the general and permanent rules published in the 

Federal Register by the executive departments and agencies of the 

Federal Government. 

Connectivity 

A measure of the extent that forested areas between or outside 

reserves provide habitat for breeding, feeding, dispersal, and 

movement. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 3
Corridor 

Connective links of certain types of vegetation between patches of 

suitable habitat which are necessary for certain species to facilitate 

movement of individuals between patches of suitable habitat. Also 

refers to transportation, utility rights-of-way, or yarding. 

Cover 

Refers to trees, shrubs, or other landscape features that allow an 

animal to partly or fully conceal itself. 

Cruise 

Refers to the general activity of determining timber volumes and 

quality as opposed to a specific method. 

Cubic Foot (CF) 

Equivalent to a cube of wood with 1-foot sides. The cubic foot 

volume is a measure of the total sound wood in a tree and is a more 

accurate depiction of wood volume than the board foot measure. 

Cultural Resources 

The fragile and nonrenewable remains of human activity that are 

found in historic districts, sites, and buildings, and artifacts, and 

that are important in past and present human events. 

Culturally Modified Tree 

A tree that has been altered by human use as part of their 

traditional use of the forest, usually for the exploitation of bark and 

wood products. 

Culvert 

A conduit or passageway under a road, trail, or other obstruction. 

A culvert differs from a bridge in that the top of a culvert does not 

serve as the road surface and is constructed entirely below the 

elevation of the traveled way. 

Cumulative Effects 

The impacts on the environment resulting from additional 

incremental impacts of past, present, and reasonably foreseeable 

future actions regardless of what agency (Federal or non-Federal) 

or person undertakes such actions. Cumulative impacts can result 

from individually minor but collectively significant actions 

occurring over time. 

4 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Decommission 

For NFS roads, decommissioning removes the road from the longterm forest road transportation system. Otherwise, the act of 

decommissioning is the same for all roads. Action on the ground 

for decommissioning ranges from blocking the entrance and 

removing drainage structures to obliterating the road, returning the 

natural contours, and replanting vegetation. The end result is the 

stabilization and restoration of unneeded roads to a more natural 

state (36 CFR 212.1). See also Road Decommissioning. 

Degradation 

The general lowering of the surface of the land by erosive 

processes, especially by the removal of material through erosion 

and transportation by flowing water. 

Detrimental Soil Disturbance 

The condition where established threshold values of soil properties 

are exceeded and result in significant change or impairment to 

long-term soil productivity. (Also see the definitions for 

significant change and significant impairment.) 

Developed Recreation 

Recreation that requires facilities that, in turn, result in 

concentrated use of an area. Facilities in these areas might include 

roads, parking lots, picnic tables, toilets, drinking water, and 

buildings. 

Diameter Breast Height (DBH) 

The diameter of a tree measured 4 feet 6 inches from the ground. 

Direct Employment 

The jobs that are immediately associated with the timber sale, 

including, for example, logging, sawmills, and pulp mills. 

Direct Income 

Direct income is calculated from total payments an individual 

receives from his or her employment in a particular job category, 

over a defined time period. 

Draft Environmental Impact Statement (Draft EIS) 

A statement of environmental effects for a major Federal action 

which is released to the public and other agencies for comment and 

review prior to a final management decision. Required by Section 

102 of the National Environmental Policy Act (NEPA). 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 5
Ecosystem 

A community of organisms and its physical setting. An ecosystem, 

whether a fallen log or an entire watershed, includes resident 

organisms, non-living components such as soil nutrients, inputs 

such as rainfall, and outputs such as organisms that disperse to 

other ecosystems. 

Effects 

Effects, impacts, and consequences as used in this environmental 

impact statement are synonymous. Effects may be ecological (such 

as the effects on natural resources and on the components, 

structures, and functioning of affected ecosystems), aesthetic, 

historical, cultural, economic, or social, and may be direct, 

indirect, or cumulative. 

Direct Effects- Results of an action occurring when and where the 

action takes place. 

Indirect Effects- Results of an action occurring at a location other 

than where the action takes place and/or later in time, but in the 

reasonably foreseeable future. 

Cumulative Effects- See Cumulative Effects (above). 

Endangered Species 

Any species of animal or plant that is in danger of extinction 

throughout all or a significant portion of its range. Plant or animal 

species identified by the Secretary of the Interior as Endangered in 

accordance with the 1973 Endangered Species Act. See also 

Threatened Species, Sensitive Species. 

Erosion 

The wearing away of the land surface by running water, wind, ice, 

gravity, or other geological activities. 

Estimated Mill Capacity 

An estimate of the processing capability of the mill based on the 

amount of net sawlog volume that could be utilized by the mill, as 

currently configured, during a standard 250-day year, two shifts 

per day, annual operating schedule, not limited by the availability 

of employment, raw materials or market. 

Estuary 

Estuary refers to (in Southeast Alaska) the relatively flat, intertidal, 

and upland areas generally found at the heads of bays and mouths 

of streams. They are predominately mud and grass flats and are 

unforested except for scattered spruce or cottonwood. 

6 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Even-aged Management 

The application of a combination of actions that result in the 

creation of stands in which trees of essentially the same age grow 

together. The difference in age between trees forming the main 

canopy level of a stand usually does not exceed 20 percent of that 

age of the stand at harvest rotation age. Clearcut, shelterwood, or 

seed tree cutting methods produce even-aged stands. 

Executive Order 

An order or regulation issued by the President or some 

administrative authority under his or her direction. 

Existing Scenic Integrity (ESI) 

Current state of the landscape, considering previous human 

alterations. ESI levels are as follows: 

Very High- Landscapes where the landscape character is intact 

with only minute, if any, deviations. The existing landscape 

character and sense of place is expressed at the highest possible 

level. 

High- Landscapes where the landscape character “appears” intact. 

Deviations may be present but repeat form, line, color, texture, and 

pattern common to the landscape character so completely and at 

such scale that they are not evident. 

Moderate- Landscapes where the landscape character “appears 

slightly altered.” Noticeable deviations remain visually 

subordinate to the landscape being viewed. 

Low- Landscapes where the landscape character “appears 

moderately altered.” Deviations begin to dominate the landscape 

character being viewed, but borrow attributes such as size, shape, 

edge effect, and pattern of natural openings, vegetative type 

changes, or architectural styles outside the landscape being viewed. 

Very Low- Landscapes where the landscape character “appears 

heavily altered.” Deviations may strongly dominate the landscape 

character. They do not borrow from attributes such as size, shape, 

edge effect, and pattern of natural openings, vegetative type 

changes, or architectural styles within or outside the landscape 

being viewed. 

Unacceptable Low- Landscapes where the landscape character 

being viewed appears extremely altered. Deviations are extremely 

dominant and borrow little, if any, form, line, color, texture, 

pattern, or scale from the landscape character. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 7
Floodplain 

That portion of a river valley, adjacent to the river channel, which 

is covered with water when the river overflows its banks at flood 

stages. 

Foreground 

The stand of trees immediately adjacent to a scenic area, recreation 

facility, or forest highway; area located less than 1/4 mile from the 

viewer. See also Background and Middleground. 

Forest and Rangeland Renewable Resources Planning Act of 1976 

(RPA) 

Amended in 1976 by the National Forest Management Act. See 

RPA Assessment and Program. 

Forest or Forested Land 

Land at least 10 percent occupied by forest trees of any size or 

formerly having had such tree cover and not currently developed 

for non-forest use. 

Forested Wetland 

A wetland whose vegetation is characterized by an overstory of 

trees that are 20 feet or taller. 

Forest Plan 

Source of management direction for an individual forest, 

specifying activity and output levels for a period of 10 to 15 years. 

Management direction in the Forest Plan is based on the issues 

identified at the time of the plan’s development. 

Forest Road or Trail 

A road or trail wholly or partly within or adjacent to and serving 

the National Forest system that the Forest Service determines is 

necessary for the protection, administration, and utilization of the 

National Forest System and the use and development of its 

resources. 

Forest Transportation Atlas 

A display of the system of roads, trails, and airfields of an 

administrative unit. 

Forest Transportation Facility 

A forest road or trail or an airfield that is displayed in a forest 

transportation atlas, including bridges, culverts, parking lots, 

marine access facilities, safety devices, and other improvements 

appurtenant to the forest transportation system. 

8 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Forest Transportation System 

The system of National Forest System roads, National Forest 

System trails, and airfields on National Forest System lands. 

FSH 

Forest Service Handbook. 

FSM 

Forest Service Manual. 

Functional Class 

The way a road services land and resource management needs, and 

the character of service it provides. Three levels of Functional 

Class:

Arterial - Provides service to large land areas and usually connects 

with other arterial roads or public highways. 

Collector - Provides service to smaller land areas than an arterial 

road. It usually connects forest arterial roads to local forest roads 

or terminal facilities. 

Local - Connects terminal facilities with forest collector or arterial 

roads or public highways. Usually local roads are single purpose 

transportation facilities. 

Geographic Information System (GIS) 

An information processing technology to input, store, manipulate, 

analyze, and display spatial and attribute data to support the 

decision-making process. It is a system of computer maps with 

corresponding site-specific information that can be electronically 

combined to provide reports and maps. 

Geomorphology 

The study of the forms of the land surface and the processes 

producing them. Also the study of the underlying rocks or parent 

materials and the landforms present which were formed in 

geological time. 

Guideline 

A preferred or advisable course of action or level of attainment 

designed to promote achievement of goals and objectives. 

 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 9
Habitat 

The sum total of environmental conditions of a specific place 

occupied by an organism, population, or community of plants and 

animals. 

Habitat Capability 

The number of healthy animals that a habitat can sustain. Could be 

used in wildlife models to calculate rough population estimates for 

management indicator species. 

Heritage Resources 

See Cultural Resources. 

Historic Property 

Any prehistoric or historic district, site, building, structure, or 

object included in or eligible for inclusion on the National 

Register, including artifacts, records, and material remains related 

to such a property or resource. 

Hydric Soils 

Soils that formed under conditions of saturation, flooding, or 

ponding long enough during the growing season to develop 

anaerobic conditions in the upper part. 

Indirect Employment 

The jobs in service industries that are associated with the timber 

sale including, for example, suppliers of logging and milling 

equipment. 

Invasive Species 

A species that is non-native (or alien) to the habitat under 

consideration, and whose purposeful or accidental introduction 

causes, or is likely to cause, economic or environmental harm or 

harm to human health. 

Inventoried Roadless Area (IRA) 

See Roadless Area. 

Interdisciplinary Team (IDT) 

A group of people with different backgrounds assembled to 

research, analyze, and write a project Environmental Impact 

Statement. The team is assembled out of recognition that no one 

scientific discipline is sufficiently broad enough to adequately 

analyze a proposed action and its alternatives. 

10 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Issue 

A point, matter, or section of public discussion or interest to be 

addressed or decided. 

Jurisdiction 

The legal right or authority to control, operate, regulate use of, 

maintain, or cause to be maintained, a transportation facility, 

through ownership or delegated authority. The authority to 

construction or maintain such a facility may be derived from fee 

title, easement, written authorization, or permit from a Federal 

agency, or some similar method. 

Karst 

A type of topography that develops in areas underlain by soluble 

rocks, primarily limestone. Dissolution of the subsurface strata 

results in areas of well-developed, surface drainage that are 

sinkholes, collapsed channels, or caves. 

Land Allocation 

The decision to use land for various resource management 

objectives to best satisfy the issues, concerns and opportunities and 

meet assigned Forest output targets. 

Land Classification 

Forested land is classified under each of the land management 

alternatives according to how it relates to be management of the 

timber resource. The following are definitions of timber 

classifications used for this purpose. 

Land Use Designation (LUD) 

In the Forest Plan Amendment, a defined area of land specific to 

which management direction is applied. 

Landslides 

The moderately rapid to rapid downslope movement of soil and 

rock materials that may or may not be water-saturated. 

Large Woody Debris (LWD) 

A term used to describe logs, tree boles, rootwads, and limbs that 

are in or near the stream channel. Current usage of the term defines 

LWD as wood material equal to or greater than 0.1 meter in 

diameter and equal to or greater than 1 meter in length. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 11
Logging Systems 

Ground Based- A system of log transportation in which logs are 

pulled from the woods to a landing by means of a crawler tractor, 

skidder, or similar ground-based equipment. 

High Lead- A system of cable logging in which the working lines 

are elevated at the landing area by a rigged wooden tree of portable 

steel spar. 

Skyline- Asystem of cable logging in which all or part of the 

weight of the logs is supported during yarding by a suspended 

cable. 

Helicopter- A system of transporting logs from the woods to a 

landing as an external load on a helicopter. 

Log Transfer Facility (LTF) 

Formerly referred to as terminal transfer facilities, log transfer 

facilities include the site and structures used for moving logs and 

timber products from land-based transportation forms to waterbased transportation forms (or vice versa). 

MBF 

A thousand board feet net sawlog and utility volume. 

MMBF 

A million board feet net sawlog and utility volume. 

Management Indicator Species (MIS) 

Species selected in a planning process that are used to monitor the 

effects of planned management activities on viable populations of 

wildlife and fish, including those that are socially or economically 

important. 

Management Prescriptions 

Management practices and intensity selected and scheduled for 

application on a specific area (e.g., a land use designation) to attain 

multiple use and other goals and objectives. 

Management Requirement 

Standards for resource protection, vegetation manipulation, 

silvicultural practices, even-aged management, riparian areas, and 

soil and water and diversity, to be met in accomplishing National 

Forest System goals and objectives. 

12 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Maritime Climate 

Weather conditions controlled by an oceanic environment 

characterized by small annual temperature ranges and high 

precipitation. 

Microsale 

A microsale is a timber sale consisting of dead or down timber, 

which has been proposed by a prospective purchaser, and the 

District ranger agrees to offer for bidding using an informal 

advertisement, and short Bid Form. 

Middleground 

The visible terrain beyond the foreground where individual trees 

are still visible but do not stand out distinctly from the landscape; 

area located 1/4 to 5 miles from the viewer. See also “Foreground” 

and “Background”. 

Mineral Soils 

Soils consisting predominately of, and having its properties 

determined by, mineral material. 

Mitigation 

Measures designed to counteract environmental impacts or to make 

impacts less severe. These may include: avoiding an impact by not 

taking a certain action or part of an action; minimizing an impact 

by limiting the degree or magnitude of an action and its 

implementation; rectifying the impact by repairing, rehabilitating, 

or restoring the affected environment; reducing or eliminating the 

impact over time by preservation and maintenance operations 

during the life of the action; or compensating for the impact by 

replacing or providing substitute resources or environments. 

Mixed Conifer 

In Southeast Alaska, mixed conifer stands usually consist of 

western hemlock, mountain hemlock, Alaska yellow-cedar, 

Western redcedar, and Sitka spruce species. Shore pine may 

occasionally be present depending on individual sites. 

Model 

A representation of reality used to describe, analyze, or understand 

a particular concept. A model may be a relatively simple 

qualitative description of a system or organization, or a highly 

abstract set of mathematical equations. A model has limits to its 

effectiveness, and is used as one of several tools to analyze a 

problem. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 13
Monitoring 

A process of collecting information to evaluate whether or not 

objectives of a project and its mitigation plan are being realized. 

Monitoring can occur at different levels: to confirm whether 

mitigation measures were carried out in the manner called for, to 

determine whether the mitigation measures were effective, or to 

validate whether overall goals and objectives were appropriate. 

Different levels call for different methods of monitoring. 

Motor Vehicle 

Any vehicle which is self-propelled, other than: 

(1) A vehicle operated on rails; and 

(2) Any wheelchair or mobility device, including one that is 

battery-powered, that is designed solely for use by a mobilityimpaired person for locomotion, and that is suitable for use in an 

indoor pedestrian area. 

Motor Vehicle Use Map 

A map reflecting designated roads, trails, and areas on an 

administrative unit or a Ranger district of the National Forest 

system. 

Multiple Use 

The management of all the various renewable surface resources of 

the National Forest System so that they are used in the 

combination that will best meet the needs of the American people; 

harmonious and coordinated management of the various resources, 

each with the other, without impairment of the productivity of the 

land, with consideration being given to the relative values of the 

various resources. 

Muskeg 

In Southeast Alaska, a type of bog that has developed over 

thousands of years in depressions or flat areas on gentle to steep 

slopes. Also called peatlands. 

National Environmental Policy Act (NEPA) of 1969 

An Act to declare a national policy which will encourage 

productive and enjoyable harmony between humankind and the 

environment, to promote efforts which will prevent or eliminate 

damage to the environment and biosphere and stimulate the health 

and welfare of humanity, to enrich the understanding of the 

ecological systems and natural resources important to the Nation, 

and to establish a Council on Environmental Quality (The 

Principal Laws Relating to Forest Service Activities, Agricultural 

Handbook 453. USDA Forest Service, 359 pp.). 

14 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
National Forest Management Act (NFMA) 

A law passed in 1976 as an amendment to the Forest and 

Rangeland Renewable Resources Planning Act requiring the 

preparation of Regional Guides and Forest Plans and the 

preparation of regulations to guide that development. 

National Forest System Road 

A forest road other than a road which has been authorized by a 

legally documented right-of-way held by a State, conty or toehr 

local public road authority. NFS roads have in the past been 

referred to as “Forest Development Roads”, “classified”, “system” 

roads, or “specified” roads. 

National Forest System Trail 

A forest trail other than a trail which has been authorized by a 

legally documented right-of-way held by a State, county, or other 

local public road authority. A Motorized Trail is a route 50 inches 

or less in width or a route over 50 inches wide that is identified and 

managed as a trail. 

Native Selection 

Application by Alaska Native corporations and individuals to a 

portion of the USDI Bureau of Land Management for conveyance 

of lands withdrawn in fulfillment of Native entitlements 

established under Alaska Native Claims Settlement Act (ANCSA). 

Net Sawlog Volume 

Tree or log volume suitable in size and quality to be processed into 

lumber. 

No-action Alternative 

The most likely condition expected to exist in the future if current 

management direction were to continue unchanged. 

Non-forest Land 

See Timber Classification 

Notice of Intent (NOI) 

A notice printed in the Federal Register announcing that an 

environmental impact statement will be prepared. The NOI must 

describe the proposed action and possible alternatives, describe the 

agency's proposed scoping process, and provide a contact person 

for further information. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 15
Objective Maintenance Level (OBML) 

The maintenance level to be assigned at a future date considering 

future road management objectives, traffic needs, budget 

constraints, and environmental concerns. The objective 

maintenance level may be the same as, or higher or lower than, the 

operational maintenance level. 

Off-highway Vehicle 

Any vehicle which is restricted by law from operating on public 

roads for general motor vehicle traffic; includes: motorbikes, minibikes, trail bikes, snowmobiles, dune buggies, all-terrain vehicles, 

and four-whelel drive, high clearance vehicles. 

Old Growth Forest 

Ecosystems distinguished by old trees and related structural 

attributes. Old growth encompasses the later stages of forest stand 

development that typically differ from earlier stages in a variety of 

characteristics which may include larger tree size, higher 

composition, and different ecosystem function. The structure and 

function of an old-growth ecosystem will be influenced by its stand 

size and landscape position and context. 

Open Road Density 

The length of forest development roads open for public access and 

use per unit area of land; usually expressed as miles of open road 

per square mile of land. 

Operational Maintenance Level (OPML) 

The maintenance level currently assigned to a road considering 

today’s needs, road condition, budget constraints, and 

environmental concerns. It defines the level to which the road is 

currently being maintained. 

Organic Soils 

Soils that contain a high percentage (generally greater than 20 to 

30 percent) of organic matter throughout the soil depth. 

Parent Material 

The unconsolidated and partially weathered material from which 

upper layers of soil developed. 

Partial Cut 

Removal of only part of a stand for purposes other than 

regeneration of a new age class. Partial cutting is not considered a 

regeneration method. 

16 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Peak Flow 

The highest discharge of water recorded over a specified period of 

time at a given stream location. Often thought of in terms of spring 

snowmelt, summer, fall, or winter rainy season flows. Also called 

maximum flow. 

Permit 

A special use authorization which provides permission, without 

conveying an interest in land, to occupy and use national Forest 

System land or facilities for specified purposes, and which is both 

revocable and terminable. 

Precommercial Thinning 

The practice of removing some of the trees of less than marketable 

size from a stand in order to achieve various management 

objectives. See also Thinning. 

Process Group 

A combination of similar stream channel types based on major 

differences in landform, gradient, and channel shapes. 

 Productive Old Growth (POG) 

Old-growth forest capable of producing at least 20 cubic feet of 

wood fiber per acre per year, or having greater than 8,000 board 

feet per acre. 

Project Record 

A system that records decisions and activities that result from the 

process of developing a forest plan, revision, or significant 

amendment. 

Pruning 

The removal, close to the branch collar or flush with the stem, of 

side branches (live or dead) and multiple leaders from a standing 

tree. 

Public Participation 

Meetings, conferences, seminars, workshops, tours, written 

comments, responses to survey questionnaires, and similar 

activities designed and held to obtain comments from the public 

about Forest Service activities. 

Rare Plants 

Rare plants are defined as those plants included on the Alaska 

Natural Heritage Program (ANHP) Vascular Plant Tracking List 

(ANHP, 2006) with a ranking of S1 or S2. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 17
Record of Decision 

A document separate from but associated with an environmental 

impact statement which states the decision, identifies all 

alternatives, specifying which were environmentally preferable, 

and states whether all practicable means to avoid environmental 

harm from the alternative have been adopted, and if not, why not. 

Recreation Opportunity Spectrum (ROS) 

A system for planning and managing recreation resources that 

categorizes recreation opportunities into six classes. Each class is 

defined in terms of the degree to which it satisfies certain 

recreation experience needs based on the extent to which the 

natural environment has been modified, the type of facilities 

provided, the degree of outdoor skills needed to enjoy the are and 

the relative density of recreation use. The Central Kupreanof 

project area contains five of the seven categories. 

Primitive- An unmodified environment generally greater than 

5,000 acres in size and located generally at least 3 miles from all 

roads and other motorized travel routes. A very low interaction 

between users (generally less than 3 group encounter per day) 

results in a very high probability of experiencing solitude, 

freedom, closeness to nature, tranquility, self-reliance, challenge, 

and risk. Evidence of other users is low. Restrictions and controls 

are not evident after entering the land unit. Motorized use is rare. 

Semi-primitive Non-motorized – A natural or natural-appearing 

environment generally greater than 2,500 acres in size and 

generally located at least 0.5 mile (greater or less depending on 

terrain and vegetation, but no less than o.25 mile) but not further 

than 3 miles from all roads and other motorized travel routes. 

Concentration of users is low (generally less than 10 group 

encounter per day), but there is often evidence of other users. 

There is a high probability of experiencing solitude, freedom, 

closeness of nature, tranquility, self-reliance, challenge, and risk. 

There is a minimum of subtle on-site controls. No roads are 

present in the area. 

Semi-primitive Motorized – A natural or natural-appearing 

environment generally greater than 2,500 acres in size and 

generally located within 0.5 mile of primitive roads and other 

motorized travel routes used by motor vehicles; but not closer than 

0.5 mile (greater or less depending on terrain and vegetation, but 

no less than o.25 miles) from better-than-primitive roads and other 

motored travel routes. Concentration of users is low (generally 

less than 10 group encounters per day), but there is often evidence 

of other users. There is a moderated probability of experiencing 

solitude, closeness to nature, and tranquility along with a high 

18 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
degree of self-reliance, challenge, and risk in using motorized 

equipment. Local roads may be present, or along saltwater 

shorelines there may be extensive boat traffic. 

Roaded Modified – Vegetative and landform alterations typically 

dominate the landscape. There is little on-site control of users 

except for gated roads. There is moderate evidence of other users 

on roads ( generally less than 20 group encounters per day), and 

little evidence of others or interactions at campsites. There is 

opportunity to get away from others but with easy access. Some 

self-feeling of independence and freedom exists with little 

challenge and risk. Recreation users will likely encounter timber 

management activities. 

Roaded Natural- Resource modification and utilization are 

evident, in a predominantly naturally-appearing environment 

generally occurring with 0.5 mile (great or less depending on 

terrain and vegetation, but no less than 0.25 mile) from better-thanprimitive roads and other motorized travel routes. Interactions 

between users may be moderate to high (generally less than 20 

group encounters per day), with evidence of there users prevalent. 

There is an opportunity to affiliate with other users in developed 

sites but with some chance for privacy. Self-reliance on outdoor 

skills is only of moderate importance with little opportunity for 

challenge and risk. Motorized use is alloRed Pipes. 

Red CulvertsPassage barriers to various life stages of fish, generally culverts 

placed improperly. 

Reforestation 

The natural or artificial restocking of an area with trees. 

Regeneration 

The process of establishing a new crop of trees on previously 

harvested land. 

Reserve Trees 

Merchantable or submerchantable trees and snags that are left 

within the harvest unit to provide biological habitat components 

over the rotation. 

Resident Fish 

Fish that are not anadromous and that reside in freshwater on a 

permanent basis. Resident fish include non-anadromous Dolly 

Varden char and cutthroat trout. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 19
Responsible Official 

The Forest Service employee who has the delegated authority to 

make a specific decision. 

Restoration 

The process of assisting the recovery of an ecosystem that has been 

degraded, damaged, or destroyed. The concept of ecological 

restoration is forward-looking. Restoration focuses on 

reestablishing composition, structure and ecological processes to 

maintain or increase resilience of terrestrial and aquatic ecosystems 

in a dynamic, continually evolving world (ecology definition). 

Revegetation 

The re-establishment and development of a plant cover. This may 

take place naturally through the reproductive processes of the 

existing flora or artificially through the direct action of 

reforestation or reseeding. 

Riparian Area 

Area with distinctive resource values and characteristics that 

contain elements of aquatic and riparian ecosystems, which can be 

geographically delineated. 

Riparian Management Area (RMA) 

The area including water, land and plants adjacent to perennial 

streams, lakes, and other bodies of water that is managed for the 

inherent qualities of the riparian ecosystem. 

Road 

A motor vehicle route over 50 inches wide, unless identified and 

managed as a trail. 

Road Closure 

See Road Storage. 

Road Construction 

Supervising, inspecting, actual building, and incurrence of all costs 

incidental to the construction of a road. 

Road Decommissioning 

Activities that result in the stabilization and restoration of 

unneeded roads to a more natural state. The term generally refers 

to temporary roads constructed for timber harvests that have had 

stream courses restored, culverts removed, waterbars added where 

needed, and cut and fill slopes revegitated. 

20 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Road Maintenance 

The ongoing upkeep of a road, necessary to retain or restore the road to 

the approved road Management objective (FSM 7712.3). Periodic 

repairs to an existing road surface, brushing, and cleaning and 

repairing drainage features. These tasks are performed to keep the 

roads in the safe and useful condition for which they were 

designed. Repairs may be done as annual maintenance. 

Road Maintenance Levels 

The level of service maintained for a specific road, consistent with 

road Management objectives and maintenance criteria. 

 Maintenance Level 1- Assigned to intermittent service roads 

during the time they are closed to vehicular traffic. The closure 

period must exceed 1 year. Basic custodial maintenance is 

performed to keep damage to adjacent resource to an acceptable 

level and to perpetuate the road to facilitate future management 

activities. Emphasis is normally given to maintaining drainage 

facilities and runoff patterns. Planned road deterioration may occur 

at this level. Appropriate traffic management strategies are 

"prohibit" and "eliminate". Roads receiving level 1 maintenance 

may be of any type, class or construction standard, and may be 

managed at any other maintenance level during the time they are 

open for traffic. However, while being maintained at level 1, they 

are closed to vehicular traffic, but may be open and suitable for 

non-motorized uses. 

Maintenance Level 2- Assigned to roads open for use by high 

clearance vehicles. Passenger car traffic is not a consideration. 

Traffic is normally minor, usually consisting of one or a 

combination of administrative, permitted, dispersed recreation, or 

other specialized uses. Log haul may occur at this level. 

Appropriate traffic management strategies are either to (1) 

discourage or prohibit passenger cars or (2) accept or discourage 

high clearance vehicles. 

Maintenance Level 3- Assigned to roads open and maintained for 

travel by a prudent driver in a standard passenger car. User comfort 

and convenience are not considered priorities. Roads in this 

maintenance level are typically low speed, single lane with 

turnouts and spot surfacing. Some roads may be fully surfaced 

with either native or processed material. Appropriate traffic 

management strategies are either "encourage" or "accept." 

"Discourage" or "prohibit" strategies may be employed for certain 

classes of vehicles or users. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 21
Maintenance Level 4- Assigned to roads that provide a moderate 

degree of user comfort and convenience at moderate travel speeds. 

Most roads are double lane and aggregate surfaced. However, 

some roads may be single lane. Some roads may be paved and/or 

dust abated. The most appropriate traffic management strategy is 

"encourage." However, the "prohibit" strategy may apply to 

specific classes of vehicles or users at certain times. 

Maintenance Level 5- Assigned to roads that provide a high 

degree of user comfort and convenience. These roads are normally 

double-lane, paved facilities. Some may be aggregate surfaced and 

dust abated. The appropriate traffic management strategy is 

"encourage." 

Road Management Objective (RMO) 

Defines the intended purpose of an individual road based on 

Management Area direction and access management directives. 

Road Storage 

Remove or bypass all drainage structures to restore natural 

drainage patterns, add water bars as needed to control runoff, 

revegetate. Storage is intended to be the primary maintenance 

strategy on intermittent use roads (ML1) during their closure cycle. 

Road storage is defined in FSH 5409.17 as “the process/action of 

closing a road to motorized vehicle traffic and placing it in a 

condition that requires minimum maintenance to protect the 

environment and preserve the facility for future use.” In this 

strategy, the bridges and culverts on live streams may be 

completely removed to restore natural drainage patterns. Cross 

drains and ditch relief culverts will be bypassed with deep water 

bars but may be left in place to minimize the cost of re-using these 

roads in the future. Roads in storage are left in a self-maintaining 

state in order to use more road maintenance funds on the open 

drivable roads on the island. Maintenance Level 1, closure and 

basic custodial maintenance, is assigned. Roads in storage are 

considered part of the long-term forest road transportation system 

and may be opened to vehicular traffic in the future. 

It should be noted that the ML 1 level of closure is different than 

the one defined in the Alaska Forest Resources and Practices Act 

(AFRPA). Road storage as discussed fit the AFRPA “inactive” 

definition. 

22 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Roadless Area 

An area of undeveloped public land within which there are no 

improved roads maintained for travel by means of motorized 

vehicles intended for highway use. Inventoried roadless areas 

(IRAs) are undeveloped areas typically exceeding 5,000 acres that 

meet the minimum criteria for wilderness consideration under the 

Wilderness Act. 

Rotation 

The planned number of years (100-200 years in Alaska) between 

the time that a forest stand is regenerated and its next cutting at a 

specified stage of maturity. 

Sacred Site 

Any specific, discrete, narrowly delineated location on Federal 

land that is identified by an Indian tribe, or Indian individual 

determined to be an appropriately authoritative representative of an 

Indian religion, as sacred by virtue of its established religious 

significance to, or ceremonial use by, an Indian religion; provided 

that the tribe or appropriately authoritative representative of an 

Indian religion has informed the agency of the existence of such a 

site. 

Sawlog 

That portion of a tree that is suitable in size and quality for the 

production of dimension lumber collectively known as sawtimber. 

Scenic Integrity Objective (SIO) 

A desired level of scenic quality and diversity of natural features 

based on physical and sociological characteristics of an area. 

Refers to the degree of acceptable alterations of the characteristic 

landscape. The adopted SIO is the SIO to be achieved as a result 

of management direction identified in the approved Forest Plan. 

SIOs are described below: 

Very High- Landscapes where the landscape character is intact 

with only minute, if any, deviations. The existing landscape 

character and sense of place is expressed at the highest possible 

level. 

High- Landscapes where the landscape character “appears” intact. 

Deviations may be present but repeat form, line, color, texture, and 

pattern common to the landscape character so completely and at 

such scale that they are not evident. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 23
Moderate- Landscapes where the landscape character “appears 

slightly altered.” Noticeable deviations remain visually 

subordinate to the landscape being viewed. 

Low- Landscapes where the landscape character “appears 

moderately altered.” Deviations begin to dominate the landscape 

character being viewed, but borrow attributes such as size, shape, 

edge effect, and pattern of natural openings, vegetative type 

changes, or architectural styles outside the landscape being viewed. 

They should not only appear as valued character outside the 

landscape being viewed but compatible or complimentary to the 

character within. 

Very Low- Landscapes where the landscape character “appears 

heavily altered.” Deviations may strongly dominate the landscape 

character. They may not borrow from attributes such as size, 

shape, edge effect, and pattern of natural openings, vegetative type 

changes, or architectural styles within or outside the landscape 

being viewed. However, deviations must be shaped and blended 

with the natural terrain so that elements such as unnatural edges, 

roads, landings, and structures do not dominate the composition. 

Scheduled Lands 

Land suitable and scheduled for timber production and which are 

in the land base for the calculation of the allowable sale quantity 

and long-term sustained yield timber capacity. 

Scoping Process 

Early and open activities used to determine the scope and 

significance of a proposed action, what level of analysis is 

required, what data is needed, and what level of public 

participation is appropriate. Scoping focuses on the issues 

surrounding the proposed action, and the range of actions, 

alternatives, and impacts to considered in an EA or an EIS. 

Sediment 

Solid material, both mineral and organic, that is in suspension, is 

being transported, or has been moved from its site of origin by air, 

water, gravity, or ice and has come to rest on the earth's surface. 

24 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Sensitive Species 

Plant and animal species which are susceptible or vulnerable to 

activity impacts or habitat alterations. Those species that have 

appeared in the Federal Register as proposed for classification or 

are under consideration for official listing as endangered or 

threatened species, that are on a non-official State list, or that are 

recognized by the Regional Forester as needing special 

management to prevent placement on Federal or State lists. 

Service Life 

The length of time that a facility is expected to provide a specified 

service. 

Long Term Service- Continuous or annual recurrent service. 

Intermittent Term Service- A road which is closed to wehicle 

tradffic between periods of use. The closed period must exceed 

one year. 

Intermittent Stored Service- Intermittent service road, closed to 

traffic. The road is in a condition that there is little resource risk if 

maintenance is not performed (self-maintaining). 

Short Term Service- Short term use (including temporary roads). 

Silviculture 

The science of controlling the establishment, composition, and 

growth of forests. 

Soil Productivity 

The capacity of a soil, in its normal environment, to produce a 

specific plant or sequence of plants under a specific system of 

management. 

Sortyard 

A location used to sort grades, types, and size of logs. 

Spawning Area 

The available area in a streamcourse which is suitable for the 

deposition and incubation of salmon or trout eggs. 

Stand (Tree Stand) 

An aggregation of trees occupying a specific area and sufficiently 

uniform in composition, age arrangement, and condition as to be 

distinguishable from the forest in adjoining areas. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 25
Standard 

A course of action or level of attainment required by the 2008 

Forest Plan to promote achievement of goals and objectives. 

State Historic Preservation Officer (SHPO) 

State-appointed official who administers Federal and State 

programs for cultural resources. 

Stocking 

The degree of occupancy of land by trees as measured by basal 

area or number of trees and as compared to a stocking standard; 

that is, the basal area or number of trees required to fully use the 

growth potential of the land. 

Storm Proof 

Provide water bars, rolling dips, out sloping, etc., to assure 

controlled runoff until any needed maintenance can be performed 

on the primary drainage system. Control roadside brush to 

maintain passage. An intermediate maintenance strategy is to 

storm proof, or to stabilize the road by providing roadway features 

such as driveable water bars and out sloping to control runoff in 

case the primary drainage system of culverts and ditches is 

overwhelmed during a storm event. Each culvert will be evaluated 

as to where the water would go if the culvert were to fail to carrry 

the high flow. A water bar or out slope at this location will 

minimize the potential for erosion of long stretches of ditch line or 

roadway. This is intended to be the primary maintenance strategy 

applied to roads assigned Maintenance Level 2. 

Stream Classes 

Class I- Streams and lakes with anadromous (migrating from the 

ocean) or adfluvial (migrating from lakes) fish or fish habitat; or, 

high quality resident fish waters, or habitat above fish migration 

barriers known to provide reasonable enhancement opportunities 

for anadromous fish. 

Class II- Streams and lakes with resident fish or fish habitat and 

generally steep (6 to 25 percent or higher) gradients where no 

anadromous fish occur, and otherwise not meeting class I criteria. 

Class III- Streams are perennial and intermittent streams that have 

no fish populations or fish habitat, but have sufficient flow or 

sediment and debris transport to directly influence downstream 

water quality or fish habitat capability. 

26 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Class IV- Other intermittent, ephemeral, and small perennial 

channels with insufficient flow or sediment transport capabilities to 

directly influence downstream water quality or fish habitat 

capability. Class IV streams are too small to be mapped on aerial 

photographs, thus they appear only where field mapping has taken 

place. 

Stream Order 

First-order streams are the smallest unbranched tributaries; secondorder streams are initiated by the point where two first-order 

streams meet; third-order streams are initiated by the point where 

two second-order streams meet, and so on. 

Structural Diversity 

The diversity of forest structure, both vertically and horizontally, 

which provides for a variety of forest habitats such as logs and 

multi-layered forest canopy for plants and animals. 

Stumpage 

The value of timber as it stands uncut in terms of dollar value per 

thousand board feet. 

Subsistence 

Section 803 of the Alaska National Interest Lands Conservation 

Act defines subsistence use as "the customary and traditional uses 

by rural Alaska residents of wild renewable resources for direct, 

personal or family consumption as food, shelter, fuel, clothing, 

tools, or transportation; for the making and selling of handicraft 

articles out of nonedible by-products of fish and wildlife resources 

taken for personal or family consumption; for barter, or sharing for 

personal or family consumption; and for customary trade." 

Subsistence Use Area 

Important subsistence use areas include the "most reliable" and 

"most often hunted" categories from the Tongass Resource Use 

Cooperative Survey (TRUCS) and from subsistence survey data 

from ADF&G, the University of Alaska, and the Forest Service, 

Region 10. Important use areas include both intensive and 

extensive use areas for subsistence harvest of deer, furbearers, and 

salmon. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 27
Substrate 

The type of material in the bed (bottom) of rivers and streams. 

Succession 

The ecological progression of community change over time, 

characterized by displacements of species leading towards a stable 

climax community. 

Suitable 

Commercial forest land identified as having both the biological 

capability and availability to produce industrial wood products. 

Suspended Sediment 

The very fine soil particles which remain in suspension in water 

for a considerable period of time without contact with the stream 

or river channel bottom. 

Sustained Yield 

The amount of renewable resources that can be produced 

continuously at a given intensity of management. 

Temporary Road or Trail 

A road of trail necessary for emergency operations or authorized 

by contract, permit, lease, or other written authorization that is not 

included in a forest transporation atlas. For National Forest system 

timber slaes, temporary roads are constructed to harvest timber on 

a one-time basis, and are decomissioned after harvest operations 

are complete. 

Thinning 

The practice of removing some of the trees in a stand so that the 

remaining trees will grow faster due to reduced competition for 

nutrients, water, and sunlight. Thinning may also be done to 

change the characteristics of a stand for wildlife or other purposes. 

Thinning may be done at two different stages – Precommercial 

Thinning or Commercial Thinning (see definitions in this section). 

Threatened Species 

Plant or animal species which is likely to become endangered 

throughout all or a significant portion of its range within the 

foreseeable future, as defined in the Endangered Species Act of 

1973, and which has been designated in the Federal Register by the 

Secretary of the Interior as a Threatened Species. See also 

Endangered Species, Sensitive Species. 

28 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Threshold 

The point or level of activity beyond which an undesirable set of 

responses begins to take place within a given resource system. 

Tiering 

Eliminating repetitive discussions of the same issue by 

incorporating by reference. The general discussion in an 

environmental impact statement of broader scope; e.g., this 

document is tiered to the Tongass Land and Resource Management 

Plan FEIS. 

 Timber Appraisal 

Establishing the fair market value of timber by taking the selling 

value minus manufacturing costs, the cost of getting logs from the 

stump to the manufacturer, and an allowance for profit and risk. 

Commercial Forest: Forest land tentatively suitable for the 

production of continuous crops of timber and that has not been 

withdrawn. 

Nonforest: Land that has never supported forests and land 

formerly forested where use for timber production is precluded by 

development or other uses. 

Forest: Land at least 10 percent stocked (based on crown cover) 

by forest trees of any size, or formerly having had such tree cover 

and not currently developed for nonforest use. 

Suitable and Available: Land to be managed for timber 

production on a regulated basis. 

Unsuitable: Forest land withdrawn from timber utilization by 

statute or administrative regulation (for example, wilderness), or 

identified as inappropriate for timber production in the Forest 

planning process. 

Timber Harvest Unit 

A timber harvest unit (or simply, "unit") is a portion of a timber 

sale within which Forest Service specifies for harvest all or part of 

the timber to meet the requirements of a timber sale contract. 

Tongass Timber Reform Act (TTRA) 

This Act (1990) requires annual appropriations for timber 

management on the Tongass National Forest, with a provision 

providing for the multiple use and sustained yield of all renewable 

forest resources. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 29
Trail 

A route 50 inches or less in width or a route over 50 inches wide 

that is identified and managed as a trail. 

Turbidity 

An expression of the optical quality that causes light to be 

scattered and absorbed rather than transmitted in a straight line 

through the water sample. Turbidity is caused by the presence of 

suspended sediment. 

Two-aged Management 

A silvicultural method in which the majority of the trees in a 

harvest unit are cut in one entry, and the rest are left as residual 

tree, either singly or in patches. The residual trees remain 

unharvested to provide structural diversity and older-aged trees 

within the second-growth stand. 

Unauthorized Road or Trail 

A road or trail that is not a forest road or trail or a temporary road 

or trail and that is not included in a forest transportation atlas. 

Non-system roads include roads that have been decommissioned as 

well as roads now called unauthorized roads. Thus, unauthorized 

roads in this EIS include some decommissioned roads. 

Understory 

The trees and shrubs in a forest growing under the canopy or 

overstory. 

Uneven-aged Management 

Forest management techniques which simultaneously maintain 

continuous high-forest cover, recurring regeneration of desirable 

species, and the orderly growth and development of trees through a 

range of diameter or age classes. Cutting is usually regulated by 

specifying the number or proportion of trees of particular sizes to 

retain within each area, thereby maintaining a planned distribution 

of size classes. Single tree selection and group selection harvest 

methods create or maintain uneven-aged stands. See also “Partial 

Cut”. 

Unsuitable 

See Timber Classification. 

Utility Logs 

Those logs that do not meet sawlog grade but are suitable for 

production of firm usable pulp chips. 

30 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Value Comparison Unit (VCU) 

Areas which generally encompass a drainage basin containing one 

or more large stream systems; boundaries usually follow easily 

recognizable watershed divides. Established to provide a common 

set of areas where resource inventories could be conducted and 

resource interpretations made. 

Viable Population 

The number of individuals of a species required to ensure the longterm existence of the species in natural, self-sustaining populations 

adequately distributed throughout their region. 

Viewshed 

An expansive landscape or panoramic vista seen from a road, 

marine waterway, or specific viewpoint. 

V-Notches 

A deeply incised valley along some waterways that would look 

like a "V" from a cross-section. These abrupt changes in terrain 

features are often used as harvest unit or yarding boundaries. 

Volume 

Stand volume based on standing net board feet per acre by 

Scribner Rule. 

Volume Strata 

Categories of timber volume derived from the timber type data 

layer (TIMTYP) and the common land unit data layer (CLU). 

Three volume strata (low, medium, and high) are recognized in the 

Forest Plan. 

Watershed 

The area that contributes water to a drainage or stream. Portion of 

the forest in which all surface water drains to a common point. 

Watersheds can range from a few tens of acres that drain a single 

small intermittent stream to many thousands of acres for a stream 

that drains hundreds of connected intermittent and perennial 

streams. 

Wetlands 

Areas that are inundated or saturated by surface or groundwater at 

a frequency and duration sufficient to support, and that under 

normal circumstances do support, a prevalence of vegetation 

typically adapted to life in saturated soil conditions. Wetlands 

generally include swamps, marshes, bogs, and similar areas. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 31
Wildlife Analysis Area (WAA) 

A division of land used by the Alaska Department of Fish and 

Game for wildlife analysis. 

Windfirm 

Trees that have been exposed to the wind throughout their life and 

have developed a strong root system or trees that are protected 

from the wind by terrain features. 

Windthrow 

The act of trees being uprooted by the wind. In Southeast Alaska, 

Sitka spruce and hemlock trees are shallow rooted and susceptible 

to windthrow. There are generally are three types of windthrow: 

Endemic: where individual trees are blown over; 

Catastrophic: where a major windstorm can blow down hundreds 

of acres; and 

Management Related: where the clearing of trees in an area make 

the adjacent standing trees vulnerable to windthrow. 

Yarding 

The process of conveying logs from the stump to a landing 

location. 

32 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
List of Preparers 

Tiffany Benna 

Position: Interdisciplinary Planning Team Leader (from April 

2007) 

Experience: 81⁄2 years with the Forest Service 

Education: BA English/Creative Writing and Poetry 

Ben Case 

Position: Forester (May 2007) 

Experience: 15 years with the Forest Service 

Education: BS Forest Management 

Carey Case 

Position: Writer/Editor (May 2007) 

Experience: 10 years with the Forest Service 

Education: BA Political Science 

Mary Clemens 

Position: Recreation Planner 

Experience: 25 years with the Forest Service 

Education: BS Forest Management 

Gina Esposito 

Position: Archaeologist 

Experience: 10 years with the Forest Service 

Education: BA Anthropology 

Crystal Harlan 

Position: Fish Biologist 

Experience: 51⁄2 years with the Forest Service 

Education: BS Biology with a Concentration in Marine Science 

Alan Murph 

Position: Transportation Planner 

Experience: 28 years professional experience (9 years with the 

Forest Service) 

Education: BS Civil Engineering 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 33
Madonna Parks 

Position: Geographic Information Systems Technician 

Experience: 17 years with the Forest Service 

R.D. Parks 

Position: Silviculturist 

Experience: 27 years professional experience, 18 years with the 

Forest Service 

Education: BS Forestry 

Charles Parsley 

Position: Wildlife Biologist 

Experience: 20 years with the Forest Service 

Education: BS Wildlife Science, MS Fisheries 

Gene Primaky 

Position: Geographic Information Systems Technician 

Experience: 16 years with the Forest Service 

Education: Certificate of Forestry, AV Tech 

Jane Smith 

Position: Archaeologist 

Experience: 23 years professional experience (16 years with the 

Forest Service) 

Education: BS Anthropology 

Jim Steward 

Position: Landscape Architect 

Experience: 24 years with the Forest Service 

Heath Whitacre 

Position: Hydrologist (Dec 2006 - present) 

Experience: 7 years with the Forest Service 

Education: BA Environmental Biology, MS Watershed Science 

Marina Whitacre 

Position: Writer/Editor (April 2007 - present) 

Experience: 4 years with the Forest Service 

Education: BA Biology, MS Range Science 

34 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
List of FEIS Recipients 

The following agencies, organizations, and individuals were provided 

with a copy of the Central Kupreanof Timber Harvest Final 

Environmental Impact Statement. 

Agencies 

Alaska Department of Fish and 

Game, Division of Wildlife 

Conservation 

Alaska Department of Fish and 

Game- Division of Habitat 

Alaska Department of Fish and 

Game, Area Wildlife Biologist 

Alaska Department of Fish and 

Game, Division of Subsistence 

Alaska Division of Forestry, 

Regional Forester 

Alaska Department of Natural 

Resources 

Bureau of Land Management 

(USDI) 

Chugach National Forest 

Craig Ranger District, Tongass 

National Forest 

Division of Coastal and Ocean 

Management (DCOM) 

Environmental Protection 

Agency, Region 10, EIS 

Review Coordinator 

Federal Aviation 

Administration (USDOT), 

Alaska Region Headquarters 

Federal Highway 

Administration (USDOT) 

 Hoonah Ranger District, 

Tongass National Forest 

Ketchikan-Misty Ranger 

District, Tongass National 

Forest 

National Marine Fisheries 

Service (USDOC), Protected 

Resources Management 

Division 

National Park Service (USDI) 

Thorne Bay Ranger District, 

Tongass National Forest 

National Marine Fisheries 

Service 

NOAA Office of Policy and 

Strategic Planning 

Office of the Secretary, Senior 

Advisor 

Petersburg Ranger District, 

Tongass National Forest 

Sitka Ranger District, Tongass 

National Forest 

State of Alaska Department of 

Natural Resources, Office of 

Habitat Management and 

Permitting 

State of Alaska, Department of 

Environmental Conservation 

Tongass Document 

Coordinator- Sue Jennings 

Tongass National Forest Land 

Management Coordinator 

Tongass National Forest 

Supervisor and Deputy 

Supervisor 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 35
Tongass National Forest 

Timber Planning Program 

Manager 

University of Alaska Land 

Management 

US Advisory Council on 

Historic Preservation 

US Army Corps of Engineers, 

Juneau Regulatory Field Office 

US Army Engineer District, 

Regulatory Branch, E Section 

US Army Engineers, Pacific 

Ocean Division (CEPOD) 

US Coast Guard, 

Environmental Management 

US Department of Energy 

US Environmental Protection 

Agency 

 US Environmental Protection 

Agency, Alaska Operations 

Office 

 US Fish and Wildlife Service 

US House of Representatives 

US Navy 

USDA APHIS PPD/EAD 

USDA Forest Service, Director 

of Ecosystem Management 

Coordinator 

USDA Natural Resources 

Conservation Service 

USDA Forest Service, Alaska 

Region 

USDA Forest Service, Alaska 

Region, Ecosystem Planning 

USDA Forest Service, 

Environmental Coordinator 

USDA Forest Service, 

Ketchikan Supervisor’s Office 

USDA Forest Service, 

Petersburg Supervisor’s Office 

USDA Forest Service, 

Publications and Printing 

Program Manager 

USDA Forest Service, 

Regional Forester 

USDI Office of Environmental 

Policy and Compliance 

Wrangell Ranger District, 

Tongass National Forest 

Tribes and Tribal 

Corporations 

Kake Tribal Corporation 

Organized Village of Kake 

Petersburg Indian Association 

Sealaska Corporation 

Tlingit/Haida Central Council 

Wrangell Cooperative 

Association 

Libraries 

Craig Public Library 

Haines Public Library 

Hollis Public Library 

Hyder Public Library 

Kake Public Library 

Kasaan Community Library 

Ketchikan Public Library 

Kettleson Memorial Library 

Pelican Public Library 

Petersburg Public Library 

Quinney Library 

Tenakee Springs Public Library 

36 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Thorne Bay Community 

Library 

University of Minnesota 

Forestry Library 

USDA National Agricultural 

Library 

Wrangell Public Library 

Organizations and 

Buisnesses 

Alaska Forest Association 

Alaska Small Business 

Development Center 

Bluewater Adventures, Ltd. 

Cascadia Wildlands Project 

Earthjustice Legal Defense 

Forest Dwellers 

Forest Industry Consulting 

Glacier Guides, Inc. 

Green Peace 

Juneau Group of the Sierra 

Club 

Narrows Conservation 

Coalition 

National Outdoor Leadership 

School 

Natural Resource Defense 

Council 

Paden Timber Services 

Parker Guide Service, Inc. 

SEACC 

Sitka Conservation Society 

Southeast Alaska Regional 

Advisory Council 

Thuja Plicata Lumber 

Company 

Tongass Kayak Adventures 

The Wilderness Society 

Public Officials and 

Offices 

City of Kupreanof 

City of Petersburg 

City of Port Alexander 

Honorable Bert Stedman 

Representative Peggy Wilson 

United State Senator Mark 

Begich 

United States Senator Lisa 

Murkowski 

United States Congressman 

Don Young 

Individuals 

Casimero Acaveda 

Dick Artley 

Dave Beebe 

Mathew Bell 

Anissa Berry 

Jim Cariello 

Mary Ellen Clark 

Dick Coose 

Nicholas Davis 

Lou Anna Denison 

Ken Dorman 

Susan Erickson 

Barney Freedman 

John Geddie 

Eric Grundberg 

Eric Hanson 

Kim Hastings 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 37
Karen R. Hegyi 

Molly Hogan 

R.W. Holsinger 

Deb Hurley 

Heinrich Kadake Sr. 

Marvin Kadake 

David Kensinger 

Becky Knight 

Diane Kyser 

Dan LaCrosse 

Jay and Carolyn Pritchett 

Sigurd Mathisen 

Harold Medalen 

Gerry Merrigan 

Karin McCullough 

Tim Moore 

Jean Norheim 

Dave Ohmer 

Craig Olson 

Helmer Olson 

Jermy Parker 

Brian Paust 

William B. Privett 

David Randrup 

Steve Seley 

Ronald Simpson 

Martha Smith 

Allen Smith 

Mike Stainbrook 

John R. Swanson 

John Wigren 

38 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
References 

Alaback, P.B. 1982. Forest Community Structural Changes During 

Secondary Succession in Southeast Alaska. Proceedings in: 

Forest Succession and Stand Development Research in the 

Northwest Symposium; March 26, 1981; Coravallis, OR: Forest 

Research Laboratory, Oregon State University. 

Alaska Department of Commerce, Community and Economic 

Development, State of Alaska ( ADCCED). 2004. ADCCED 

Community Profile website. 

www.dced.state.ak.us/oed/toubus/home.cfm (accessed 

11/20/2008) 

Alaska Community Database, DCCED 2007, Community Information 

Summaries (CIS), 

http://www.commerce.state.ak.us/dca/commdb/CIS.cfm 

Alaska Natural Heritage Program 2008. Rare Vascular Plant Tracking 

List. 

http://aknhp.uaa.alaska.edu/botany/Botany_tracking_page.htm 

(Accessed June 2008) 

Alexander, Susan J. 2006. Employment Coefficients and Indirect 

Effects for NEAT-R. USDA Forest Service, Alaska Region. 2p. 

Unpublished document. 

Bartos, L. 1989. A New Look at Low Flows After Logging, in 

Proceedings of Watershed ’89: A Conference on the 

Stewardship of Soil, Air, and Water Resources. Juneau, Alaska 

1989. pp95-98. USDA Forest Service Region. R10-MB-77. 

Beers, Russell. 2006. Central Kupreanof Timber Sale Special Uses, 

Lands, and Minderals Resource Report. Peterburg Ranger 

District, Tongass National Forest. December 2006. 

Benda, L., N.L. Poff, D. Miller, T. Dunne, G. Reeves, G. Pess, and M. 

Pollock. 2004. The Network Dynamics Hypothesis: How channel 

Networks Structure Riverine Habitats. Bioscience 54(5): 413-

427. 

Beschta, R.L., Pyles, M.R., Skaugset, A.E., Surfleet, C.G. 2000. 

Peakflow Responses to Forest Practices in the Western Cascades 

of Oregon, USA. Journal of Hydrology. 233: 102-120. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 39
Brackley, A.M.; Parrent, D.J.; Rojas, R.W.; 2006. Estimating Sawmill 

Processing Capacity for Tongass Timber: 2003 and 2004 

Update. USDA Forest Service Research Note PNW-RN-553. 

Brackley, A.M.; T.D.; Haynes, R.W. 2008. An Addendum: Timber 

Products Output and Timber Harvests in Alaska: Projections for 

2005-25. USDA Forest Service General Technical Report PNWGTR-677. 

Brainard, J.D., III. 1996. Letter to Forrest Cole; Deer die-off on Kuiu 

Island, Alaska, winter of 1971-72. USDA Forest Service, Stikine 

Area, Tongass National Forest. April 15 1996. 3 pages. 

Brainard, J. D. 2008. Deer Population Fluctuations in SE Alaska. 

United States Department of Agriculture, Forest Service, 

Petersburg Alaska. 

Brainard, J.D. 2008. Neo-tropical Brids and Other Bird Species of 

Concern on the Tongass National Forest: Kuiu Island. United 

States Department of Agriculture, Forest Service, Petersburg, 

Alaska. 

Brardinoni, F., M.A. Hassan and H.O. Slaymaker. 2002. Complex 

Mass Wasting Response of Drainage Basins to Forest 

Management in Coastal British Columbia. Geomorphology 49: 

109-124. 

Bryant, M.D., Louke, M.D., McDonell, J.P., Gubernick, R.A. and R.S. 

Aho. 2009. Stream Discharge and Seasonal Movement of Dolly 

Varden and Cutthroat Trout in a 2nd Order Stream in Southeast 

Alaska. North American Journal of Fisheries Management. In 

Review. 

Bryant, M.D., Caouette, J.P., and B.E. Wright 2004. Evaluating 

Stream Habitat Survey Data and Statistical Power Using an 

Example From Southeast Alaska. North American Journal of 

Fishery Management. 24: 1353-1362. 

Bschor, Dennis, E. Regional Forester Memo. March 14, 2007. 

Limited Interstate Shipments of Unprocessed Sitka spruce and 

Western Hemlock Timber. U.S. Department of Agriculture 

Forest Service, Alaska Region. 

40 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Cederholm, C.J., Reid, L.M., and E.O. Salo. 1980. Cumulative Effects 

of Logging Road Sediment on Salmonid Populations in the 

Clearwater River, Jefferson County, Washington. Conference 

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46 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
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Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 47
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48 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
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Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 49
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50 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
Wemple, B.C. and J.A. Jones 2003. Runoff Production On Forest 

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Extension by Logging Roads in Two Basins, Western Cascades, 

Oregon. Journal of the American Water Resources Association 

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Effectiveness Monitoring of Floodplain Channel Aquatic 

Habitat: Channel Condition Assessment. Landscape and Urban 

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(accesed June 2009)

Ziemer R. R. 1981. The Role of Vegetation in the Stability of 

Forested Slopes. USDA Forest Service, Pacific Southwest 

Forest and Range Experiment Station. Division I. XVII 

International Union of Forest Research Organizations World 

Congress Proceedings-Referate-Exposes. Japan. 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 51
Index 

A

Alaska Department of Fish and Game 

(ADF&G), 1-16, 2-3, 3-2, 3-72, 3-

99, 3-100, 3-101, 3-118, 3-127 

Alaska Department of Labor, 3-12 

Alaska Department of Natural 

Resources, 1-16 

Alaska Marine Highway, 3-42, 3-194 

Alaska National Interest Lands 

Conservation Act (ANILCA), 1-3, 

1-17, 1-23, 3-46, 3-105, 3-106 

anadromous fish, 3-117, 3-118, 3-136 

Army Corps of Engineers (ACOE), 1-

16, 1-22 

B

Bald and Golden Eagle Protection 

Act, 1-23 

bald eagle, 3-75, 3-76 

beach and estuary buffers, 3-141 

beach fringe, 3-76, 3-79, 3-88, 3-89, 

3-92, 3-97, 3-104, 3-112 

Best Management Practices (BMPs), 

2-2, 2-3, 2-7, 2-14, 3-3, 3-47, 3-49, 

3-50, 3-54, 3-56, 3-57, 3-68, 3-70, 

3-121, 3-123, 3-126, 3-138, 3-158, 

3-162, 3-166, 3-169, 3-176, 3-178 

biogeographic province, 2-19, 2-20, 

3-2, 3-3, 3-72, 3-78, 3-80, 3-85, 3-

88, 3-89, 3-90, 3-92, 3-93, 3-94, 3-

95, 3-96, 3-97, 3-98, 3-101 

Biogeographic province, 3-78 

biological diversity, 3-4, 3-26, 3-86, 

3-148 

black bear, 3-78, 3-81, 3-89, 3-101, 

3-170, 3-194, 3-197, 3-198, 3-199, 

3-202 

black bear hunting, 3-197, 3-198, 3-

202 

brown creeper, 3-75, 3-76 

Bureau of Land Management, 3-157 

C

cabin, 1-3, 2-9, 3-20, 3-37, 3-58, 3-

168, 3-179, 3-180, 3-189, 3-194, 

3-197, 3-198, 3-201, 3-202, 3-203, 

3-204, 3-205, 3-206 

cavity nester, 3-76, 3-149 

channel type, 3-111, 3-122 

chinook, 3-136, 3-138 

chinook salmon, 3-136, 3-138 

Chum salmon, 3-119, 3-124, 3-136, 

3-137, 3-138 

Clean Air Act, 1-23 

Clean Water Act, 2-7, 3-56, 3-169, 3-

178 

clearcut with reserves, 2-5, 3-13, 3-14 

clearcutting, 1-15, 2-5, 2-6, 2-20, 3-

13, 3-14, 3-15, 3-18, 3-30, 3-32, 3-

33, 3-93, 3-94, 3-123, 3-129, 3-

131, 3-132, 3-134, 3-145, 3-148, 

3-149, 3-150, 3-151, 3-152, 3-187, 

3-188 

Coastal Zone Management Act 

(CZMA) 1-23, 1-24 

coho, 1-5, 3-119, 3-124, 3-137, 3-138 

Coho salmon, 1-5, 3-119, 3-124, 3-

137, 3-138 

commercial fishing, 3-6, 3-11, 3-21 

competition, 3-62, 3-86, 3-105, 3-

151, 3-152 

Council on Environmental Quality 

(CEQ), 1-15, 2-5, 3-3, 3-9 

crab, 3-120, 3-136 

cultural resources, 1-23, 3-4, 3-7, 3-

209, 3-210 

cumulative effects, 1-15, 1-21, 2-4, 3-

1, 3-3, 3-35, 3-36, 3-37, 3-47, 3-

48, 3-50, 3-55, 3-60, 3-62, 3-65, 3-

69, 3-76, 3-85, 3-92, 3-93, 3-94, 3-

95, 3-96, 3-97, 3-101, 3-103, 3-

108, 3-124, 3-125, 3-128, 3-130, 

3-133, 3-135, 13-37, 3-161, 3-162, 

3-165, 3-175, 3-178, 3-183, 3-185, 

3-190, 3-204, 3-205, 3-209 

52 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
D

deer, 1-18, 1-21, 2-2, 2-5, 2-10, 2-12, 

3-74, 3-76, 3-77, 3-78, 3-80, 3-87, 

3-90, 3-91, 3-92, 3-96, 3-99, 3-

100, 3-101, 3-102, 3-103, 3-106, 

3-107, 3-151, 3-194, 3-198 

deer winter habitat, 3-77, 3-91 

Deer, Sitka black-tailed deer, 3-80, 3-

81, 3-91, 3-102 

desired condition, 1-2, 1-4, 1-7, 1-9, 

3-45, 3-184, 3-185, 3-192, 3-210 

distance zone, 3-181, 3-189 

diversity, 1-4, 1-19, 3-11, 3-25, 3-29, 

3- 31, 3-86, 3-150, 3-171 

Dolly Varden, 3-117, 3-119, 3-136, 

3-137 

E

ecological processes, 1-9 

economics, 1-19, 2-3, 2-6, 2-11, 2-15, 

2-18, 3-1, 3-4, 3-10, 3-11, 3-13, 3-

14, 3-18, 3-19, 3-20, 3-22, 3-23, 3-

49, 3-99, 3-148, 3-153 

employment, 1-19, 3-6, 3-11, 3-12, 3-

13, 3-19, 3-20, 3-21 

endangered species, 3-31 

Environmental Protection Agency 

(EPA), 1-1, 1-16, 1-24, 3-3, 3-72 

erosion, 3-41, 3-57, 3-68, 3-70, 3-

111, 3-114, 3-128, 3-158, 3-159, 

3-162, 3-168, 3-178, 3-209 

Essential Fish Habitat (EFH), 3-21, 3-

103, 3-136, 3-137 

estuary, 3-29, 3-76, 3-141, 3-172 

even-aged management, 3-14, 3-147, 

3-148, 3-153, 3-154 

existing visual condition, 3-183 

F

Federal Subsistence Board, 3-101 

financial efficiency analysis, 1-19, 2-

11, 2-12, 3-15, 3-16, 3-21 

finfish, 3-100, 3-103 

firewood, 3-48, 3-104 

fish habitat, 2-3, 3-41, 3-51, 3-52, 3-

101, 3-107, 3-111, 3-117, 3-118, 

3-119, 3-121, 3-136, 3-158, 3-159 

fish passage, 1-5, 2-8, 3-46, 3-115, 3-

116, 3-119, 3-121, 3-124, 3-125, 

3-128, 3-133, 3-137 

fishing, 3-6, 3-7, 3-11, 3-21, 3- 99, 3-

181, 3-194, 3-196, 3-197, 3-198 

floating camp, 2-7, 3-45, 3-189 

forest health, 3-8, 3-152, 3-153, 3-

154 

Forest Plan, 1-1, 1-2, 1-4, 1-8, 1-9, 1-

10, 1-11, 1-12, 1-15, 1-18, 1-19, 1-

20, 1-21, 1-22, 1-26, 2-1, 2-2, 2-3, 

2-6, 2-7, 2-10, 2-13, 2-14, 2-17, 3-

1, 3-2, 3-3, 3- 8, 3-13, 3-14, 3-21, 

3- 23, 3-26, 3-27, 3-30, 3-31, 3-36, 

3-41, 3-45, 3-47, 3-49, 3-51, 3-56, 

3-72, 3-76, 3-77, 3-80, 3-81, 3-85, 

3-87, 3-90, 3-91, 3-92, 3-93, 3-96, 

3-97, 3-98, 3-99, 3-3-103, 3-106, 

3-107, 3-120, 3-121, 3-122, 3-123, 

3-137, 3-138, 3-141, 3-143, 3-147, 

3-148, 3-157, 3-159, 3-163, 3-166, 

3-171, 3-175, 3-180, 3-183, 3-184, 

3-185, 3-187, 3-188, 3-189, 3-190, 

3-191, 3-192, 3-193, 3-196 

Forest Plan standards and guidelines, 

3-56, 3-76, 3-90, 3-107 

Forest Practices Act, 3-106 

G

Game Management Unit (GMU), 3-

72, 3-90, 3-99, 3-100 

geology, 3-1, 3-2, 3-25, 3-57, 3-86, 3-

111, 3-157, 3-178, 3-179 

goshawk, 3-44, 3-74 

ground-based logging, 3-160 

H

habitat capability, 3- 85, 3- 88, 3-89, 

3-90, 3-101, 3-102, 3-103 

hairy woodpecker, 3-75 

harvest treatment, 3-123 

helicopter, 1-23, 2-5, 2-15, 2-18, 3-

13, 3-14, 3-15, 3-17, 3-18, 3-22, 3-

23, 3-30, 3-32, 3-33, 3-129, 3-131, 

3-158, 3-164, 3-167, 3-187, 3-188 

heritage resource, 3-207, 3-208, 3-

209, 3-210 

heritage resources, 3-207, 3-208, 3-

209, 3-210 

heritage site, 3- 210 

high value, 3-26, 3-50, 3-169, 3-170, 

3-172 

humpback whale, 3-75 

hunting, 1-24, 3-72, 3-99, 3-100, 3-

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 53
102, 3-103, 3-105, 3-107, 3-181, 

3-194, 3-196, 3-197, 3-198, 3-202, 

3-209 

hydrology, 1-3, 1-21, 2-8, 2-13, 2-21, 

3-1, 3-8, 3-58, 3-62, 3-65, 3-108, 

3-111, 3-114, 3-124, 3-125, 3-126, 

3-129, 3-132, 3-134, 3-137, 3-168, 

3-176, 3-178, 3-179, 3-206 

I

income, 1-19, 2-15, 3-6, 3-7, 3-11, 3-

19, 3-20, 3-21, 3-22, 3-23 

independent timber sale, 13-45 

Interstate shipping, 3-15, 3-16, 3-21 

intertidal, 3-170 

Inventoried Roadless Area, 1-5, 1-12, 

1-19, 2-4, 2-6, 2-11, 2-12, 2-16, 2-

18, 2-19, 3-1, 3-2, 3-25, 3-26, 3- 

27, 3-28, 3-29, 3-30, 3-31, 3-32, 3-

33, 3-34, 3-35, 3-36, 3-37, 3-51, 3-

52 

J

job, 1-19, 2-18, 3-20, 3-21 

K

Kake, city of, 1-5, 1-8, 1-10, 1-15, 1-

17, 1-20, 1-22, 2-7, 2-8, 2-9, 2-12, 

3-5, 3-6, 3-7, 3-13, 3-18, 3-19, 3- 

24, 3-28, 3-29, 3-42, 3-45, 3-50, 3-

55, 3-56, 3-59, 3-66, 3-67, 3-68, 3-

69, 3-70, 3-72, 3-77, 3-85, 3-93, 3-

94, 3-99, 3-100, 3-102, 3-103, 3-

104, 3-105, 3-112, 3-124, 3-153, 

3-167, 3-168, 3-178, 3-179, 3-189, 

3-190, 3-194, 3-196, 3-197, 3-198, 

3-202, 3-205, 3-206, 3-208, 3-209 

karst, 1-12, 3-28, 3-157, 3-158 

Kuiu Island, 3-24, 3-29, 3-60, 3-72, 

3-79, 3-85, 3-94, 3-100, 3-101, 3-

102, 3-208 

Kupreanof Island, 1-1, 1-5, 1-7, 1-9, 

1-11, 1-13, 1-14, 1-19, 3-6, 3-28, 

3-29, 3-35, 3-36, 3-42, 3-45, 3-55, 

3-61, 3-72, 3-77, 3-78, 3-80, 3-81, 

3-90, 3-91, 3-92, 3-94, 3-99, 3-

100, 3-126, 3-143, 3-156, 3-157, 

3-165, 3-178, 3-180, 3-204, 3-208 

L

Land Use Designation (LUD), 1-8, 1-

9, 1-10, 1-11, 1-13, 1-14, 1-20, 1-

22, 3-2, 3-26, 3-27, 3-49, 3-70, 3-

107, 3-141, 3-143, 3-148, 3-153, 

3-184, 3-185, 3-187, 3-188, 3-191, 

3-193 

landslide, 3-41, 3-111, 3-113, 3-123, 

3-126, 3-158, 3-160, 3-165, 3-166, 

3-167 

large woody debris (LWD), 3-113 

log transfer facility (LTF), 1-25, 3-13, 

3-15, 3-18, 3-35, 3-42, 3-44, 3-45, 

3-51, 3-52, 3-53, 3-115, 3-120, 3-

123, 3-133, 3-135, 3-138, 3-189, 

3-209 

logging camp, 1-25, 3-45 

logging system, 1-19, 3-10, 3-11, 3-

13, 3-19, 3-22, 3-49, 3-68, 3-131, 

3-150, 3-162 

long-term productivity, 3-4, 3-157 

M

Management Indicator Species 

(MIS), 3-73, 3-74, 3-76 

management prescription, 1-8, 1-9, 2-

7, 3-111, 3-156, 3-183, 3-184, 3-

192 

marine environment, 3-101 Marine 

Marine Mammal Protection Act 1-24 

marine resource, 3-100 

market demand, 1-4, 1-16, 1-19, 2-6, 

3-10, 3-13, 3-26, 3-153 

marten, 73-4, 3-76, 3-79, 3-81, 3-89, 

3-96, 3-101 

Mass Movement Index (MMI), 2-20, 

3-113, 3-129, 3-132, 3-134, 3-160, 

3-162, 3-63, 3-164, 3-165 

mass wasting, 3-140, 3-159 

microsale, 1-3, 1-4, 2-9, 2-10, 2-11, 

3-13, 3-19, 3-24, 3-50, 3-59, 3-87, 

3-153, 3-168, 3-179, 3-190 

minerals, 3-4, 3-57, 3-67, 3-69, 3-

157, 3-158, 3-170, 3-177, 3- 208 

mining, 2-1, 2-2, 2-7, 2-8, 2-14, 3-11, 

3-57, 3-157, 3- 208 

mitigation, 1-1, 1-4, 1- 1-18, 3-3, 3-

47, 3-49, 3-57, 3-66, 3-70, 3-71, 3-

121, 3-123, 3-125, 3-137, 3-178, 

3-189, 3-210 

mitigation measure, 1-1, 1-4, 1-18, 2-

8, 2-14, 3-3, 3-47, 3-57, 3-66, 3-

54 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
71, 3-121, 3-123, 3-125, 3-189, 3-

210 

Modified Landscape, 1-9, 1-10, 1-11, 

3-184, 3-187, 3-191 

Modified Landscape LUD, 1-9, 1-10, 

1-11, 3-184, 3-187, 3-191 

monitoring, 1-4, 1-18, 2-1, 2-2, 2-9, 

2-13, 2-14, 3-3, 3-8, 3-57, 3-70, 3-

143, 3-210 

moose, 3-75, 3-79, 3-80, 3-81, 3-89, 

3-90, 3-96, 3-99, 3-101, 3-151, 3-

194, 3-198 

multiple use, 1-8, 3-106 

muskeg, 3-28, 3-78, 3- 81, 3-140, 3-

170, 3-171, 3-172, 3-173, 3-174, 

3-175, 3-193 

N

National Environmental Policy Act 

(NEPA), 1-1, 1-20, 1-24, 1-26, 2-

17, 3-3, 3-9, 3-11, 3-36, 3-49, 3-

50, 3-51, 3-69, 3-72, 3-125, 3-136, 

3-146, 3-168 

National Forest Management Act 

(NFMA), 1-24, 2-1, 2-13, 3-4, 3-

106, 3-148 

National Forest System Roads, 1-4, 

1-7, 1-8, 1-20, 2-3, 2-5, 2-6, 2-7, 

2-10, 2-12, 2-14, 2-15, 2-16, 2-17, 

2-18, 2-19, 3-4, 3-13, 3-14, 3-18, 

3-19, 3-22, 3-23, 3-30, 3-31, 3-32, 

3-33, 3- 34, 3-35, 3-37, 3-41, 3-42, 

3-43, 3-44, 3-46, 3-47, 3-48, 3-49, 

3-50, 3-51, 3-52, 3-53, 3-54, 3-55, 

3-59, 3-77, 3-91, 3-101, 3-104, 3-

107, 3-120, 3-121, 3-125, 3-130, 

3-132, 3-133, 3-134, 3-165, 3-167, 

3-175, 3-197, 3- 203, 3-204 

National Historic Preservation Act 

(NHPA), 1-24, 3-207 

National Register of Historic Places 

(NRHP), 3-207, 3- 210 

NEPA Economics Analysis 

Tool_Residuals (NEAT_R), 2-3, 

3-11, 3-15, 3-16, 3-17, 3-18, 3-20, 

3-23, 3-49 

Northern goshawk, 2-7, 3-44, 3-74 

Notice of Intent (NOI), 1-15 

O

old-growth, 1-9, 1-11, 1-12, 1-21, 2-

2, 2-7, 3-32, 3-33, 3-34, 3-72, 3-

76, 3-78, 3-79, 3-80, 3-81, 3-85, 3-

88, 3-89, 3-90, 3-91, 3-92, 3-93, 3-

95, 3-97, 3-101, 3-107, 3-145, 3-

151, 3-153, 3-154, 3-156, 3-184, 

3-197 

old-growth habitat, 2-7, 3-76, 3-92, 3-

97, 3-107 

old-growth habitat reserves (OGR), 

3-55, 3-81 

Old-Growth Reserves (OGR), 3-55, 

3-90 

Organized Village of Kake, 1-17, 3-5, 

3-6, 3-7, 3-100, 3-207, 3-208 

otter, 3-170 

outfitters and guides, 1-22, 3-21, 3-

199, 3-202, 3-205 

overstory removal, 1-22 

P

partial harvest, 1-8, 3-15, 3-76, 3-88, 

3-89, 3-152 

past timber harvest, 3-190 

peregrine falcon, 3-74 

permit, 1-11, 1-23, 3-43, 3-44, 3-45, 

3-138, 3-198 

Petersburg, city of, 1-1, 1-2, 1-5, 1-7, 

1-8, 1-15, 1-16, 1-17, 1-18, 1-20, 

1-26, 2-8, 2-9, 2-13, 3-1, 3-5, 3-6, 

3-36, 3-50, 3-55, 3-56, 3- 60, 3-72, 

3-77, 3-78, 3-99, 3-100, 3-102, 3-

103, 3-117, 3-125, 3-140, 3-144, 

3-146, 3-167, 3-178, 3-180, 3-194, 

3-205, 3-208, 3-210 

pink salmon, 3-119, 3-138 

planning record, 2-5, 2-13, 3-1, 3-11, 

3-21, 3-45, 3-46, 3-61, 3-66, 3-77, 

3- 99, 3-101, 3-104, 3-107, 3-140, 

3-159, 3-199 

precommercial thinning, 1-5, 1-22, 2-

9, 3-144, 3-153 

preferred alternative, 2-2, 2-6, 3-169, 

3-174 

productive forest, 3-78, 3-141, 3-144 

productive old growth (POG), 2-3, 2-

4, 2-19, 2-20, 3-72, 3-76, 3-77, 3- 

78, 3-81, 3-85, 3-86, 3-87, 3-88, 3-

89, 3- 90, 3-91, 3-92, 3-93, 3-94, 

3- 95, 3-96, 3-97, 3- 98, 3-101, 3-

103 

Projects Common to all Action 

Alternatives, 3-20, 3-37, 3-50, 3-

68, 3-70, 3-104, 3-153, 3-167, 3-

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 55
168, 3-178, 3-179, 3-189, 3-209 

proposed action, 1-1, 1-2, 1-15, 1-19, 

1-21, 2-2, 2-10, 3-1, 3-7, 3-8, 3-9, 

3-48, 3-73, 3-92, 3-94, 3-120, 3-

123, 3-136, 3- 137, 3-165, 3-209 

pruning, 1-22, 3-124, 3-126, 3-128, 3-

147, 3-148, 3-151, 3-152, 3-153 

public involvement, 1-15, 2-2, 3-1 

purose and need, 1-1, 1-2, 2-1, 2-5, 2-

11, 2-17 

R

Record of Decision (ROD), 1-2, 1-7, 

1-11, 2-7, 3-26, 3-36, 3-46 

Recreation Opportunity Spectrum 

(ROS), 3-194, 3-195, 3-196, 3-

199, 3-200, 3-201, 3-203 

red-breasted sapsucker, 3-75 

reforestation, 3-151 

regeneration, 1-22, 3-48, 3-104, 3-

144, 3-147, 3-148, 3-149, 3-150, 

3-151, 3-152, 3-153, 3-171 

renewable resource, 3- 4 

reserve trees, 3-149 

resident fish, 3-115, 3-117 

riparian, 3-62, 3-67, 3-107, 3-113, 3-

122, 3-138, 3-141, 3-143 

riparian area, 3-46, 3-62, 3-67, 3-76, 

3-79, 3-88, 3-89, 3-107, 3-111, 3-

113, 3-122, 3-138, 3-141, 3-143 

riparian management area (RMA), 3-

122, 3-131 

Rivers and Harbors Act, 1-24 

road construction, 1-4, 1-8, 1-11, 1-

15, 1-20, 2-5, 2-6, 2-7, 2-12, 2-14, 

2-15, 2-16, 2-17, 3-4, 3-8, 3-10, 3-

14, 3-17, 3-18, 3-19, 3-22, 3-25, 3-

26, 3-30, 3-31, 3-32, 3-33, 3-35, 3-

42, 3-44, 3-47, 3-48, 3-49, 3-51, 3-

53, 3-56, 3-57, 3-60, 3-62, 3-63, 3-

65, 3-68, 3-69, 3-70, 3-71, 3-130, 

3-132, 3-134, 3-139, 3-145, 3-158, 

3-159, 3-161, 3-162, 3-163, 3-164, 

3-165, 3-169, 3-172, 3- 174, 3-

175, 3-176, 3-177, 3-178, 3- 189, 

3-193, 3-202, 3-203, 3-204, 3-207, 

3-209 

road maintenance, 1-5, 1-8, 2-3, 2-9, 

2-12, 2-13, 3-20, 3-41, 3-44, 3-47, 

3-48, 3-50, 3-52, 3-53, 3-57, 3-59, 

3-69, 3-93, 3-95, 3-128, 3-162, 3-

168, 3-179, 3-190 

Road Management Objective (RMO), 

1-4, 1-7, 1-20, 2-8, 2-14, 2-17, 3-

45, 3-49, 3-51, 3-55, 3-93, 3-94, 3-

105, 3-107, 3-205 

roadless, 1-5, 1-11, 1-12, 1-19, 1-20, 

2-6, 2-11, 2-15, 2-16, 3-2, 3-22, 3-

25, 3-26, 3-27, 3-28, 3-29, 3-30, 3-

31, 3-32, 3-33, 3-34, 3-35, 3-36, 3-

37, 3-39, 3-42, 3-45, 3-53, 3-193 

Roadless Area Conservation Rule, 3-

26 

roads, 1-2, 1-3, 1-4, 1-5, 1-7, 1-8, 1-

11, 1-12, 1-15, 1-19, 1-20, 1-21, 1-

22, 1-25, 2-3, 2-5, 2-6, 2-7, 2-8, 2-

9, 2-10, 2-11, 2-12, 2-13, 2-14, 2-

15, 2-16, 2-17, 2-18, 2-19, 2-20, 3-

1, 3-3, 3- 4, 3-7, 3-8, 3-10, 3-13, 3-

14, 3-15, 3-17, 3-18, 3-19, 3-20, 3-

22, 3-23, 3-25, 3-26, 3-28, 3-29, 3-

30, 3-31, 3-32, 3-33, 3- 34, 3-35, 

3-36, 3-3-37, 3- 41, 3-42, 3-43, 3-

44, 3-45, 3-46, 3-47, 3-48, 3-49, 3- 

50, 3-51, 3-52, 3- 53, 3-54, 3-55, 

3-56, 3-57, 3-58, 3-59, 3-60, 3-62, 

3-63, 3-64, 3-65, 3-66, 3-67, 3-68 

3-69, 3-70, 3-71, 3- 72, 3-77, 3-78, 

3-81, 3-87, 3-88, 3-89, 3-90, 3-91, 

3-93, 3-94, 3-96, 3-99, 3-100, 3-

102, 3-103, 3-104, 3-105, 3-107, 

3-108, 3-111, 3-112, 3-113, 3-114, 

3-115, 3-116, 3-117, 3-120, 3-121, 

3-122, 3-123, 3-124, 3-125, 3-126, 

3-128, 3-129, 3-130, 3-131, 3-132, 

3-133, 3-134, 3-135, 3-137, 3-138, 

3-139, 3-145, 3-153, 3-156, 3-158, 

3-159, 3-160, 3-161, 3-162, 3-163, 

3-164, 3-165, 3-166, 3-167, 3-168, 

3-169, 3-172, 3-173, 3-174, 3-175, 

3-176, 3-177, 3-178, 3-179, 3-180, 

3-185, 3-186, 3-189, 3-190, 3-193, 

3-194, 3-195, 3-196, 3-197, 3-198, 

3-199, 3-201, 3-202, 3-203, 3-204, 

3-205, 3-206, 3-207, 3-208, 3-209, 

3-210 

Roads Rule, 3- 45 

S

salmon, 1-5, 3-6, 3-79, 3-80, 3-100, 

3-103, 3-119, 3-120, 3-123, 3-124, 

3-136, 3-137, 3-138, 3-170, 3-196, 

3-197 

sawtimber, 1-3, 

scenic quality, 3-150, 3-180, 3-184, 

56 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
3-185, 3-187, 3-188, 3-189 

scoping, 1-7, 1-15, 1-18, 1-20, 2-1, 2-

2, 3-10, 3-73 

second-growth, 3-59, 3-78, 3- 88, 3-

93, 3- 94, 3-151, 3-152, 3-156, 3-

176, 3-197, 3-206 

sediment, 3-112, 3-113, 3-114, 3-120, 

3-121, 3-123, 3-124, 3-125, 3-128, 

3-133, 3-137, 3-139, 3-169, 3-170, 

3-171 

selection, 1-22, 2-20, 3-9, 3-14, 3-15, 

3-32, 3-33, 3-108, 3-123, 3-128, 3-

149, 3-150, 3-153, 3-186, 3-187, 

3-196 

Semi-remote recreation LUD, 1-9, 1-

10, 1-11, 

sensitive species, 1-22, 2-4, 3-25, 3- 

31, 3- 60, 3-61, 3- 62, 3-65 

shellfish, 3-99, 3-120 

sightseeing, 3-194, 3-198 

significant restriction, 3-101, 3-103, 

3-106 

silvicultural prescription, 1-16, 2-1, 

2-12, 3-10, 3-14, 3-18, 3-92, 3-

147, 3-148, 3-152, 3-159 

silvicultural system, 3-147, 3-148 

silviculture, 1-3, 1-22, 2-9, 2-20, 3-

14, 3-20, 3-59, 3- 60, 3-88, 3-140, 

3-148, 3-150, 3-151, 3-153, 3-168, 

3-179, 3-206 

Sitka, 3-16, 3-21, 3-74, 3-78, 3-91, 3-

102, 3-140, 3-170 

Sitka spruce, 3-21, 3-78, 3-140 

small timber sale, 1-8 

sockeye salmon, 3-136, 3-137 

soil, 2-4, 2-20, 3-4, 3-31, 3-57, 3-62, 

3-67, 3-68, 3-70, 3-78, 3-86, 3-

113, 3- 114, 3-140, 3-143, 3-148, 

3-157, 3-158, 3-159, 3-160, 3-161, 

3-162, 3-163, 3-164, 3-165, 3-166, 

3-167, 3-168, 3-170, 3-171, 3-175, 

3-176, 3-177, 3-178 

Special Interest Area, 1-9, 1-10, 1-11, 

1-12, 3-184 

Special Interest Area LUD, 1-9, 1-10, 

1-11, 1-12, 3-184 

species composition, 1-22, 3-2, 3-17, 

3-147, 3-151, 3-153 

squirrel, red, 3-74, 3-76, 3-81 

standards and guidelines, 1-8, 2-2, 2-

6, 2-7, 2-10, 2-14, 3-14, 3-47, 3-

56, 3-98, 3-107 

State Historic Preservation Officer 

(SHPO), 3-207 

steelhead trout, 1-5, 3-119, 3-124, 3-

136, 3-137 

stewardship, 1-3, 1-17, 2-8, 2-9, 3-20, 

3-58, 3-59, 3-70, 3-119, 3-153, 3-

210 

strata, 3-17, 3-85, 3-87, 3-88, 3-144, 

3-146, 3-147 

stream, 3-111, 3-117 

stream buffer, 2-7, 3-44, 3-143 

Stream channels, 3-111 

stream class, 3-110, 3-111, 3-117, 3-

121, 3-132 

stream crossing, 1-16, 1-17, 2-3, 3-

46, 3-51, 3-52, 3-59, 3-87, 3-104, 

3-111, 3-114, 3-115, 3-116, 3-117, 

3-124, 3-125, 3-129, 3-132, 3-134, 

3-168 

stream habitat, 3-119 

structure, 1-1, 1-5, 1-25, 2-9, 3-85, 3-

86, 3-114, 3-115, 3-143, 3-145, 3-

146, 3-147, 3-148, 3-149, 3-151, 

3-152 

subsistence, 1-3, 1-5, 1-15, 1-17, 1-

18, 1-20, 1-22, 2-3, 2-10, 2-17, 2-

21, 3-1, 3-5, 3-7, 3-8, 3-11, 3-25, 

3-41, 3-51, 3-62, 3-65, 3-85, 3-94, 

3-99, 3-100, 3-101, 3-103, 3-104, 

3-105, 3-106, 3-107, 3-181, 3-209 

suitable land, 1-3, 1-11, 1-12, 3-2 

sustained yield, 1-3 

T

temporary road,1-2, 1-7, 1-20, 2-4, 2-

5, 2-6, 2-11, 2-12, 2-15, 3-10, 3-

22, 3-23, 3-25, 3-32, 3-33, 3-34, 3-

35, 3-42, 3-43, 3-44, 3-48, 3-49, 3-

51, 3-52, 3-53, 3-69, 3-107, 3-114, 

3-121, 3-124, 3-125, 3-129, 3-132, 

13-33, 3-134, 3-137, 3-138, 3-161, 

3-162, 3-163, 3-164, 3-165, 3-175, 

3-176, 3-186, 3-189, 3-203, 3-204 

temporary roads, 2-7, 3-30, 3-43, 3-

48, 3-104, 3-121, 3-130, 3-133, 3-

134, 3-138, 3-167 

tentatively suitable, 3-159 

thinning, 1-5, 1-8, 1-22, 2-9, 2-12, 2-

13, 3-59, 3-87, 3-103, 3-124, 3-

126, 3-128, 3-143, 3-147, 3-148, 

3-151, 3-152, 3-153, 3-156, 3-168, 

3-179, 3-190, 3-206 

timber 

harvest, 3-12 

harvest volume, 3-19 

timber economics, 1-19, 2-5, 2-6, 2-

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 57
12, 3-19, 3-88 

timber harvest, 1-2, 1-3, 1-4, 1-5, 1-7, 

1-9, 1-10, 1-11, 1-12, 1-15, 1-17, 

1-19, 1-20, 1-21, 1-22, 1-25, 2-1, 

2-5, 2-6, 2-7, 2-8, 2-12, 2-14, 2-15, 

2-16, 2-17, 2-21, 3-3, 3- 7, 3-10, 3-

11, 3-12, 3-13, 3-15, 3-18, 3-20, 3-

22, 3-25, 3-26, 3-30, 3-31, 3-32, 3-

33, 3-34, 3-35, 3-36, 3-41, 3-42, 3-

43, 3-46, 3- 48, 3-49, 3-51, 3-52, 

3-53, 3-55, 3-62, 3-65, 3-68, 3-70, 

3-78, 3-85, 3-89, 3-96, 3-101, 3-

102, 3-103, 3-104, 3-106, 3-107, 

3-108, 3-112, 3-113, 3-121, 3-122, 

3-123, 3-124, 3-125, 3-126, 3-128, 

3-130, 3-133, 3-134, 3-135, 3-138, 

3-141, 3-143, 3-144, 3-145, 3-148, 

3-151, 3-152, 3-153, 3-156, 3-158, 

3-159, 3-160, 3-161, 3-162, 3-164, 

3-165, 3-167, 3-175, 3-176, 3-178, 

3-185, 3-186, 3-187, 3-188, 3-189, 

3-190, 3-191, 3-192, 3-193, 3-195, 

3-202, 3-203, 3-204, 3-207, 3-208, 

3-209 

timber management, 2-11, 3-10, 3-13, 

3-30, 3-141 

timber production, 1-9, 1-10, 1-11, 3-

4, 3-48, 3-106, 3-140, 3-141, 3-

151, 3-171, 3-184 

Timber Production, 1-9, 1-11, 1-22, 

3-184, 3-185, 3-187, 3-188, 3-191, 

3-192, 3-193 

Timber Production LUD, 1-9, 1-11, 

1-22, 3-148, 3-184, 3-185, 3-187, 

3-188, 3- 191, 3-192, 3-193 

timber sales, 1-3, 1-8, 1-12, 1-19, 1-

21, 2-11, 2-15, 3- 3, 3-10, 3-18, 3-

93, 3-94, 3-144, 3-145, 3-208 

timber supply, 1-4, 1-19, 2-11, 2-13, 

3-12, 3-13, 3-19, 3-156 

Tlingit, 1-17, 3-5, 3-7, 3-208, 3-209 

Tongass Land and Resource 

Management Plan (Forest Plan), 1-

2, 2-6, 3-1, 3-2, 3-3, 3-8, 3-13, 3-

14, 3-21, 3-23, 3-26, 3-27, 3-30, 3- 

31, 3-36, 3-41, 3-45, 3-47, 3-49, 3-

51, 3-56, 3-72, 3-76, 3-77, 3-80, 3-

81, 3-85, 3-87, 3- 90, 3-91, 3- 92, 

3-93, 3- 96, 3-97, 3-98, 3-99, 3-

103, 3-106, 3-107, 3-120, 3-121, 

3-122, 3-123, 3-137, 3-138, 3-141, 

3-143, 3-147, 3-148, 3-157, 3-159, 

3-163, 3-166, 3-169, 3-170, 3-171, 

3-175, 3-180, 3-183, 3-184, 3-185, 

3-187, 3-188, 3-189, 3-190, 3-191, 

3-192, 3-193, 3-196, 3-210 

Tongass Land and Resource 

Management Plan (TLRMP) (see

Forest Plan), 3-85, 3-106, 3-169, 

3-170, 3-175, 3-210 

Tongass National Forest, 1-1, 1-4, 1-

5, 1-8, 1-9, 1-25, 2-13, 2-16, 3-2, 

3-4, 3-8, 3-10, 3-11, 3-12, 3-22, 3-

26, 3- 27, 3-36, 3- 60, 3-63, 3-64, 

3-65, 3-72, 3-76, 3- 86, 3-106, 3-

111, 3-113, 3-117, 3-144, 3-147, 

3-196 

Tongass Timber Reform Act 

(TTRA), 1-24, 1-26, 3-106 

tourism, 1-10, 3-5, 3-6, 3-7, 3-11, 3-

21, 3-26 

trails, 1-3, 2-8, 3-58, 3-87, 3-105, 3-

168, 3-179, 3-181, 3-189, 3-194, 

3-202, 3-203, 3- 204, 3- 205 

transportation, 1-3, 1-24, 2-1, 2-3, 2-

9, 2-15, 2-17, 2-18, 3-14, 3-22, 3-

23, 3-41, 3-42, 3-43, 3-45, 3-46, 3-

49, 3-50, 3-56, 3-57, 3-59, 3-104, 

3-121, 3-123, 3-125, 3-130, 3-140, 

3-168, 3-175, 3-179, 3-206 

tribal government, 1-15, 1-17, 3-98 

trout, 1-5, 3-136, 3-137, 3-196, 3-197 

turbidity, 3-124, 3-125 

two-aged management, 1-22, 2-20, 3-

147, 3-150, 3-153, 3-155 

U

uneven-aged management, 2-5, 2-12, 

3-147, 3-149, 3-156 

unroaded, 3-1, 3-45, 3-100, 3-193 

V

Value Comparison Unit (VCU), 3-2, 

3-72, 3-185, 3-190 

vegetation, 2-20, 3-1, 3- 8, 3-14, 3-

43, 3-46, 3-48, 3-60, 3-78, 3-79, 3- 

80, 3-86, 3-87, 3-92, 3- 97, 3-105, 

3-113, 3-122, 3-124, 3-125, 3-128, 

3-140, 3-146, 3-151, 3-152, 3-153, 

3-156, 3-157, 3-158, 3-159, 3-162, 

3-163, 3-164, 3-165, 3-169, 3-170, 

3-175, 3-176, 3-178, 3-181, 3-187, 

3-188, 3-189, 3-190, 3-191, 3-193 

viable population, 3-81 

viewshed, 2-20, 3-185, 3-190, 3-191 

visual quality, 3-188 

58 ▪ Chapter 4 Central Kupreanof Timber Harvest FEIS 4 References and Lists
volume class, 3-86, 3-144, 3-146 

volume strata, 3-17, 3- 85, 3-88, 3-

146 

W

water quality, 3-4, 3-41, 3-111, 3-

120, 3-123, 3-126, 3-128, 3-138 

waterfowl, 3-80, 3- 99, 3-101, 3-170, 

3-196, 3-197 

watershed, 3-2, 3-25, 3-28, 3-29, 3-

30, 3-101, 3-108, 3-110, 3-111, 3-

112, 3-114, 3-115, 3-116, 3- 118, 

3-119, 3-121, 3-122, 3-123, 3-124, 

3-125, 3-126, 3-127, 3-128, 3- 

129, 3-130, 3-131, 3-132, 3-133, 

3-134, 3-135, 3-139, 3-148 

western hemlock, 3- 21, 3-78, 3-140, 

3-144, 3-170 

western red cedar, 3-78, 3-140 

wetlands, 2-4, 2-20, 3-1, 3-4, 3-25, 3-

46, 3-50, 3-56, 3-60, 3-136, 3-3-

169, 3-170, 3-171, 3-172, 3-173, 

3-174, 3-175, 3-176, 3-177, 3-178, 

3-179 

whales, 73-3 

wilderness, 2-16, 3-2, 3-25, 3-26, 3- 

27, 3-28, 3-31, 3-32, 3- 33, 3-36, 

3-78, 3-184, 3-193 

Wildlife Analysis Area, 2-20, 3-2, 3-

85, 3- 95, 3-96, 3- 97, 3-100 

wildlife habitat, 3-8, 3-72, 3-85, 3-86, 

3-88, 3- 93, 3-94, 3-97, 3-98, 3-

101, 3-103, 3-124, 3-126, 3-128, 

3-145, 3-147, 3-148, 3-149, 3-150, 

3-170 

wind disturbance, 3-143, 3-145 

windthrow, 3-62, 3-113, 3-143, 3-

148, 3-152 

winter habitat, 3-76, 3-79, 3-80, 3-91 

winter range, 2-10, -80 

wolf, Alexander Archipelago, 3-75, 

3-80, 3-81, 3- 90, 3-96, 3-101, 3-

102 

woodpecker, hairy, 3-76 

woodpecker, red-breasted sapsucker, 

3-76 

Wrangell, city of, 3-5, 3-6, 3-7, 3-15, 

3-16, 3- 207, 3-208 

Y

yellow-cedar (Alaska yellow-cedar), 

3-8, 3-21, 3-78, 3-140, 3-143, 3-

144, 3-152, 3-209 

References and Lists 4

Central Kupreanof Timber Harvest FEIS Chapter 4 ▪ 59
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the 

basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, 

parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part 

of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all 

programs.) Persons with disabilities who require alternative means for communication of program information 

(Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and 

TDD). 

To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence 

Avenue, S.W., Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA 

is an equal opportunity provider and employer. 
United States 

Department of 

Agriculture 

Forest Service 

Petersburg Ranger 

District 

Tongass 

National 

Forest 

R10-MB-633b 

October 2009 

Central 

Kupreanof 

Timber Harvest

Final Environmental Impact 

Statement 

Volume B, Appendices 
Abbreviations and Common 

Acronyms 

ANILCA Alaska National Interest 

Lands Conservation Act 

ASQ Allowable Sale Quantity 

BMPs Best Management 

Practices 

CCF Hundred Cubic Feet 

CEQ Council on Environmental 

Quality 

DBH Diameter at Breast Height 

DEIS Draft Environmental 

Impact Statement 

EFH Essential Fish Habitat 

FEIS Final Environmental 

Impact Statement 

Forest Plan Tongass Land and 

Resource Management 

Plan 2008 

GIS Geographic Information 

System 

HSI Habitat Suitability Index 

IDT Interdisciplinary Team 

LTF Log Transfer Facility 

LUD Land Use Designation 

MBF Thousand Board Feet 

MIS Management Indicator 

Species 

MMBF Million Board Feet 

MMI Mass Movement Index 

NEAT_R NEPA Economic 

Analysis Tool 

NEPA National Environmental 

Policy Act 

NFMA National Forest 

Management Act 

NFS National Forest System 

POG Productive Old Growth 

RMA Riparian Management 

Area 

RMO Road Management 

Objective 

ROS Recreation Opportunity 

Spectrum 

SHPO State Historic 

Preservation Office 

VCU Value Comparison Unit 

WAA Wildlife Analysis Area 

 

 
Appendix A 

Reasons for Scheduling the 

Environmental Analysis of the 

Central Kupreanof Timber 

Harvest 
Appendix A 

Table of Contents 

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

How does the Central Kupreanof Timber Harvest Project Fit into the 

Tongass Timber Sale Program? .......................................................................... 1 

Why is Timber from the Tongass National Forest Being Offered for 

Sale? .................................................................................................................... 3 

How Does the Forest Service Develop Forecasts About Future Timber 

Market Demand? ................................................................................................. 6 

What Steps Must Be Completed to Prepare a Sale for Offer? .......................... 11 

How Does the Forest Service Maintain an Orderly and Predictable 

Timber Sale Program? ...................................................................................... 12 

How Does the Forest Service Decide Where Timber Harvest Projects 

Should be Located? ........................................................................................... 16 

Conclusion ........................................................................................................ 19 

References ......................................................................................................... 21 

Introduction 

Coordinated timber sale planning is essential for meeting the goals of 

the Tongass Land and Resource Management Plan (Forest Plan) and to 

provide an orderly flow of timber to local industry. To determine the 

volume of timber to offer each year, the Forest Service can look to 

current market conditions and the level of industry operations. 

However, the planning process for timber harvest projects requires the 

Forest Service to rely on projections of future harvest levels to decide 

how many timber sale projects to begin each year. This document 

explains how the Forest Service uses information about future markets 

and past experience with timber sale planning to determine the volume 

of timber that needs to be started through this process each year. This 

appendix relies heavily on the current annual timber demand analysis 

and the most recent timber sale schedule. 

The purpose of this appendix is two-fold: first, to explain why this 

project was selected for inclusion into the Tongass Timber Program and 

second, to explain the basis and components of the Tongass Timber 

program. To accomplish this, the following questions are answered: 

 How does the Central Kupreanof Timber Harvest project fit into 

the Tongass Timber Sale Program? 

 Why is timber from the Tongass National Forest being offered for 

sale? 

 How does the Forest Service develop forecasts about future 

timber market demand? 

 What steps must be completed to prepare a sale for offer? 

 How does the Forest Service maintain an orderly and predictable 

timber sale program? 

How does the Forest Service decide where 

timber sale projects should be located? How 

Does the Central Kupreanof Timber Harvest 

Project Fit into the Tongass Timber Sale 

Program? 

This project is currently in Gate 2, Project Analysis and Design (See 

Forest Service Handbook 2409.18, Chapter 30 and subsequent 

discussion about the Gate System) and involves environmental analysis 

and public disclosure as required by the National Environmental Policy 

Act (NEPA). The amount of volume considered for harvest under the 

action alternatives for the Central Kupreanof Timber Harvest ranges 

from 70.2 MMBF to 28.2 MMBF, with harvest potentially beginning in 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 1
2009. This volume would contribute to the Tongass timber sale 

program. A no-action alternative is also analyzed in this EIS. If an 

action alternative is selected in the decision for this project, this volume 

will be added to the volume available for sale. As displayed in Table A2, the goal for volume under analysis on the Tongass National Forest is 

299 MMBF. Currently, the forest-wide volume under analysis is about 

300 MMBF and includes the volume for this project. 

 This project contributes to the timber sale program planning objective 

of providing an orderly flow of timber from planning through harvest to 

meet timber supply requirements. A position statement (Gate 1) was 

completed to document that this project warrants additional investment 

of funds and personnel. Therefore, it is reasonable to be conducting the 

environmental analysis for this project at this time. 

This project meets all laws and regulations governing the removal of 

timber from National Forest System lands, including Forest Service 

policies as described in Forest Service manuals and handbooks, and the 

Forest Plan and Record of Decision. Based on current year and 

anticipated future timber demand, and the timber supply provisions of 

the Tongass Timber Reform Act, the Central Kupreanof Timber Harvest 

is needed at this time to meet timber sale needs identified on the 

approved multiple-year timber sale plan. Anticipated budget allocations 

and resources are sufficient to prepare and offer this project for sale as 

scheduled. 

Areas are selected for environmental analysis for timber harvest projects 

for a variety of reasons. The reasons this project was considered in this 

area include: 

 The Central Kupreanof Timber Harvest Project Area contains 

sufficient acres of suitable and available forest land to make this 

timber harvest proposal reasonable. Areas with available timber 

need to be considered for harvest in order to seek to provide a 

supply of timber from the Tongass National Forest which (1) 

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

the market demand from such forest for each planning cycle, 

pursuant to Section 101 of the Tongass Timber Reform Act 

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

of past harvest. 

 The Central Kupreanof Timber Harvest will use many existing 

roads to provide access to many of the proposed timber harvest 

units, and to transport harvested logs. 

 The Central Kupreanof Timber Harvest project will use the 

existing and currently permitted LTF at Little Hamilton Bay. 

 There was local interest in timber sale opportunities. 

 The majority of the project area and proposed harvest units are 

within the Timber Production land use designation. 

Why is This Project 

Occurring in This 

Location? 

2 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
 The Central Kupreanof project area is completely within Phase 1 

lands as identified by the Timber Adaptive Management Strategy 

in the 2008 Forest Plan Record of Decision. 

 Effects on subsistence resources from timber harvest are 

projected to have few differences based on the sequence in which 

areas are harvested. Harvesting other areas with available timber 

on the Tongass National Forest is expected to have similar 

potential effects on resources, including subsistence resources, 

because of widespread distribution of subsistence use and other 

factors. Harvest within other areas is foreseeable under the Forest 

Plan. 

In conclusion, this project area can provide a mixture of uses in 

compliance with the laws that govern National Forest management 

and be consistent with current Forest Direction. 

Why is Timber from the Tongass National 

Forest Being Offered for Sale? 

On a national level, the legislative record is clear about the role of the 

timber program in the multiple-use mandate of the national forests. One 

of the original objectives for creation of national forests was to provide 

natural resources, including timber, for the American public. The 

Organic Administration Act of 1897 (partially repealed in 1976) directed 

the agency to manage the forests in order to "improve and protect the 

forest ... [and] for the purpose of securing favorable conditions of water 

flows, and to furnish a continuous supply of timber for the use and 

necessities of the citizens of the United States" (emphasis added). The 

Multiple-Use Sustained Yield Act of 1960 directs the Forest Service to 

administer federal lands for “outdoor recreation, range, timber, 

watershed, and wildlife and fish purposes.” 

The National Forest Management Act (NFMA) of 1976 states that “the 

Secretary of Agriculture...may sell, at not less than appraised value, 

trees, portions of trees, or forest products located on National Forest 

System Lands.” Although the heart of the Act is the land management 

planning process for national forests, the Act also sets policy direction 

for timber management and public participation in Forest Service 

decision making. Under NFMA, the Forest Service was directed to 

“limit the sale of timber from each national forest to a quantity equal to 

or less than a quantity which can be removed from such forest annually 

in perpetuity on a sustained-yield basis.” 

The NFMA directs the Forest Service to complete land management 

plans for all units of the National Forest System. Forest plans are 

developed by an interdisciplinary team to provide for the coordination of 

outdoor recreation, range, timber, watershed, wildlife and fish, and 

National Legislation 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 3

Appendix A
wilderness. Forest plans designate areas of national forest where 

different management activities and uses are considered appropriate 

including those areas suitable for timber harvest. 

Timber from the Tongass National Forest is being offered for sale as 

part of the multiple-use mission of the Forest Service identified in the 

public laws guiding the agency. In addition, Alaska-specific legislation 

and the Tongass Forest Plan direct the Forest Service to seek to provide 

timber to meet market demand, subject to certain limitations. 

The Alaska National Interest Lands Conservation Act (ANILCA) and 

the Tongass Timber Reform Act (TTRA) provide direction on the issue 

of Tongass timber supply. Section 101 of TTRA amended the ANILCA 

timber supply mandate and fixed budget appropriations and replaced 

them with the following text in Section 705 (a): 

“Sec. 705. (a) Subject to appropriations, other applicable law, and 

the requirements of the National Forest Management Act of 1976 

(P.L. 94-588); except as provided in subsection (d) of this section, 

the Secretary shall, to the extent consistent with providing for the 

multiple use and sustained yield of all renewable forest resources, 

seek to provide a supply of timber from the Tongass National Forest 

which (1) meets the annual market demand for timber from such 

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

each planning cycle.” 

The Tongass Land Management Plan was completed in 1979 and 

revised in 1997. The Record of Decision (ROD) for the 2008 Tongass 

Land Management Plan Amendment (Forest Plan) was signed by the 

Alaska Regional Forester January 23, 2008. The Forest Plan 

incorporates new resource information and scientific studies and reflects 

an extensive public involvement process. The 2008 Forest Plan defines 

appropriate activities within each of 19 land use designations (LUDs). 

Approximately 79 percent of the Tongass was allocated to LUDs where 

scheduled commercial timber harvest is not allowed. The decision for 

the 2008 Forest Plan establishes the annual average allowable sale 

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

sale) at 267 million board feet (MMBF). This is the same as the ASQ 

established for the previous Forest Plan in 1997. While technically a 

limit on sale volume, in effect the ASQ also limits the amount of timber 

that may be harvested on the Tongass National Forest. 

The environmental effects analysis in the Final EIS for the 2008 Forest 

Plan assumed the maximum timber harvest allowed under each 

alternative would occur annually over the next 100 to 150 years. In that 

way, the Forest Plan analysis displayed the maximum environmental 

effects that could be reasonably foreseen. However, substantially less 

timber volume and acres have actually been harvested over the last 

several years than the maximum level allowed under the 1997 Forest 

Alaska-Specific 

Legislation 

Tongass National 

Forest Land and 

Resource 

Management Plan 

(Forest Plan, as 

amended) 

4 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
Plan (see Figure A-1). Thus, the effects on resources are expected to be 

less than projected in the 2008 Final EIS for the Forest Plan 

Amendment. 

Figure A-1 

Tongass Timber Harvest, Fiscal Years 2001-2008 

47.8 46.0

28.0

18.7

50.8 49.6

33.8

43.1

0

10

20

30

40

50

60

2001 2002 2003 2004 2005 2006 2007 2008

 Timber Harvest - mmbf per year

The Record of Decision for the 2008 Forest Plan Amendment includes 

transition language for projects that were being planned when the Forest 

Plan was completed. That language identifies three different categories 

of projects, depending on how far along they were in the project 

planning process when the Forest Plan Amendment was completed, and 

specifies the extent to which projects in each category must comply with 

the amended Forest Plan. The transition language lists this project as 

being in Category 2, which requires the Forest Supervisor to review the 

project and incorporate the new direction in the amended Forest Plan to 

the extent this can be done without causing major disruptions in the 

implementation of the project. Information on the inclusion of the 2008 

direction is included as appropriate in the Central Kupreanof Timber 

Harvest Final EIS and will be included in the decision. 

Timber Sale Program Adaptive Management Strategy 

To further balance the competing demands and respond to requests for 

additional protection of roadless areas, the Record of Decision for the 

2008 Forest Plan Amendment also approved the Timber Sale Program 

Adaptive Management Strategy. The Strategy is based on three critical 

factors: 

1. The long-term demand for timber from the Tongass is inherently 

very uncertain, and is influenced by the ability of all interested 

parties to work together to stabilize the timber supply. 

2. The annual average ASQ of 267 MMBF is considerably higher 

than the current level of timber harvest on the Tongass. 

3. The land base associated with the ASQ includes roadless areas, 

many of which are highly valued by substantial portions of the 

public. 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 5

Appendix A
Under the Timber Sale Program Adaptive Management Strategy, actual 

operation of the timber sale program will be implemented in three 

phases, as determined by actual timber harvest levels. 

In Phase 1, the timber program will be restricted to a portion of the 

suitable land base focusing on the roaded portion and some lower-value 

roadless areas and excludes moderate and higher-value roadless areas. 

The Phase 1 portion includes approximately 537,000 suitable acres, or 

69 percent of the total suitable land base. Should the actual level of 

timber harvest reach 100 MMBF for 2 consecutive fiscal years, the 

Tongass could then plan for timber projects in the Phase 2 portion of the 

approved suitable land base, resulting in a program that operates on 

680,000 acres of suitable lands, including some moderate-value roadless 

areas. Not all of these suitable acres are scheduled for timber harvest 

during the life of this Forest Plan. If timber harvest reaches 150 MMBF 

for 2 consecutive fiscal years, the Tongass could then plan for timber 

projects in Phase 3, which includes the entire suitable land base. The 

Central Kupreanof Timber Harvest project is located in the Phase 1 

portion of the suitable land base; accordingly, planning and 

implementation of it may proceed under the Timber Sale Program 

Adaptive Management Strategy. 

The January 2001 Roadless Area Conservation Rule prohibited most 

timber harvest and road construction in inventoried roadless areas on 

National Forest System lands. The Roadless Rule has been the subject 

of several lawsuits. The authority to approve road construction and 

timber harvest in inventoried roadless areas is reserved to the Secretary 

of Agriculture (Secretary’s Memoradndum 1042-154). Such activities 

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

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

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

consistent with agency policy and procedures and has been designed to 

meet the management direction, goals and objectives, and standards and 

guidelines in the Forest Plan. 

How Does the Forest Service Develop 

Forecasts about Future Timber Market 

Demand? 

Consistent with the provisions of the Tongass Timber Reform Act, the 

Forest Service makes two types of forecasts of market demand for 

timber from the Tongass National Forest. The first, “planning cycle 

market demand,” forecasts the long-term demand for timber from the 

Tongass over the life of the Forest Plan, derived from trends in 

international demand for end products manufactured from such timber. 

Based on these long-term projections, the Forest Service also estimates 

Roadless Area 

Conservation Rule 

6 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
annual market demand in order to determine how much timber to plan to 

offer for sale. 

Research economists with the Forest Service’s Pacific Northwest (PNW) 

Research Station have prepared several studies of “planning cycle 

market demand” for Tongass timber, including three General Technical 

Reports by Brooks and Haynes (1990, 1994, and 1997). In 2006, the 

PNW Research Station published new harvest projections (Brackley et 

al. 2006). This report and an addendum to it (Brackley and Haynes, 

2008) provided key information for the 2008 Forest Plan Amendment 

analysis. 

The Brackley et al. 2006 projections include four scenarios: 1) limited 

lumber production, which represents the situation the timber industry in 

Southeast Alaska has faced over the last several years; 2) expanded 

lumber production, which assumes some form of demand stimulus 

occurs; 3) medium integrated industry, which assumes sufficient 

demand stimulus occurs to cause an expansion of the current industry 

capacity and better utilization of forest products removed from public 

timber sales; and 4) high integrated industry, assumes some kind of 

additional demand stimulation to result in full utilization of all types of 

forest products available from the Tongass. More detailed information 

about these scenarios and their assumptions is in the Forest Plan 

Amendment Final EIS and ROD (January 2008), and in Brackley and 

Haynes, 2008. 

The Brackley et al. 2006 study displays alternative projections of 

derived demand for timber from the Tongass National Forest. For the 

first two scenarios, which assume no market for low-grade sawlogs and 

utility volume, the estimates of planning cycle demand include 

sawtimber only. For the two integrated industry scenarios, the 

projections include total volume, including both sawlogs and utility. 

Utility volume must be cut down along with higher-quality timber even 

if there is no demand for it. It is the total volume of timber cut on the 

Tongass that is of most interest, in part because environmental effects 

result from total volume cut. In addition, any comparison of scenarios 

must be based on comparable figures. Table A-1 shows annualized 

Brackley et al 2006 projections for all four scenarios in terms of total 

volume. 

Market Demand for 

the Planning Cycle 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 7

Appendix A
Table A-1 

Tongass National Forest Timber Sale Volume Necessary to 

Supply Derived Demand for Decked Log Volume and Chips, 

in Million Board Feet (MMBF); (Alexander, 20081

) 

Year Scenario 1 

Limited 

lumber 

Scenario 2 

Expanded 

lumber 

Scenario 3 

Medium 

integrated 

Scenario 4 

High 

integrated 

2007 49.8 61.9 67 67 

2008 49.8 66.4 139 139 

2009 51.3 72.4 151 151 

2010 52.8 78.5 166 166 

2011 52.8 84.5 184 184 

2012 54.3 90.5 204 286 

2013 55.8 98.1 204 291 

2014 57.3 105.6 204 295 

2015 58.9 113.2 204 299 

2016 58.9 122.2 204 303 

2017 60.4 131.3 204 308 

2018 61.9 140.3 204 312 

2019 63.4 150.1 204 317 

2020 64.9 163.0 204 325 

2021 66.4 175.0 204 333 

2022 67.9 187.1 204 342 

2023 69.4 200.7 204 351 

2024 70.9 215.8 204 360 

2025 72.4 230.9 204 370 

1 Annualized calculation to fulfill derived demand scenarios from Brackley et al. (2006). This table was 

created using annualized values provided by Dr. Allen Brackley (personal communication, Nov 29 2006) 

from the model used to develop derived demand estimates in Brackley et al. (2006). The values for Limited 

Lumber Scenario and Expanded Lumber scenarios reported in this table have been adjusted to include low 

quality material not included in the demand projections and include saw logs, cedar export, and utility (chip) 

volumes available from sawmill production. The Medium and High Integrated Scenarios are not adjusted 

and include saw logs, cedar exports, chip volumes, low-grade material, and utility in Brackley et al. (2006). 

After the Brackley et al. 2006 study was published, the Regional 

Forester approved a policy under which timber purchasers may ship to 

the lower 48 states unprocessed certain small-diameter and low-quality 

logs harvested from the Tongass, up to 50 percent of the volume 

harvested on each sale. This policy creates a market opportunity for 

low-quality material that the Brackley et al. 2006 study assumed would 

not be utilized under scenarios 1 and 2. In response to the new interstate 

shipment policy and other recent events, Brackley and Haynes (2008) 

conclude that “[D]emand for national forest timber in Alaska is on a 

trajectory more similar to the scenario 2 (expanded lumber production).” 

8 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
The annual market demand forecast is a methodology used to set the 

short-term goals for the Tongass timber sale program, volume the 

Forest plans to offer for sale in the current year pending sufficient 

funding. 

The formulas and procedures used in forecasting annual market demand 

are described in a Forest Service report titled Responding to the Market 

Demand for Tongass Timber (Morse, 2000). These procedures, which 

have become known as the “Morse methodology,” are based on the 

premise that: 

 Forest product markets are volatile, especially in the short run. 

 Timber purchasers in Southeast Alaska have few alternative 

suppliers of timber if they cannot obtain it from the Tongass 

National Forest. Oversupplying this market has relatively few 

adverse economic effects; undersupplying it can have much 

greater negative economic consequences. 

 It takes years to prepare National Forest timber for sale, 

including completion of environmental impact statements. 

 It is difficult to estimate demand for timber from the Tongass, 

even a year or two in advance. 

 Industry must be able to respond to rapidly changing market 

conditions in order to remain competitive. 

Accordingly, the Morse methodology establishes a system that considers 

factors such as mill capacity and utilization of that capacity, and seeks to 

build and maintain sufficient volume of timber under contract (i.e., 

timber purchased but not yet harvested) to allow the industry to react 

promptly to market fluctuations. Industry actions such as annual harvest 

levels are monitored and timber program targets are developed by 

estimating the amount of timber needed to replace volume harvested 

from year to year. The methodology is adaptive, because if harvest level 

drop below expectations and other factors remain constant, future timber 

sale offerings would also be reduced to levels needed to maintain the 

target level of volume under contract. Conversely, if harvest levels rise 

unexpectedly, future timber sale targets would also increase sufficiently 

to ensure that the inventory of volume under contract is not exhausted. 

By dealing with uncertainty in a flexible, science-based fashion, the 

Morse methodology is an example of adaptive management. 

The Morse methodology originally used the projected harvest from the 

final 1997 Brooks and Haynes report. These procedures were recently 

updated (Alexander, 2008) to use the annual projected harvest figures 

from Brackley et al. 2006 in calculations of annual timber offer targets. 

No further changes to the Morse methodology were required as a result 

of the updated long-term demand projections contained in the Brackley 

et al. study. 

Annual Market 

Demand 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 9

Appendix A
Using the updated annual market demand procedures, the Forest Service 

has set a goal for volume to be offered in FY 2009 of 177 MMBF. This 

figure was calculated using the Brackley et al. 2006 “expanded lumber 

scenario.” Due to the Region 10 shipment policy and the success of 

Alaska producers in niche or specially markets, Brackley et. al 2008 

determined that demand for National Forest timber in Alaska is on a 

trajectory most similar to the scenario 2 (expanded lumber production). 

The actual volume of timber offered for sale reflects a combination of 

factors, such as final budget appropriations, completing the NEPA 

process; the practice of offering smaller sales for smaller operators 

rather than all the volume from a NEPA decision; the statutory 

requirement that timber sales offered in the Alaska Region appraise 

positive; and volume enjoined from being offered because of litigation. 

The spreadsheet displaying the annual demand calculation and a 

summary of the factors used in these calculations are in the project 

record. 

The planned annual timber volume offer could include a combination of 

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

timber and salvage will be components of the program. Offerings will 

consist of those targeted for Small Business qualified firms, as well as a 

portion of the volume being made available for the open market. 

For planning and scheduling purposes, the Tongass uses a 5-year timber 

sale plan, which is consistent with Forest Service Manual 2430. This 5-

year plan is based on completed and ongoing environmental analyses 

and contains information to purchasers and other interested parties, and 

provides a plan that can be adjusted in response to changing market 

conditions. 

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

demand” projections are important for timber sale program planning 

purposes. They provide guidance to the Forest Service to request 

budgets, to make decisions about workforce and facilities, and to 

indicate the need to begin new environmental analysis for future 

program offerings. They also provide a basis for expectations regarding 

future harvest, and thus provide an important source of information for 

establishing the schedule of probable future sale offerings. The weight 

given to the projections will vary depending on a number of factors, 

such as how recently they were done and how well they appear to have 

accounted for recent, site-specific events in the timber market. More 

information on timber demand on the Tongass National Forest is 

presented in Appendix G in the 2008 TLMP FEIS (USDA Forest 

Service 2008c). 

10 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
What Steps Must Be Completed to Prepare a 

Sale for Offer? 

The Tongass National Forest’s timber sale program is complex. A 

number of projects are underway at any given point in time, each of 

which may be in a different stage of planning and preparation. A system 

of checkpoints, or “gates”, helps the Forest Service track the 

accomplishments of each stage of a project from inception to contract 

termination. 

Gate 1 – Initial Planning of Timber Sale Project 

A Timber Sale Project Plan, often referred to as a Position Statement, is 

a brief analysis of the project area with the intent of determining the 

feasibility of a potential timber sale. After the Position Statement is 

developed, the Forest Service decides whether the project area merits 

continued investment of time and funds in sale planning.

Gate 2 – Project Analysis, Sale Area Design, and Decision 

This step is commonly referred to as the “NEPA” phase and includes 

field work, public scoping, analysis, draft disclosure of the effects of the 

project on the environment, public comment, final analysis and 

disclosure, decision, and potentially administrative appeals and 

litigation. Gate 2 activities must be completed before a sale is awarded. 

Legislation, policy changes, and appeals and litigation have recently 

extended completion of some projects, often doubling the desired time 

frame. 

Gate 3 – Preparation of a Timber Sale 

During this step, the information and direction included in the decision 

document from Gate 2 is used to layout units and design roads on the 

ground. Additional site-specific information is collected at this time. In 

order to maintain an orderly flow of sales, Gate 3 activities need to be 

complete before a sale is advertised. 

Gate 4 – Advertise a Timber Sale 

The costs and value associated with the timber sale designed in Gate 3 

are appraised and packaged in a timber sale contract. The contract is a 

legally binding document that tells a prospective timber sale purchaser 

how the sale must be harvested to conform to the project decision 

document. This step occurs during the final year of the project 

development and culminates with the advertisement of the project for 

sale. 

Gate 5 – Bid Opening 

Gate 5 is completed with the opening of bids for the project. If a bid is 

submitted, contractual provisions govern when the award of the sale 

takes place, when the sale will be completed (contract length and 

operation season), and how timber removal is to occur. 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 11 Appendix A
Gate 6 – Award a Timber Sale Contract 

Gate 6 is the formal designation of a contract between a bidder and the 

Forest Service. 

How Does the Forest Service Maintain an 

Orderly and Predictable Timber Sale 

Program? 

As discussed earlier, the Forest Service tracks the accomplishment of the 

different steps of development of each timber sale with the Gate System 

(Forest Service Handbook 2409.18). From a timber sale program 

standpoint, it is also necessary to track and manage multiple projects as 

they move through the Gate System. Because of the timeframes needed 

to accomplish a given timber sale and the complexities inherent in 

timber sale project and program development, it is necessary to track 

various timber sale program volumes from Gate 1 through Gate 6. 

The goal of the Tongass National Forest is to provide an even flow of 

timber sale offerings on a sustained-yield basis to meet market demand. 

In recent years, this has been difficult to accomplish due to a 

combination of uncertainties such as delays related to appeals and 

litigation; changing economic factors, such as rapid market fluctuations; 

and industry-related factors, such as changes in timber industry 

processing capabilities. To achieve an even flow of timber sale 

offerings, ‘pools’ of volume in various stages of the Gate System are 

maintained so volume offered can be balanced against current year 

demand and market cycle projections. 

Today, upward trends in demand are resolved by moving out-year 

timber projects forward, which may leave later years not capable of 

meeting the needs of the industry. In other instances, a number of new 

projects are started based on today’s market but will not be available for 

a number of years. By the time the added projects are ready for offer, 

the market and demand for this volume may have changed. Three pools 

of timber volume are tracked to achieve an even flow of timber sale 

offerings. 

The objective of the timber pools concept is to maintain sufficient 

volume in preparation and under contract to be able to respond to yearly 

fluctuations in a timely manner. Table A-2,displays the current 

estimated volume in each pool, as well as the goal which the Tongass 

has established for the volume to be maintained in each pool, based on 

historic patterns. Appeals and litigation can cause timber sale projects to 

be reevaluated to ensure they meet current standards and direction, 

which can cause delays in making projects available to move through 

the pools, thereby not fully meeting the goals for volumes in each pool. 

Pools of Timber 

(Pipeline Volume) 

12 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
Pool 1 - Timber Volume Under Analysis (Gate 1 and Gate 2) 

Volume in Gate 1, the initial planning step, represents a large amount of 

volume, but represents a relatively low investment in each project. This 

relatively low investment level offers the timber program manager a 

higher degree of flexibility and thus, does not greatly influence the flow 

of volume through the pipeline. A signed Project Plan (FSH 2409.18, 

Chapter 20) is the completion of this gate. 

Gate 2, timber volume under environmental analysis, includes sales 

being analyzed and undergoing public comment through the NEPA 

process. This pool includes any project that has started the scoping 

process through those projects ready to have a decision issued. In 

addition, tracking how much volume is involved in appeals or litigation 

may be necessary to determine possible effects on the flow of potential 

timber sales. A signed NEPA decision (FSH 2409.18, Chapter 30) is the 

completion of this gate. Volume affected by appeals and litigation is 

tracked as a subset of this pool (Table A-3). 

Based on historic patterns, the Tongass has established a goal for the 

pipeline volume to be maintained in each of the timber pools. The goal 

for Pool 1 is to be maintained at approximately 4.5 times the amount of 

the projected harvest to account for projects at various stages of analysis. 

That goal reflects a number of factors which can lead to a decrease in 

volume available, such as a decision in Gate 1 to drop further analysis in 

a particular planning area (called the “no go” decision), a falldown in 

estimated volume between Gate 1 and Gate 2, and volume not available 

for harvest due to appeals or litigation. 

Pool 2 - Timber Volume Available for Sale (Gates 3, 4 and 5) 

Timber volume available for sale includes sales for which environmental 

analysis has been completed, and have had any administrative appeals 

and litigation resolved. Enough volume in this pool is needed to be 

maintained to be able to schedule future sale offerings of the size and 

configuration that best meets market needs in an orderly manner. 

As a matter of policy and sound business practice, the Forest Service 

announces probable future sale offerings through the Periodic Timber 

Sale Announcement. Delays at Gate 2 have affected sale preparation 

(Gate 3) and have made scheduling of sales uncertain. At Gate 4, sales 

have been fully prepared and appraised, and are available to managers to 

advertise for sale. This allows potential purchasers an opportunity to do 

their own evaluations of these offerings to determine whether to bid, and 

if so, at what level. 

Timber in this pool can include a combination of new sales, previously 

offered unsold sales, and remaining volume from cancelled sales. The 

goal is to maintain Pool 2 at approximately 1.3 times the amount of the 

projected harvest to allow flexibility in offering sales. 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 13 Appendix A
Pool 3 - Timber Volume Under Contract (Gate 6) 

Timber volume under contract contains sales that have been sold and a 

contract awarded to a purchaser, but which have not yet been fully 

harvested. Contract length is based on the amount of timber in the sale, 

the current timber demand, and the accessibility of the area for 

mobilization. The longer the contract period, the more flexibility the 

operator has to remove the timber based on market fluctuations. Timber 

contracts typically initially give the purchaser 3 years to harvest and 

remove the timber purchased; however, they can be extended under 

certain circumstances, such as inoperable periods of weather, 

injunctions, and other contractual delays. 

The Tongass attempts to maintain roughly 3 years of unharvested 

volume under contract to the industry as a whole. This volume of timber 

is the industry’s dependable timber supply, which allows adaptability for 

business decisions. This practice is not limited to the Alaska Region, 

but is particularly pertinent to Alaska because of the nature of the land 

base. The relative absence of roads, the island geography, the steep 

terrain, and the consequent isolation of much of the timber land means 

that timber purchasers need longer-than-average lead times to plan 

operations, stage equipment, set up camps, and construct roads prior to 

beginning harvest. 

A combination of projected harvest and projected demand is used to 

estimate the volume needed to maintain an even-flow timber sale 

program. As purchasers harvest timber, they deplete the volume under 

contract. Timber harvest is then planned and offered by the agency as 

sales that give the industry the opportunity to replace this volume and 

build or maintain their working inventory. Although there will be 

variation for practical reasons from year to year, in the long-run over 

both the high points and low points of the market cycle, the volume 

harvested will equal the timber volume sold, excluding cancelled sales. 

The goal for Pool 3, volume under contract, is to maintain timber 

volume at approximately three times the amount of annual projected 

harvest. This allows the purchasers to have a continuous supply of 

timber volume available for harvest so they can plan their operations and 

be flexible to allow for weather conditions and market fluctuations. 

14 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
Table A-2 

Accomplishments in Gate System and Timber Pools (MMBF) 

Pipeline Pool Volume 2009 Goal FY 09 

Pool 1 

Volume Under Analysis 

 (Gate 1 and 2) 

326 1 460 

Pool 2 

Volume Available for Sale 

 (Gate 3, Gate 4 and Gate 5) 

94 2 443

Pool 3 

Volume Under Contract

 (Gate 6)

217 4

 92 5

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

current year (72.4 MMBF for 2009 based on expanded lumber scenario). Volume under analysis 

includes all volume in projects from the Notice of Intent through completion of the 

environmental analysis for sales planned. 

2

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

current year (72.4 MMBF) in sales that have approved NEPA and completion of timber sale 

preparation. 

3 This is the estimated volume that is expected to appraise positive and is not slated for multiple 

small sales over a period of years. Some projects (75 mmbf) will have small sales offered first 

and the total volume from these projects will not be available this year. As a result, only 19% of 

the NEPA-cleared Pool 2 volume (232 mmbf) is readily available for sale. This figure also 

includes volume under litigation – see Table A-3. 4

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

contract as projected for harvest for the current year (72.4 MMBF). 

5 Estimated volume under contract available for harvest from July 2009 report 

Timber harvest projects require site-specific environmental analysis that 

usually is documented in an environmental assessment (EA) or an 

environmental impact statement (EIS). The public is notified of the 

analysis and is provided the opportunity to comment on proposals and 

file an appeal on decisions. The administrative appeal process for most 

timber harvest projects takes up to 105 days before implementation to 

occur. 

When decisions are appealed and affirmed through the administrative 

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

lengthy process. Although litigation does not preclude offering timber 

for sale, the Forest Service and potential purchasers are often reluctant to 

enter into a contract where the outcome is uncertain. Recently, sales 

were enjoined from harvest after the contracts were awarded. The 

outcome of litigation affects the Forest’s ability to provide a reliable 

timber supply. 

How Appeals and 

Litigation Affect the 

Timber Sale 

Program 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 15 Appendix A
Table A-3 

Timber Volume Involved in Appeals and/or Litigation 1

Timber volume with decision reversed on 

appeals 2

72.8 MMBF 

Timber volume involved with litigation 41.7 MMBF 1

 As of August 2009. 

2

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

period or undergoing an appeal review. 

How Does The Forest Service Decide Where 

Timber Harvest Projects Should Be Located? 

The location of timber sale projects is based first on the land allocation 

decisions in the Forest Plan. Under the Forest Plan, lands designated for 

possible timber harvest are in the development land use designations 

(LUDs), primarily the Timber Production, Modified Landscape, and 

Scenic Viewshed LUDs. 

The second consideration is the suitability of the land for timber 

production. Many acres within the development LUDs are not suitable 

for timber production due to poor soils or steep slopes. The process for 

determining the suitability of the land is found in the 2008 Forest Plan 

Amendment, Appendix A. Figure A-2 depicts the classification of all 

the lands within the Tongass National Forest. Four percent of the 

Tongass land base, the suitable, available and scheduled forest land, 

provides the land base for the allowable sale quantity of 267 MMBF per 

year. Under the 2008 Forest Plan, the remainder of the land, 

approximately 96 percent or 663,000 acres, is not physically suitable, 

does not allow timber harvest, or is not scheduled. 

Timber Resource 

Land Suitability 

16 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
Figure A-2 

2008 Forest Plan Timber Resource Suitability Analysis 

Non-Forest land

41%

 Withdrawn lands

25%

Non-Productive Forest

14%

Productive Forest 

Suitable and Available -

 Scheduled 4%

Productive Forest NonDevelopment LUD

8%

Productive Forest 

Suitable and Available - 

Unscheduled 2%

Productive ForestNot suitable

6%

Non-Forest land – Land that has never supported forests, e.g. muskeg, rock, ice, etc. 

Withdrawn Lands – Lands designated by Congress, the Secretary of Agriculture, or Chief for purposes that 

preclude timber harvest, e.g. Wilderness Areas. 

Non-productive Forest – Forest land not capable of producing commercial wood on a sustained yield basis. 

Productive Forest, Not suitable, Physical Attributes – Forest land unsuitable for timber due to physical 

attributes (steep slopes, soils, etc.) and/or inadequate information to ensure restocking of trees within five 

years of final harvest. 

Productive Forest, Not Suitable, Non-development LUD – Productive forest lands where timber production 

is not allowed due to Forest Plan land use designation, e.g. Semi-Remote Recreation, Old-growth Habitat, 

etc. 

Productive Forest, Suitable and Available, Scheduled – Forest land that meets all the criteria for timber 

production suitability and is available and is scheduled by the Forest Plan over the planning horizon. 

Productive Forest Suitable and Available Unscheduled – Forest land that meets all the criteria for timber 

production suitability, is available for harvest, however was not scheduled in the Forest Plan model for 

harvest includes the model implementation reduction factor (MIRF) acreage of 226, 000 acres. 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 17 Appendix A
District-Level Planning 

The Tongass National Forest is divided into ten ranger districts. As 

described in the 2008 Forest Plan Amendment ROD, under the Timber 

Sale Program Adaptive Management Strategy, the timber sale program 

will be implemented in three phases as determined by actual timber 

harvest levels. For current planning and scheduling purposes, the Forest 

will operate on the Phase 1 portion of the suitable land base, capable of 

supporting a sustained harvest of 150 MMBF annually. Personal use of 

timber, micro sales, salvage sales, small commercial timber sales 

generally less than one MMBF, young-growth management projects, 

and the roads associated with these activities, would be allowed in 

development LUDs outside of the Phase 1 portion of the ASQ land base. 

The Forest Supervisor for the Tongass National Forest is responsible for 

the overall management of the Forest’s timber sale program. Included 

within these responsibilities is making the determination on the amount 

of timber volume to be made available to industry. Whether or not 

sufficient funding is appropriated to attain the program is the 

responsibility of the Congress and the President. 

District Rangers develop a timber sale plan of potential timber harvest 

projects. The goal of the plan is to attain the targeted offer level for the 

current year, based on the estimated annual market demand, and to 

develop a timber program for several years of the planning cycle. The 

offer level for the current year is based, to the extent possible, on the 

forecasted annual market demand. Actual demand may fluctuate from 

year to year due to short-term market fluctuations. Actual offer levels 

vary year to year depending on several factors, including volume in 

Gates 2 through 3, and current market conditions. 

The District Ranger is responsible for identifying and recommending the 

project areas for the 5-Year Timber Sale Plan. The Ranger’s role is to 

develop and recommend to the Forest Supervisor timber harvest projects 

that meet Forest Plan goals and objectives. Districts work on various 

timber sale projects simultaneously, resulting in continual movement of 

projects through the stages of the timber program pipeline. This 

schedule allows the necessary time to complete preliminary analysis, 

resource inventories, environmental documentation, field layout 

preparations and permit acquisition, appraisal of timber resource values, 

advertisement of sale characteristics for potential bidders, bid opening, 

and physical award of the timber sale. Project delays through the 

completion of Gate 2 attributable to legal injunctions and litigation have 

affected the offer level in recent years. Once all of the Rangers’ 

recommendations are made and compiled into a consolidated schedule, 

the Forest Supervisor is responsible for the review and approval of the 

final timber sale plan and prioritization of projects as necessary. 

18 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
Considerations the District Ranger takes into account for each project 

include: 

 If the project area contains a sufficient number of suitable timber 

production acres allocated to development land use designations. 

Consideration includes if the timber volume being considered for 

harvest can be achieved while meeting Forest Plan goals, 

objectives, and standards and guidelines. 

 Other resource uses and potential future uses of the area and of 

adjacent areas and of non-National Forest System lands. 

 Areas where the investment necessary for project infrastructure 

(roads, bridges, etc) is achievable with the estimated value of 

timber volume in the project area. Where infrastructure already 

exists, the project would allow any maintenance and upgrade of 

the facilities necessary for removal of timber volume. 

 Areas where investments for the project coincide with long-term 

management based on Forest Plan direction. 

The implementation of the sales on the timber sale plan depends in part 

on the final budget appropriation to the agency. In the event insufficient 

budget is allocated, or resolution of pending litigation or other factors 

delay planned sales, timber sale projects are selected and implemented 

on a priority basis. Generally, the higher-priority projects include sales 

where investments such as road networks, camps or log transfer 

facilities have already been established or where land management 

status is not under dispute. The distribution of sales across the Tongass 

is also taken into account to distribute the effects of sales and to provide 

sales in proximity to timber processing facilities. Timber sale projects 

scheduled for the current year that are not implemented, or the 

remaining volume of projects that are only partially implemented, are 

shifted to future years in the plan. The sale plan becomes very dynamic 

in nature due to the number of influences on each district. 

Conclusion 

There is a long legislative recognition that timber harvest is one of the 

appropriate activities on national forests, starting with the founding 

legislation for national forests in 1897. The Organic Administration Act 

provides that national forests may be established “to improve and 

protect the forest within the boundaries, or for the purpose of securing 

favorable conditions of water flows, and to furnish a continuous supply 

of timber for the use and necessities of the citizens of the United States.”

Congress’s policy for national forests, as stated in the Multiple-Use 

Sustained Yield Act of 1960, is “the national forests are established and 

shall be administered for outdoor recreation, range, timber, watershed, 

and wildlife and fish purposes.” Accordingly, Congress has authorized 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 19 Appendix A
the Secretary of Agriculture to sell trees and forest products from the 

national forests “at no less than appraised value.” The National Forest 

Management Act directs that forest plans shall “provide for multiple use 

and sustained yield, and in particular, include coordination of outdoor 

recreation, range, timber, watershed, wildlife, fish and wilderness.” 

ANLICA provided for timber harvest from the Tongass as well as other 

uses such as subsistence. Effects on subsistence resources from timber 

harvest Tongass-wide are projected to have few differences based on the 

sequence in which areas are harvested. Because of the multiple use 

mandate and other requirements of the laws, these effects to subsistence 

are necessary, consistent with sound management of public lands.

In addition to nationwide statutes, Section 101 of the Tongass Timber 

Reform Act directs the Forest Service to seek to meet market demand 

for timber from the Tongass, subject to certain qualifications. It is the 

goal of the Tongass National Forest to provide an even-flow of timber 

on a sustained-yield basis and in an economically efficient manner. The 

amount of timber offered for sale each year is based on the objective of 

offering enough volume for sale to meet the projected annual demand. 

That annual demand projection starts with installed mill capacity, and 

then looks to industry rate of capacity utilization under different market 

scenarios, the volume under contract, and a number of other factors, 

including anticipated harvest and the range of expected timber 

purchases. 

As described by Morse (April 2000), in terms of short-term economic 

consequences, oversupplying the market is less damaging than 

undersupplying it. If more timber is offered than purchased in a given 

year, the unsold volume is still available for re-offer in future years. The 

unsold volume would have no environmental effects because it would 

not be harvested. Conversely, a short fall in the supply of timber can be 

financially devastating to the industry. 

20 ▪ Appendix A Central Kupreanof Timber Harvest FEIS Appendix A
References 

Alexander, S. 2008. Tongass National Forest Timber Sale Procedures: 

Using Updated Information about Market Demand to Schedule FY 2006 

Timber Offerings. USDA Forest Service Region 10, Juneau AK. 10 p. 

On file with: Regional Economist, Alaska Region, PO Box 21628, 

Juneau AK 99802. 

Brackley, A.M.; Rojas, T.D.; Haynes, R.W. 2006. Timber products 

output and timber harvests in Alaska: projections for 2005-25. Gen. 

Tech. Rep. PNW-GTR-677. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 33 p. 

Brackley, A.M. and Haynes, R.W. 2008. Timber Products Output and 

Timber Harvests in Alaska: An Addendum. Res. Note PNW-RN-559. 

Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. 

Brooks, D.J.; Haynes, R.W. 1997. Timber products output and timber 

harvests in Alaska: projections for 1997-2010. Gen. Tech. Rep. PNWGTR-409. Portland, OR: U.S. Department of Agriculture, Forest 

Service, Pacific Northwest Research Station. 17 p. 

Morse, K.S. 2000a. Responding to the Market Demand for Tongass 

Timber: Using Adaptive Management to Implement Sec. 101 of the 

1990 Tongass Timber Reform Act. April 2000. Manag. Bull. R10-MB413. Juneau, AK: U.S. Department of Agriculture, Forest Service, 

Alaska Region. 43 p. 

Morse, K.S. 2000b. Tongass National Forest timber sale procedures: 

Using Information About Market Demand to Schedule FY2001 Timber 

Sale Offerings. October 2000. On file with: Regional Economist, 

Ecosystem Planning. Juneau, AK: U.S. Department of Agriculture, 

Forest Service, Alaska Region. 17 p. 

USDA Forest Service, 2008a, Forest Plan Amendment Record of 

Decision, January 2008. 

USDA Forest Service, 2008b, Forest Plan, January 2008. 

USDA Forest Service, 2008c, Forest Plan Amendment Final 

Environmental Impact Statement, January 2008. 

USDA Forest Service. 2003. Supplemental Environmental Impact 

Statement. Juneau, Alaska: U.S. Department of Agriculture, Forest 

Service, Alaska Region, Tongass National Forest. R10-MB-481a. 

Central Kupreanof Timber Harvest FEIS Appendix A ▪ 21 Appendix A
Appendix B 

Activity Cards 
Appendix B 

Table of Contents 

Introduction to Appendix B..................................................1 

Introduction to Road Management Objectives.............................2 

Operational and Objective Maintenance Levels...........................5 

AFRPA Status...................................................................6 
Introduction to Appendix B 

Activity cards (unit and road cards) are used to explain site-specific 

proposed activities and any resource concerns and responses. These 

activities include timber harvest units and proposed and existing roads 

needed for timber harvest. A complete set of both narratives and maps 

showing site-specific information were provided in the DEIS and can 

be found in the project record. 

 

In response to comments received from the State between the Draft 

and Final EIS changes were made to a number of road cards. Some 

site specific design criteria related to the potential construction of new 

NFS road and temporary roads has been updated. A complete and 

updated set of road cards are provided in this FEIS. 

The Record of Decision for the Central Kupreanof Timber Harvest 

will include those activity cards for all units and roads associated with 

the Selected Alternative. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 1
Introduction to Road Management 

Objectives 

The Road Management Objectives (RMOs) presented in this appendix 

establishes the intended purpose and display design maintenance and 

operation criteria (as per FSH 7709.55) for each National Forest 

System road in the Central Kupreanof Timber Harvest project area. 

The information on the RMO form is part of a permanent database that 

can be updated periodically as access needs, issues, and budgets 

change. Proposed new roads and existing roads with planned 

reconstruction or maintenance have a second section with site specific 

design criteria that will be used during design, construction, and initial 

monitoring of any road work proposed in this document. The road 

segments are described using mileposts (MP) as beginning and ending 

points (Beginning milepost = Bmp; Ending milepost = Emp). Lengths 

are given in miles (mi). Road width is given in feet. Culverts are 

identified as cmp. See Figure B-1 for a map of the Central Kupreanof 

Timber Harvest project area showing existing road locations. 

The general design criteria provide various descriptions of the type of 

road and the intended purpose and future use of the road. From this 

information, the maintenance and operation criteria can be developed. 

All Central Kupreanof Timber Harvest roads are constructed and 

maintained for silvicultural purposes, and will apply the practices 

described in BMP 12.5. Therefore, they meet the criteria for a 

silvicultural exemption from permitting under the Clean Water Act 

Section 404. General Design Criteria and Elements are shown on the 

Road Management Objectives portion of the road cards and are 

defined as follows: 

• Functional Class: Local (L), Collector (C), and Arterial (A) 

classifications 

• Service Life: Long (L) or Short (S), Constant (C) or Intermittent (I) 

The maintenance criteria include a discussion of how the road is to be 

maintained, centering on three strategies: 

•Active: provide frequent cleanout of ditches and catch basins to 

assure controlled drainage. Control roadside brush to maintain sight 

distance. Grade as needed to maintain crown and running surface. 

•Storm Proof: provide water bars, rolling dips, out sloping, etc., to 

assure controlled runoff until any needed maintenance can be 

Purpose and Use 

General Design 

Criteria 

Maintenance 

Criteria 

2 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
performed on the primary drainage system. Control roadside brush to 

maintain passage. 

•Storage: remove or bypass all drainage structures to restore natural 

drainage patterns, add water bars as needed to control runoff, 

revegetate. 

The active maintenance strategy is applied to roads that are open and 

maintained for travel by a prudent driver in a standard passenger car. 

User comfort and convenience are not considered priorities. These 

roads are assigned Maintenance Level 3. The active maintenance 

strategy will also at times be applied to roads intended only for use by 

high clearance vehicles, or Maintenance Level 2 roads. This will 

usually be the case when log haul is expected in the near future. 

An intermediate maintenance strategy is to storm proof, or to stabilize 

the road by providing roadway features such as drivable water bars 

and out sloping to control runoff in case the primary drainage system 

of culverts and ditches is overwhelmed during a storm event. Each 

culvert will be evaluated as to where the water would go if the culvert 

were to fail to carry the high flow. A water bar or out slope at this 

location will minimize the potential for erosion of long stretches of 

ditch line or roadway. This is intended to be the primary maintenance 

strategy applied to roads assigned Maintenance Level 2. 

Storage is intended to be the primary maintenance strategy on 

intermittent use roads during their closure cycle. Road storage is 

defined in FSH 5409.17 as “the process/action of closing a road to 

vehicle traffic and placing it in a condition that requires minimum 

maintenance to protect the environment and preserve the facility for 

future use.” In this strategy, the bridges and culverts on live streams 

may be completely removed to restore natural drainage patterns. Cross 

drains and ditch relief culverts will be bypassed with deep water bars 

but may be left in place to minimize the cost of re-using these roads in 

the future. Roads in storage are left in a self-maintaining state in order 

to use more road maintenance funds on the open drivable roads on the 

island. Maintenance Level 1, closure and basic custodial maintenance, 

is assigned. 

The interdisciplinary team went through a process defining road 

management considerations leading to the maintenance strategy to be 

applied to each road in the project area. The Road Cards show the 

desired future condition of each road in the project area as a result of 

the process. The work needed to meet the objectives can be 

accomplished on the roads along the haul route in resultant contracts. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 3
Work needed on other roads to meet the desired objective would be 

scheduled as funding allows. 

The operations criteria include a presentation of each of the five traffic 

management strategies identified in FSM 7731 (encourage, accept, 

discourage, prohibit, and eliminate) to be applied to different traffic 

classes on each road. The traffic management narrative describes what 

actions will be taken in order to apply each strategy. For example, if 

the strategy “eliminate” is prescribed for standard passenger and high 

clearance vehicles, the narrative describes the method to accomplish 

this, such as removal of stream crossing. Traffic management 

strategies for the NFS roads are displayed on the Road Management 

Objectives (Road Cards). 

The site-specific design criteria section includes road location 

objectives, wetland information, erosion control, proposed rock 

borrow sources, and all streams within the project area with proposed 

construction or rehabilitation of stream crossing structures. Log 

stringer bridges will be the preferred method of stream crossing on all 

Class III unless site conditions warrant a different crossing structure. 

Use of bridges will reduce or eliminate impacts on streams from fill 

material on streams necessary for culvert installations, and the impacts 

from the subsequent removal of the culverts when the roads are put in 

to storage. 

Prior to actual construction of roads and stream crossings, the final 

location, structure type and design criteria are designed to meet all 

applicable Forest Plan Standards and Guidelines, Forest Service 

Manual and Handbooks, Best Management Practices and MOUs with 

Alaska Department of Fish and Game (when applicable). 

Best Management Practices (BMPs) are used to assure soil and water 

resources are considered in transportation planning activities. 

Operations 

Criteria 

Site Specific 

Design Criteria 

4 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Table B-3 Fish stream crossings on NFS roads proposed for 

reconstruction1

Road # 

Mile Post Stream 

Class Channel Type 

45803 .04 2 HC2 

45803 .20 2 HC2 

45803 .23 2 HC5 

45808 2.79 2 HC3 

45808 3.49 1 MM1 

45808 3.74 1 MM1 

 1 The following BMPs will be implemented for all reconstructed and temporary road: 12.17, 

14.5, 14.6, 14.8, 14.9, 14.12, 14.14, 14.15, 14.17. See road cards 45803, 45808, 45897, and 

45886 for Class I and II stream crossing information on newly constructed NFS road. 

Operational and Objective Maintenance 

Levels 

Operational Maintenance Levels indicate the level of road 

maintenance, either Maintenance Level 2 or 3, during sale-related 

activities. Objective Maintenance Levels indicate the long-term 

maintenance plan for the roads as described in the following 

definitions. Maintenance Levels (MLs) discussed in the Road 

Management Objectives (RMOs) includes Maintenance Level 1, 2, 

and 3. The definitions for maintenance levels are from the Forest 

Service Handbook 7709.58. The purpose of the ML is to define the 

level of service provided by, and maintenance required for, a specific 

road or segment. 

Assigned to intermittent service roads during the time they are closed 

to vehicular traffic. The closure period must exceed 1 year. Basic 

custodial maintenance is performed to keep damage to adjacent 

resources to an acceptable level and to perpetuate the road to facilitate 

future management activities. Emphasis is normally given to 

maintaining drainage facilities and runoff patterns. Planned road 

deterioration may occur at this level. Appropriate traffic management 

strategies are "prohibit" and "eliminate." Roads are closed by barrier, 

bridge removal or organic encroachment and are monitored for 

resource protection. 

Assigned to roads open for use by high clearance vehicles. Traffic is 

normally minor, usually consisting of one or a combination of 

administrative, permitted, dispersed recreation, or other specialized 

Maintenance 

Level 1 

Maintenance 

Level 2 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 5
uses. Log haul may occur at this level. Appropriate traffic 

management strategies are either to (1) discourage or prohibit 

passenger cars or (2) accept or discourage high clearance vehicles. 

Assigned to roads open and maintained for travel by a prudent driver 

in a standard passenger car and are subject to the provisions of the 

Highway Safety Act. Some roads may be fully surfaced with either 

native or processed material. Appropriate traffic management 

strategies are either "encourage" or "accept." "Discourage" or 

"prohibit" strategies may be employed for certain classes of vehicles or 

Users. 

AFRPA Status 

AFRPA Class: Alaska Forest Resources and Practices Act. Under this 

Act, all roads will be maintained as "Active" during harvest-related 

activities. After these activities are completed, the AFRPA classes on 

the road cards will be implemented. These classes include: 

A forest road being actively used for hauling logs, pulpwood, chips, or 

other major forest products, or rock and other road building materials. 

A forest road on which commercial hauling is discontinued for one or 

more logging seasons, and the forest landowner desires continuation of 

access for fire control, forest management activities, occasional or 

incidental use for forest products harvesting, or similar activities. 

A road is closed when the following activities have been completed: a 

road is outsloped or waterbarred, or is left in a condition suitable to 

control erosion. The ditches are also left in a condition suitable to 

control erosion, and bridges, culverts, and fills are removed from 

surface waters. 

Maintenance 

Level 3 

Active 

Inactive 

Closed 

6 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
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c:/workspace/ckupre/plots/deis/figB_1_rmo.mxd 09-20-08 EP

Legend

Lakes

NFS Road Proposed to be Closed

Open NFS Road

Project Area Boundary

Roads in Storage (Closed)

Stream Class I 

!( Existing Rock Quarries ±

0 0.5 1 2

Miles

R

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c

k

y

P

a

s

s

Central Kupreanof Timber Harvest

Figure B-1

Road Maintenance Objectives

Big John

Bay

6314

45845
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6000 Seal Point MP 6.21 Road 6040 TTF 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.032 Existing PBGD6 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 16' 20 Log Truck Log Truck 

Intended Purpose/Future Use

Access for to TTF. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.032 2 2 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 20 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to high clearance vehicles. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 9
 

Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6328 Jasper High MP 3.96 Road 6314 Jnct 6314 & 6315 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 7.844 Existing PBGD5 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 16' 30 Lowboy Lowboy 

Intended Purpose/Future Use

Serves as part of mainline road system. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 7.844 3 3 

 

Maintenance Narrative

Road will be maintained to facilitate travel passenger car at 30 mph. All culverts, ditches and drainage structures will be serviced and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: All motorized vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to all traffic. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

10 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6333 NICE MP 4.16 ROAD 6326 SECTION 14 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.61 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local I Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Road should remain open for the first 1.434 miles. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.61 2 1 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph and all culverts, ditches and drainage structures will be serviced, 

and road brushed on this portion. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Maintain as maintenance level 2. Close road when funds are available. Road closure may include any 

combination of closure devices at the beginning of the road, pulling some or all drainage structures such as 

culverts, and/or gating. This road will be further evaluated for the most effective and efficient closure method 

prior to implementation. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 11
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45800 MP 2.85 Road 6314s 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.033 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Close road until needed in the future. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.033 1 1 

 

Maintenance Narrative

Road should be properly closed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles when open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles 

 Eliminate: Motorized vehicles 

Travel Management Narrative

This road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have re-vegetated with alder 

4” to 8” in diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and drainage structures replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale activities. 

They may remain open from five to ten years after this timber sale for other activities including fire wood removal; these roads would be constructed 

or placed in a self maintaining hydrologic status. This would include the placement of drivable water bars or dips at all drainage culvert locations to 

direct water across the road in event that the culvert plugs. Other design elements like oversized culverts may be used to help reduce the need for 

routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or natural 

vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains (water bars and dips), and 

the road would be considered stored. A review will be conducted at the time of closure for any additional resource concerns 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

12 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45806 mp 8.813 road 6314S end of Shamrock unit

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.140 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local I Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.555 2 1 

0.555 1.140 1 1 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph for the first 0.55 mile and all culverts, ditches and drainage 

structures will be serviced, and road brushed on this portion. 

Operation Criteria

Highway Safety Act: NO Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles on open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles on closed section 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

Close road properly with other funds. Road closure may include any combination of closure devices at the 

beginning of the road, pulling some or all drainage structures such as culverts, and/or gating. This road will be 

further evaluated for the most effective and efficient closure method prior to implementation. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 13
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45808 Screwdriver MP 6.67 Road 6328 Section 1 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 3.883 Existing PBGD5 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Road should remain open for the first 2.788 miles. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 2.788 2 2 

2.788 3.883 1 1 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph for open part and all culverts, ditches and drainage structures will 

be serviced, and road brushed on this portion. Remainder of road should be properly closed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles on open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles on closed section 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

Part of this road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have revegetated with alder 4” to 8” in diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and 

drainage structures replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale 

activities. They may remain open from five to ten years after this timber sale for other activities including fire wood removal; these 

roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of drivable water bars 

or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design elements like 

oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

14 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45915 MP 12.71 Road 6314S 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.089 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.089 1 1 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

This road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have re-vegetated with alder 4” to 8” in 

diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and drainage structures replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale activities. They may remain open 

from five to ten years after this timber sale for other activities including fire wood removal; these roads would be constructed or placed in a self maintaining hydrologic 

status. This would include the placement of drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. 

Other design elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or natural vegetation allowed to 

eliminate motorized access.. Drainage structures would remain in place with additional cross drains (water bars and dips), and the road would be considered stored. A 

review will be conducted at the time of closure for any additional resource concerns 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 15
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6030 Goose Lake MP 8.92 Road 6040 Section 8 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 13.288 Existing PBGD6 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 16' 30 Lowboy Lowboy 

Intended Purpose/Future Use

Serves as part of mainline road system. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 13.288 3 3 

 

Maintenance Narrative

Road will be maintained to facilitate travel passenger car at 30 mph. All culverts, ditches and drainage structures will be serviced and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: All motorized vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to all traffic. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

16 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6314 Jasper High MP 12.325 Road 6040 Section 20 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 6.767 Existing PBGD6 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 16' 30 Lowboy Lowboy 

Intended Purpose/Future Use

Serves as part of mainline road system to MP 3.96. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 3.96 3 3 

3.96 4.85 2 2 

4.85 6.767 2 decommission 

Maintenance Narrative

Road will be maintained to facilitate travel passenger car at 30 mph to MP 3.96, high clearance vehicles to 4.85, decommission to end. 

All culverts, ditches and drainage structures will be serviced and road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: All motorized vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to all traffic for first 3.96, to high clearance vehicles to 4.85, decommission to end. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 17
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6326 Marble Knobs MP 1.93 Road 6314 Section 18 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 8.076 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 8.076 2 2 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to high clearance vehicles. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

18 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6339 Notch MP 0.92 Road 6334 Section 25 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.71 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.71 2 2 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to high clearance vehicles. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 19
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45805 MP 1.42 Road 45803 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 0.387 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.387 2 1 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Maintain open during project activities close after project complete. Road closure may include any combination of tanktraps at the 

beginning of the road, pulling some or all drainage structures such as culverts, and/or gating. This road will be further evaluated for 

the most effective and efficient closure method prior to implementation. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

20 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45810 MP 0.82 Road 6315 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.190 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Close road until needed in the future. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.190 1 1 

 

Maintenance Narrative

Check if verify if road is properly closed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles when open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles 

 Eliminate: Motorized vehicles 

Travel Management Narrative

This road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have re-vegetated with alder 

4” to 8” in diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and drainage structures replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale activities. 

They may remain open from five to ten years after this timber sale for other activities including fire wood removal; these roads would be constructed 

or placed in a self maintaining hydrologic status. This would include the placement of drivable water bars or dips at all drainage culvert locations to 

direct water across the road in event that the culvert plugs. Other design elements like oversized culverts may be used to help reduce the need for 

routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or natural 

vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains (water bars and dips), and 

the road would be considered stored. A review will be conducted at the time of closure for any additional resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 21
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45803 MP 6.99 Road 6314S 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 4.608 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Road should remain open for the first 1.42 miles. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.42 2 2 

1.42 4.608 1 1 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph for open part and all culverts, ditches and drainage structures will 

be serviced, and road brushed on this portion. Remainer of road should be properly closed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles on open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles on closed section 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

Part of this road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have re-vegetated 

with alder 4” to 8” in diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and drainage structures 

replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale activities. 

They may remain open from five to ten years after this timber sale for other activities including fire wood removal; these roads would be constructed 

or placed in a self maintaining hydrologic status. This would include the placement of drivable water bars or dips at all drainage culvert locations to 

direct water across the road in event that the culvert plugs. Other design elements like oversized culverts may be used to help reduce the need for 

routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or natural 

vegetation allowed to eliminate motorized access.. Drainage structures would remain in place with additional cross drains (water bars and dips), and 

the road would be considered stored. A review will be conducted at the time of closure for any additional resource concerns 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

22 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6040 Kake Road Kake Portage Jnct Section 27 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 17.138 Existing PBGD6 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 16' 30 Lowboy Lowboy 

Intended Purpose/Future Use

Serves as part of mainline road system to MP 12.33 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 12.33 3 3 

12.33 17.138 2 2 

Maintenance Narrative

Road will be maintained to facilitate travel passenger car at 30 mph to MP 12.33, high clearance vehicles to end. All culverts, ditches 

and drainage structures will be serviced and road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: All motorized vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to all traffic for first 12.33, to high clearance vehicles to end. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 23
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6314s Keku Strait Jnct 6328 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 14.11 Existing PBGD6 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 16' 30 Lowboy Lowboy 

Intended Purpose/Future Use

Serves as part of mainline road system. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 14.11 3 3 

 

Maintenance Narrative

Road will be maintained to facilitate travel passenger car at 30 mph. All culverts, ditches and drainage structures will be serviced and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: All motorized vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to all traffic. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

24 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6327 Grebberg Mountain MP 0.27 Road 6326 Section 9 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 1.12 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Close road until needed in the future. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.121 2 1 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

This road will be closed and placed in storage within 10 years of timber sale activities. This closure will remove all culverts on live 

streams, helping restore natural drainage patterns. Cross drains and ditch relief culverts would be bypassed with deep water bars to 

minimize the cost of re-using these roads in the future. This road would remain in a self-maintaining state. 

Intermittent service road during the time of closed to vehicular traffic. Basic custodial maintenance is performed to keep damage to 

adjacent resources to an acceptable level and to perpetuate the road to facilitate future management activities. Emphasis is normally 

given to maintaining drainage facilities and runoff patterns. Planned road deterioration may occur at this level. Maybe open and 

suitable for non-motorized uses. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 25
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6330 Marble Knobs South MP 1.22 Road 6326 Section 8 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 0.88 Existing PBGD5 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Close road until needed in the future. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.880 2 1 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles when open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles 

 Eliminate: Motorized vehicles 

Travel Management Narrative

This road will be closed and placed in storage within 10 years of timber sale activities. This closure will 

remove all culverts on live streams, helping restore natural drainage patterns. Cross drains and ditch relief 

culverts would be bypassed with deep water bars to minimize the cost of re-using these roads in the future. This 

road would remain in a self-maintaining state. 

Intermittent service road during the time of closed to vehicular traffic. Basic custodial maintenance is 

performed to keep damage to adjacent resources to an acceptable level and to perpetuate the road to facilitate 

future management activities. Emphasis is normally given to maintaining drainage facilities and runoff 

patterns. Planned road deterioration may occur at this level. Maybe open and suitable for non-motorized uses. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

26 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6334 Grebberg Ridge MP 2.92 Road 6328 Section 14 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 2.142 Existing PBGD5 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 2.142 2 2 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to high clearance vehicles. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 27
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6336 Crash Ridge MP 5.76 Road 6326 Section 13 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 2.196 Existing PBGD5 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 2.196 2 2 

 

Maintenance Narrative

Road will be maintained to facilitate travel pickup truck at 10 mph. All culverts, ditches and drainage structures will be serviced, and 

road brushed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: N/A 

Travel Management Narrative

Road will remain open to high clearance vehicles. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

28 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

45807 MP 0.15 Road 45808 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 0.594 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Close road until needed in the future. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.2 2 1 

0.21 0.594 1 1 

Maintenance Narrative

Verify that road is properly closed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles when open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles 

 Eliminate: Motorized vehicles 

Travel Management Narrative

Part of this road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have re-vegetated with 

alder 4” to 8” in diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and drainage structures replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale activities. 

They may remain open from five to ten years after this timber sale for other activities including fire wood removal; these roads would be constructed 

or placed in a self maintaining hydrologic status. This would include the placement of drivable water bars or dips at all drainage culvert locations to 

direct water across the road in event that the culvert plugs. Other design elements like oversized culverts may be used to help reduce the need for 

routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or natural 

vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains (water bars and dips), and 

the road would be considered stored. A review will be conducted at the time of closure for any additional resource concerns 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 29
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus

6315 MP 7.44 Road 6328 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos

0.00 0.849 Existing 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log Truck Log Truck 

Intended Purpose/Future Use

Access for silvicultural activities. Close road until needed in the future. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.849 1 1 

 

Maintenance Narrative

Verify that road is properly closed. 

Operation Criteria

Highway Safety Act: Yes Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles when open section 

 Discourage: N/A 

 Prohibit: Motorized vehicles 

 Eliminate: Motorized vehicles 

Travel Management Narrative

This road is currently in storage. Most drainage structures have been removed to restore natural drainage pattern. They have re-vegetated with alder 4” to 8” in 

diameter. This road needs reconditioning done prior to use, requiring brushing, clearing of alder and drainage structures replaced. 

All reconstructed roads will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these timber sale activities. They may remain open 

from five to ten years after this timber sale for other activities including fire wood removal; these roads would be constructed or placed in a self maintaining hydrologic 

status. This would include the placement of drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. 

Other design elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or natural vegetation allowed to 

eliminate motorized access.. Drainage structures would remain in place with additional cross drains (water bars and dips), and the road would be considered stored. A 

review will be conducted at the time of closure for any additional resource concerns 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

30 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

 45810 45810 MP 1.19 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

1.19 1.49 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

1.19 2.68 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and maintained 

in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to maintain crown 

and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage patterns, add 

water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 31
Site Specific Design Criteria 

Road 45810 

ROAD LOCATION: The road steadily gains elevation from the beginning point at the existing Road 

45810. The first 1400 feet is a steady climb @ 10% to 15% through timber with 20% sideslopes. 

From 1400 feet to 3500 feet is a steady climb @ 10% to 15% with timber sideslopes of 40 to 60%. At 

3500 feet it enters edge of muskeg to 4300 feet. At 4300 feet climb @ 15% along steep side slope of 

80 to 110% to gain bench at top. At 5500 feet it crosses stream needing a 60” diameter pipe. Road 

ends at steep cliffs at 7400 feet. 

WETLANDS: The proposed road crosses about 454 feet of wetland in Alternative 3. The wetland 

type is muskeg/forested mosaic. Minimize the road footprint through the wetlands and provide 

adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some portions of 

the location due to safety, engineering design constraints and consideration for other resources. 

Alternatives to the location on wetlands would mean longer higher cost roads that may have impacted 

similar areas of wetlands (BMP 14.2). Overlay construction is recommended to minimize disturbance 

to the wetland and ensure hydraulic connectivity of the roaded wetland with the surrounding areas 

(BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting through Army 

Corps of Engineers. 

SOILS: A slope stability investigation will be completed by a soil specialist prior to implementation in 

areas where the proposed road crosses side slopes greater than 67%. The on-site investigation will 

follow Forest Plan protocols. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit @ station 4+00. During periods of high rainfall (as defined in current 

Regional specifications), blasting operations will be suspended at quarries near potentially unstable 

sites where ground vibration may induce mass movement (BMP 14.6). Also during these periods, 

road construction that requires rock supplied from quarries shall be suspended in high risk areas on 

roads where rock hauling would increase the risk of mass failure (BMP 14.7). Follow BMP 14.18 for 

development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

32 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
7

219

221

218

222

45810

45808

6328

6314S

0 660 1,320 2,640

Feet

Road 45810

c:/workspace/ckupre/plots/deis/rd_45810.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

45810

6315

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 33
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

6327 6327 MP 1.12 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

1.12 1.07 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

1.12 2.19 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and maintained 

in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to maintain crown 

and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage patterns, add 

water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a self maintaining state. 

. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

34 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 6327 

ROAD LOCATION: The road begins by traverseing a new thinning unit for the first 11+00 feet. The 

road location rise at about 5% with sideslopes of 10%. From 11+00 feet to 21+00 feet the area is 

timbered with sideslopes of 10 – 15 %. At 26+00 feet the location enters a 20 year-old clearcut with 

20 – 30% sideslopes. A 30 foot deep V- notch is crossed at 36+50 feet a 60 foot bridge may be 

required. The old clearcut ends at 4050 feet. A 30 foot deep V- notch is crossed at 42+00 feet a 60 

foot bridge may be required. The road continues through timber with 5% rise and 10 – 20% 

sideslopes to the end. 

WETLANDS: The proposed road does not cross any wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit @ station 23+00 and 34+00. During periods of high rainfall (as 

defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: 

1) MP: 0.55 AHMU: III Channel Type: HC5 BF Width: 6.5ft Incision: 14ft Gradient: 36% 

Structure: 60ft log stringer bridge 

2) MP: 0.62 AHMU: III Channel Type: HC5 BF Width: 13ft Incision: 20ft Gradient: 33% 

Structure: 60ft log stringer bridge 

3) MP: 0.73 AHMU: III Channel Type: HC5 BF Width: 6.5ft Incision: 14ft Gradient: 26% 

Structure: 30ft log stringer bridge 

4) MP: 0.96 AHMU: III Channel Type: HC6 BF Width: 6ft Incision: 20ft Gradient: 20% 

Structure: 40ft log stringer bridge 

These stream crossings may require site-specific design consideration for volume of flow, fish habitat, 

or other design complexity. Follow BMP 14.14 , 14.17 to minimize stream channel disturbances and 

related sediment production. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 35
1

901 2

201

316

317

6327

6332

6331

6326

6327

6328

0 660 1,320 2,640

Feet

Road 6327

c:/workspace/ckupre/plots/deis/rd_6327.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

36 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

 45885 6326 MP 7.04 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.06 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.06 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber sale activities and physically 

blocked or natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross 

drains (water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any 

additional resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 37
Site Specific Design Criteria 

Road 45885 

ROAD LOCATION: The road is located on fairly flat ground which slopes down hill at approximately 

5% grade through timber. 

WETLANDS: The proposed road does not cross wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located on 6326 at MP 5.63. During periods of high rainfall (as 

defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: 

There are no major stream crossings on the section of road. 

38 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
205

206

204

6326

45885

6326

6336

0 660 1,320 2,640

Feet

Road 45885

c:/workspace/ckupre/plots/deis/rd_45885.mxd 11-17-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 39
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

 45891 6328 MP 2.70 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.60 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.60 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and maintained 

in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to maintain crown 

and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage patterns, add 

water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a self maintaining state. 

. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

40 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45891 

ROAD LOCATION: The road steadily gains elevation between the beginning point at the existing 

Road 6328. The first 23+00 feet is a stead climb @ 15% through timber with 50% sideslopes. A 20 

foot deep V- notch is crossed at 10+50 feet a 40 foot bridge may be required. At 12+00 a stream is 

crossed, a 36 inch pipe may be required. At 20+80 feet a stream is crossed, a 36 inch pipe may be 

required. From 21+00 to end the road continues to climb @ 15% through timber with 70% 

sideslopes. 

WETLANDS: The proposed road does not cross any wetland. 

SOILS: A slope stability investigation will be completed by a soil specialist prior to implementation in 

areas where the proposed road crosses side slopes greater than 67%. The on-site investigation will 

follow Forest Plan protocols. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at beginning of road at intersection of 6328. During periods 

of high rainfall (as defined in current Regional specifications), blasting operations will be suspended 

at quarries near potentially unstable sites where ground vibration may induce mass movement (BMP 

14.6). 

STREAM CROSSINGS: There are three Class IV stream crossings at stations 10+50, 12+00, and 

20+80 that may require site-specific design consideration for volume of flow, fish habitat, or other 

design complexity due to stream incision. Follow BMP 14.14, 14.17 to minimize stream channel 

disturbances and related sediment production. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 41
901

5

208

2

209

202

45891

45890

6334

6332

6334

6334

6328

0 660 1,320 2,640

Feet

Road 45891

c:/workspace/ckupre/plots/deis/rd_45891.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

42 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

6339 6339 MP 1.71 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

1.71 0.70 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

1.71 2.41 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and maintained 

in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to maintain crown 

and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage patterns, add 

water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a self maintaining state. 

. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 43
Site Specific Design Criteria 

Road 6339 

ROAD LOCATION: The road steadily gains elevation between the beginning point at the existing 

Road 6328. The first 13+00 feet is a stead climb @ 10 - 15% through timber with 30 to 50% 

sideslopes. The remainder of the road location is rolling along the contour with no appreciable gain in 

elevation with 30 to 50% sideslopes, also going through timber. 

WETLANDS: The proposed road does not cross any wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at beginning of road at start of this new section of 6339. 

During periods of high rainfall (as defined in current Regional specifications), blasting operations will 

be suspended at quarries near potentially unstable sites where ground vibration may induce mass 

movement (BMP 14.6). Also during these periods, road construction that requires rock supplied from 

quarries shall be suspended in high risk areas on roads where rock hauling would increase the risk of 

mass failure (BMP 14.7). Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

44 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
502

217

6

215

501

216

214

6339

6339

6318

6328

0 660 1,320 2,640

Feet

Road 6339

c:/workspace/ckupre/plots/deis/rd_6334.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 45
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

6326 6339 MP 8.08 8.46 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

8.08 0.50 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

8.08 8.58 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and maintained in 

“Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to maintain crown 

and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage patterns, add 

water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

Road 6326 was part of the North Irish Timber Sale NEPA document. The 0.5 portion proposed for new NFS construction in the 

Central Kupreanof project area was built as a temporary road in North Irish and therefore does not show up on the USFS GIS roads 

layer. The adjacent unit was not harvested in North Irish and the section of temporary road was coded as decommissioned. 

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

46 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 6326 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in 

elevation with 30 to 50% sideslopes, also going through timber. 

WETLANDS: The proposed road does not cross any wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 5.60 of existing road 6326. During periods of high 

rainfall (as defined in current Regional specifications), blasting operations will be suspended at 

quarries near potentially unstable sites where ground vibration may induce mass movement (BMP 

14.6). Also during these periods, road construction that requires rock supplied from quarries shall be 

suspended in high risk areas on roads where rock hauling would increase the risk of mass failure 

(BMP 14.7). Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 47
206

205

204

6326

45885

6326

6336

0 660 1,320 2,640

Feet

Road 6326

c:/workspace/ckupre/plots/deis/rd_6326.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

48 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45890 Intersection 6334 & 6339 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 1.25 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.25 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including firewood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 49
Site Specific Design Criteria 

Road 45890 

ROAD LOCATION: The road steadily gains elevation from the beginning point at the existing Road 

6334. The first 20+00 feet is a steady climb @ 10 - 15% through timber with 30 to 50% sideslopes. 

The remainder of the road location is rolling along the contour with no appreciable gain in elevation 

with 30 to 50% sideslopes, also going through timber. 

WETLANDS: The proposed road crosses about 674 feet of wetland in Alternatives 2 and 3. The 

wetland type is muskeg. Minimize the road footprint through the wetlands and provide adequate 

hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some portions of the location 

due to safety, engineering design constraints and consideration for other resources. Alternatives to 

the location on wetlands would mean longer higher cost roads that may have impacted similar areas 

of wetlands (BMP 14.2). Overlay construction is recommended to minimize disturbance to the 

wetland and ensure hydraulic connectivity of the roaded wetland with the surrounding areas (BMPs 

12.5 and 14.17). This road meets silviculture exemption for 404 permitting through Army Corps of 

Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at 0.4 miles south of road at intersection of 6334. During 

periods of high rainfall (as defined in current Regional specifications), blasting operations will be 

suspended at quarries near potentially unstable sites where ground vibration may induce mass 

movement (BMP 14.6). Also during these periods, road construction that requires rock supplied from 

quarries shall be suspended in high risk areas on roads where rock hauling would increase the risk of 

mass failure (BMP 14.7). Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There is one Class III stream crossing that may require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. Follow 14.14, 14.17 to 

minimize stream channel disturbances and related sediment production. 

50 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
5

207

901

6

501

203

209

208

202

3

201

45890

6327

45891

45889

6334

6333

6333

6334

6339

6328

0 660 1,320 2,640

Feet

Road 45890

c:/workspace/ckupre/plots/deis/rd_45890.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 51
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45888 6040 MP 13.60 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.40 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.40 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

52 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45888 

ROAD LOCATION: The road located on flat timbered area between the beginning point at the 

existing Road 6040. The first 13+00 feet is flat and no sideslope through timber. The remainder of 

the road location is rolling along the contour with no appreciable gain in elevation with 20 to 30% 

sideslopes, also going through timber. 

WETLANDS: The proposed road crosses about 137 feet of forested wetland in Alternatives 2 and 3. 

Minimize the road footprint through the wetlands and provide adequate hillslope drainage (33 CFR 

BMPs 1, 3). Wetlands were unavoidable on some portions of the location due to safety, engineering 

design constraints and consideration for other resources. Alternatives to the location on wetlands 

would mean longer higher cost roads that may have impacted similar areas of wetlands (BMP 14.2). 

Overlay construction is recommended to minimize disturbance to the wetland and ensure hydraulic 

connectivity of the roaded wetland with the surrounding areas (BMPs 12.5 and 14.17). This road 

meets silviculture exemption for 404 permitting through Army Corps of Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at west of road intersection 6040 @ MP 12.40 road 6040. 

During periods of high rainfall (as defined in current Regional specifications), blasting operations will 

be suspended at quarries near potentially unstable sites where ground vibration may induce mass 

movement (BMP 14.6). Also during these periods, road construction that requires rock supplied from 

quarries shall be suspended in high risk areas on roads where rock hauling would increase the risk of 

mass failure (BMP 14.7). Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 53
305

304

309

306

310

45888

6041

6040

6326

6314

6314

0 660 1,320 2,640

Feet

Road 45888

c:/workspace/ckupre/plots/deis/rd_45888.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

54 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

6334 6334 MP 2.14 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

2.14 0.35 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

2.14 2.49 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 55
Site Specific Design Criteria 

Road 6334 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in 

elevation with 40 to 60% sideslopes, skirting along old clearcut. 

WETLANDS: The proposed road does not cross wetlands. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 1.40 of road 6334. During periods of high rainfall (as 

defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: 

1) AHMU: III Channel Type: HC5 BF Width: 5.1ft Incision: 19ft Gradient: 61% Structure:

40ft log stringer bridge 

2) AHMU: III Channel Type: HC5 BF Width: 3.4ft Incision: 10ft Gradient: 80% Structure:

30ft log stringer bridge 

These stream crossings may require site-specific design consideration for volume of flow, fish habitat, 

or other design complexity. Follow 14.14, 14.17 to minimize stream channel disturbances and related 

sediment production. 

56 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
5

207

901

6

501

203

209

208

202

3

201

45890

6327

45891

45889

6334

6333

6333

6334

6339

6328

0 660 1,320 2,640

Feet

Road 6334

c:/workspace/ckupre/plots/deis/rd_6334.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 57
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45889 MP 4.15 Road 6326 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.63 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.63 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

58 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45889 

ROAD LOCATION: The road steadily gains elevation between the beginning point at the existing 

Road 6326. The first 20+00 feet is a stead climb @ 15% through timber with 40 to 50% sideslopes. 

The remainder of the road location is rolling along the contour with no appreciable gain in elevation 

with 40 to 50% sideslopes, also going through timber. 

WETLANDS: The proposed road crosses about 779 feet of wetland in Alternatives 2 and 3. The 

wetland is both muskeg/forested mosaic wetland and forested wetland. Minimize the road footprint 

through the wetlands and provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were 

unavoidable on some portions of the location due to safety, engineering design constraints and 

consideration for other resources. Alternatives to the location on wetlands would mean longer higher 

cost roads that may have impacted similar areas of wetlands (BMP 14.2). Overlay construction is 

recommended to minimize disturbance to the wetland and ensure hydraulic connectivity of the roaded 

wetland with the surrounding areas (BMPs 12.5 and 14.17). This road meets silviculture exemption 

for 404 permitting through Army Corps of Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located about 0.3 mile up road 6333. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 59
5

203

202

3

207

201

6327

45889

45890

6334

6331

6326

6333

6334

0 660 1,320 2,640

Feet

Road 45889

c:/workspace/ckupre/plots/deis/rd_45889.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

60 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

6040 6040 MP 17.14 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

17.14 0.35 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

17.14 17.49 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 61
Site Specific Design Criteria 

Road 6040 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in 

elevation with 40 to 60% sideslopes, area is timbered 

WETLANDS: The proposed road crosses about 23 feet of wetland in Alternatives 2 and 3. The 

wetland type is muskeg/forested mosaic. Minimize the road footprint through the wetlands and 

provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some 

portions of the location due to safety, engineering design constraints and consideration for other 

resources. Alternatives to the location on wetlands would mean longer higher cost roads that may 

have impacted similar areas of wetlands (BMP 14.2). Overlay construction is recommended to 

minimize disturbance to the wetland and ensure hydraulic connectivity of the roaded wetland with the 

surrounding areas (BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting 

through Army Corps of Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 15.80 of road 6040. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

62 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
903

307

6040

6040

0 660 1,320 2,640

Feet

Road 6040

c:/workspace/ckupre/plots/deis/rd_6040.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 63
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45800 45800 MP 1.033 2.093 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

1.033 1.06 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

1.033 2.093 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

64 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45800 

ROAD LOCATION: The road location from beginning to 0+400 is in a 8 year old clearcut with 20% 

sideslope. Location enters timber with 20 - 50% sideslope and is rolling along the contour with no 

appreciable gain in elevation. Enter muskeg @ 25+00, need 48” culvert @ 28+00, @ 35+00 12’ deep 

“V” notch, need 48” culvert, @ 38+00 10’ deep “V” notch, need 48” culvert. Area is timbered rolling 

along the contour with no appreciable gain in elevation. @ 43+00 15’ deep “V” notch, 48” culvert, @ 

48+00 6’ “V” notch, 36” culvert, 50% sideslope, timbered. Road end this 60% sideslope and timbered 

area. 

WETLANDS: The proposed road crosses about 370 feet of wetland in Alternative 3. The wetland 

type is moss muskeg. Minimize the road footprint through the wetlands and provide adequate 

hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some portions of the location 

due to safety, engineering design constraints and consideration for other resources. Alternatives to 

the location on wetlands would mean longer higher cost roads that may have impacted similar areas 

of wetlands (BMP 14.2). Overlay construction is recommended to minimize disturbance to the 

wetland and ensure hydraulic connectivity of the roaded wetland with the surrounding areas (BMPs 

12.5 and 14.17). This road meets silviculture exemption for 404 permitting through Army Corps of 

Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at 40+00. During periods of high rainfall (as defined in 

current Regional specifications), blasting operations will be suspended at quarries near potentially 

unstable sites where ground vibration may induce mass movement (BMP 14.6). Also during these 

periods, road construction that requires rock supplied from quarries shall be suspended in high risk 

areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). Follow BMP 

14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: 

1) AHMU: III Channel Type: HC5 BF Width: 5.7ft Incision: 12.5ft Gradient: 15% Structure:

30ft log stringer bridge 

This stream crossing may require site-specific design consideration for volume of flow, fish habitat, or 

other design complexity. Follow 14.14, 14.17 to minimize stream channel disturbances and related 

sediment production. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 65
224

250

222

221

223

229

45800

45808

6314S

0 660 1,320 2,640

Feet

Road 45800

c:/workspace/ckupre/plots/deis/rd_45800.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

66 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45803 45803 MP 4.608 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

4.608 3.74 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

4.608 8.348 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 67
Site Specific Design Criteria 

Road 45803 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in elevation with 

20 to 50% sideslopes, area is timbered. 

WETLANDS: The proposed road crosses about 328 feet of wetland in Alternative 3. The wetland is both 

muskeg/forested mosaic wetland and forested wetland. Minimize the road footprint through the wetlands and 

provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some portions of the 

location due to safety, engineering design constraints and consideration for other resources. Alternatives to 

the location on wetlands would mean longer higher cost roads that may have impacted similar areas of 

wetlands (BMP 14.2). Overlay construction is recommended to minimize disturbance to the wetland and 

ensure hydraulic connectivity of the roaded wetland with the surrounding areas (BMPs 12.5 and 14.17). This 

road meets silviculture exemption for 404 permitting through Army Corps of Engineers. 

SOILS: Road location moved downslope to the 500-foot contour and away from MMI-4 soils (BMP 14.2). 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed by the 

contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral soil exposed 

during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 4.02 of road 45803. During periods of high rainfall (as 

defined in current Regional specifications), blasting operations will be suspended at quarries near potentially 

unstable sites where ground vibration may induce mass movement (BMP 14.6). Also during these periods, 

road construction that requires rock supplied from quarries shall be suspended in high risk areas on roads 

where rock hauling would increase the risk of mass failure (BMP 14.7). Follow BMP 14.18 for development 

and rehabilitation of rock sources.

STREAM CROSSINGS: Stream crossing data was not field verified along segments of this road located 

between the southern boundary of Unit 261 and the northeastern boundary of Unit 265. The most recent GIS 

stream layer and aerial photo interpretation was used to determine stream class along these segments. These 

segments will be field verified during layout should this alternative be chosen, and the State of Alaska will 

conduct Title 16 review of all proposed fish crossings prior to implementation. 

1) MP: 0.27 AHMU: II Channel Type: MM1 BF Width: 13.5ft Incision: 3ft Gradient: 2% Structure: 40ft 

log stringer bridge 

Narrative: Maintain fish migration and avoid diverting surface drainage channels. (BMPs 14.6, 14.14, 14.17) 

2) MP: 2.53 AHMU: III Channel Type: HC5 BF Width: 10ft Incision: 25ft Gradient: 25% Structure: 40ft 

log stringer bridge 

3) MP: 2.59 AHMU: III Channel Type: HC5 BF Width: 5.3ft Incision: 40ft Gradient: 20% Structure: 60ft 

modular bridge 

4) MP: 2.66 AHMU: III Channel Type: HC5 BF Width: 5.2ft Incision: 27ft Gradient: 28% Structure: 40ft 

log stringer bridge 

There are an additional 3 Class III stream crossings at MP: 0.30, 2.25 and 3.24 that may require site-specific 

design consideration for volume of flow, fish habitat, or other design complexity. Follow BMP 14.6, 14.14, 

14.15, 14.17 for timing restrictions on Class I streams, and to minimize stream channel disturbances and 

related sediment production. 

68 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
265

258

261

263

260

257

266

264

267

45803

45895

0 660 1,320 2,640

Feet

Road 45803

c:/workspace/ckupre/plots/deis/rd_45803.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 69
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45805 45805 MP 0.387 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.387 0.50 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.387 0.887 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

70 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45805 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in 

elevation with 20 to 50% sideslopes, area is timbered 

WETLANDS: The proposed road does not cross wetlands. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 0.05 of road 45805. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 71
270

272

273

274 45897

45805

45899

45803

45805

0 660 1,320 2,640

Feet

Road 45805

c:/workspace/ckupre/plots/deis/rd_45805.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

72 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45808 Screwdriver 45808 MP 3.883 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

3.883 0.29 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

3.883 4.173 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state.

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 73
Site Specific Design Criteria 

Road 45808 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in 

elevation with 20% sideslopes, area is timbered. Need a 30ft log stringer bridge @ 2+00. 

WETLANDS: The proposed road does not cross wetlands. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 3.05 of road 45808. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: 

1) MP: 0.04 AHMU: II Channel Type: HC2 BF Width: 7.2ft Incision: 6ft Gradient: NA 

Structure: 30ft log stringer bridge 

Narrative: The crossing will be designed for fish passage and to minimize soil runoff to the 

channel, retain natural drainage pattern, and minimize changes to the natural sediment transport.

Follow BMP 14.14, 14.17 to minimize stream channel disturbances and related sediment 

production. 

74 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
234

235

231

232

233 236

230 45808

45808

0 660 1,320 2,640

Feet

Road 45808

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Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 75
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45892 MP 4.55 Road 6314S 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 4.13 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 4.13 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

76 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45892 

ROAD LOCATION: The road location is steep 12 – 18% to gain the elevation @ 53+00 the area is 

timbered with sideslopes of 40-60%. Once on the ridge, road follows contour with no appreciable 

gain in elevation. There are numerous “V” notches that will require log stringer bridges. Options to 

locate road at apex of alluvial fan will be explored during implementation. All applicable Forest Plan 

Standards and Guidelines, Forest Service Manual and Handbooks and (BMPs) will be incorporated 

during design, construction and maintenance of roads. Best Management Practices (BMPs) are used 

to assure soil and water resources are considered in transportation planning activities. Any side 

slopes of greater than 67% would be mitigated by full bench construction and slope stabilization, if 

necessary. 

WETLANDS: The proposed road crosses about 1,125 feet of wetland in Alternative 3. The wetland is 

muskeg/forested mosaic wetland and forested wetland. Minimize the road footprint through the 

wetlands and provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable 

on some portions of the location due to safety, engineering design constraints and consideration for 

other resources. Alternatives to the location on wetlands would mean longer higher cost roads that 

may have impacted similar areas of wetlands (BMP 14.2). Overlay construction is recommended to 

minimize disturbance to the wetland and ensure hydraulic connectivity of the roaded wetland with the 

surrounding areas (BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting 

through Army Corps of Engineers. 

SOILS: Proposed road initially crossed steep slopes. The road was re-routed to avoid these slopes 

(BMP 14.2). 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 17+00. During periods of high rainfall (as defined in 

current Regional specifications), blasting operations will be suspended at quarries near potentially 

unstable sites where ground vibration may induce mass movement (BMP 14.6). Also during these 

periods, road construction that requires rock supplied from quarries shall be suspended in high risk 

areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). Follow BMP 

14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are two Class III streams at MP: 0.45 and 1.52 that will require log 

stringer bridges and site-specific design consideration for volume of flow, fish habitat, or other design 

complexity. Follow BMP 14.14, 14.17 to minimize stream channel disturbances and related sediment 

production. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 77
248

241

243

246

253

254

249

45892

6314S

0 660 1,320 2,640

Feet

Road 45892

c:/workspace/ckupre/plots/deis/rd_45892.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

78 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45893 MP 5.05 Road 6314S 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.50 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.50 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 79
Site Specific Design Criteria 

Road 45893 

ROAD LOCATION: The road location begins climbing at start @ 10% through timber with 30-50% 

sideslopes. 

WETLANDS: The proposed road does not cross wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 4.95 of road 6314S. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

80 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
252

250

253

254

249

248

45894

45893

45892

6314S

0 660 1,320 2,640

Feet

Road 45893

c:/workspace/ckupre/plots/deis/rd_45893.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

255

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 81
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45894 MP 5.05 Road 6314S 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.90 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.90 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

82 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45894 

ROAD LOCATION: The road location begins climbing at start @ 10% through timber with 30-50% 

sideslopes. 

WETLANDS: The proposed road crosses about 115 feet of wetland in Alternatives 2 and 3. The 

wetland is both muskeg/forested mosaic wetland and moss muskeg wetland. Minimize the road 

footprint through the wetlands and provide adequate hillslope drainage (33 CFR BMPs 1, 3). 

Wetlands were unavoidable on some portions of the location due to safety, engineering design 

constraints and consideration for other resources. Alternatives to the location on wetlands would 

mean longer higher cost roads that may have impacted similar areas of wetlands (BMP 14.2). 

Overlay construction is recommended to minimize disturbance to the wetland and ensure hydraulic 

connectivity of the roaded wetland with the surrounding areas (BMPs 12.5 and 14.17). This road 

meets silviculture exemption for 404 permitting through Army Corps of Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 4.95 of road 6314S. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 83
252

250

253

254

249

248

45894

45893

45892

6314S

0 660 1,320 2,640

Feet

Road 45894

c:/workspace/ckupre/plots/deis/rd_45894.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

255

84 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45895 MP 4.608 Road 45803 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 1.22 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.22 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 85
Site Specific Design Criteria 

Road 45895 

ROAD LOCATION: The road location starts in 10 year old clear cut and follows contour to end of 

clearcut @ 4+00 and enters timber. @ 5+00 cross streams that needs a 50’ bridge. Road progress 

through timber @ 10-15% grade with 30% sideslopes to 24+00 and enter muskeg area for several 

hundred feet. Road location continues to climb @ 10% through timber with 30% sideslopes to reach 

muskeg area @ 48+00 for several hundred feet. The road then continues through timber to end. 

WETLANDS: The proposed road crosses about 605 feet of wetland in Alternative 3. The wetland is 

both muskeg/forested mosaic wetland and forested wetland. Minimize the road footprint through the 

wetlands and provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable 

on some portions of the location due to safety, engineering design constraints and consideration for 

other resources. Alternatives to the location on wetlands would mean longer higher cost roads that 

may have impacted similar areas of wetlands (BMP 14.2). Overlay construction is recommended to 

minimize disturbance to the wetland and ensure hydraulic connectivity of the roaded wetland with the 

surrounding areas (BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting 

through Army Corps of Engineers. 

SOILS: Road location moved to avoid MMI-4 soils. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at 18+00. During periods of high rainfall (as defined in 

current Regional specifications), blasting operations will be suspended at quarries near potentially 

unstable sites where ground vibration may induce mass movement (BMP 14.6). Also during these 

periods, road construction that requires rock supplied from quarries shall be suspended in high risk 

areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). Follow BMP 

14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There is one Class III stream at MP 0.31 that will require a 50ft log stringer 

bridge and may require site-specific design consideration for volume of flow, fish habitat, or other 

design complexity. Follow BMP 14.14, 14.17 to minimize stream channel disturbances and related 

sediment production. 

86 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
265 266

268

263

267

45803

45895

0 660 1,320 2,640

Feet

Road 45895

c:/workspace/ckupre/plots/deis/rd_45895.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 87
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45896 MP 1.60 Road 45803 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 1.71 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 1.71 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

88 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45896 

ROAD LOCATION: The road location gains elevation @ a 10% through timber to 50+00 then it is 

rolling along the contour with no appreciable gain in elevation with 20% sideslopes, area is timbered. 

WETLANDS: The proposed road crosses about 496 feet of wetland in Alternative 3. The wetland 

type is muskeg/forested mosaic. Minimize the road footprint through the wetlands and provide 

adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some portions of 

the location due to safety, engineering design constraints and consideration for other resources. 

Alternatives to the location on wetlands would mean longer higher cost roads that may have impacted 

similar areas of wetlands (BMP 14.2). Overlay construction is recommended to minimize disturbance 

to the wetland and ensure hydraulic connectivity of the roaded wetland with the surrounding areas 

(BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting through Army 

Corps of Engineers. 

SOILS: Road location modified to avoid MMI-4 soils (BMP 14.2). 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 1.30 of road 45803. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are two Class III streams at MP: 1.30 and 1.65 that may require sitespecific design consideration for volume of flow, fish habitat, or other design complexity. Follow BMP 

14.14, 14.17 to minimize stream channel disturbances and related sediment production. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 89
276

275

280

279

274

281

45897

45896

45895

45803

0 660 1,320 2,640

Feet

Road 45896

c:/workspace/ckupre/plots/deis/rd_45896.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

90 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45897 MP 0.44 Road 45803 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 2.60 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 2.60 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 91
Site Specific Design Criteria 

Road 45897 

ROAD LOCATION: The road location is rolling along the contour with no appreciable gain in elevation with 

20% sideslopes, area is timbered. 

WETLANDS: The proposed road crosses about 350 feet of wetland in Alternative 3. The wetland is 

muskeg/forested mosaic wetland and forested wetland. Minimize the road footprint through the wetlands and 

provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some portions of the 

location due to safety, engineering design constraints and consideration for other resources. Alternatives to 

the location on wetlands would mean longer higher cost roads that may have impacted similar areas of 

wetlands (BMP 14.2). Overlay construction is recommended to minimize disturbance to the wetland and 

ensure hydraulic connectivity of the roaded wetland with the surrounding areas (BMPs 12.5 and 14.17). This 

road meets silviculture exemption for 404 permitting through Army Corps of Engineers. 

SOILS: Proposed road between units 275 and 276 was relocated to a stable section of the v-notch at 

approximately 300 feet elevation where the sideslopes are less than 65 percent (BMP 14.2) 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed by the 

contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral soil exposed 

during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 0.91 of road 45803. During periods of high rainfall (as 

defined in current Regional specifications), blasting operations will be suspended at quarries near potentially 

unstable sites where ground vibration may induce mass movement (BMP 14.6). Also during these periods, 

road construction that requires rock supplied from quarries shall be suspended in high risk areas on roads 

where rock hauling would increase the risk of mass failure (BMP 14.7). Follow BMP 14.18 for development 

and rehabilitation of rock sources. 

STREAM CROSSINGS: Stream crossing data was not field verified along segments of this road located 

between units. The most recent GIS stream layer and aerial photo interpretation was used to determine stream 

class along these segments. These segments will be field verified during layout should this alternative be 

chosen, and the State of Alaska will conduct Title 16 review of all proposed fish crossings prior to 

implementation. 

1) Mile: 0.19 AHMU: III Channel Type: HC6 Structure: log stringer bridge 

2) MP: 0.79 AHMU: I Channel Type: MM1 Structure: log stringer bridge 

3) MP: 1.44 AHMU: II Channel Type: HC2 Structure: log stringer bridge 

4) MP: 1.58 AHMU: II Channel Type: HC4 Structure: log stringer bridge 

5) MP: 1.98 AHMU: II Channel Type: HC3 Structure: log stringer bridge 

6) MP: 2.83 AHMU: II Channel Type: AF0 BF Width: 3.4ft Incision: 2.5ft Substrate: Gradient: 18% Structure: log 

stringer bridge 

. Narrative: Maintain fish migration and avoid diverting surface drainage channels. Apply timing restrictions for Class I 

streams (BMP 14.6). Follow BMP 14.14, 14.15, 14.17 to minimize stream channel disturbance and related sediment 

production on all streams. 

92 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
276 277

275

280

279

274

281

45803

45897

45896

0 660 1,320 2,640

Feet

Road 45897

c:/workspace/ckupre/plots/deis/rd_45897.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 93
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45898 MP 10.50 Road 6314S 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.42 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.42 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

94 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45898 

ROAD LOCATION: The road location climbs @ 15% through timber with sideslopes 30-50%. 

WETLANDS: The proposed road crosses about 91 feet of wetland in Alternatives 2 and 3. The 

wetland type is muskeg/forested mosaic. Minimize the road footprint through the wetlands and 

provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some 

portions of the location due to safety, engineering design constraints and consideration for other 

resources. Alternatives to the location on wetlands would mean longer higher cost roads that may 

have impacted similar areas of wetlands (BMP 14.2). Overlay construction is recommended to 

minimize disturbance to the wetland and ensure hydraulic connectivity of the roaded wetland with the 

surrounding areas (BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting 

through Army Corps of Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 10.05 of road 6314S. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 95
282

284

45898

6314S

0 660 1,320 2,640

Feet

Road 45898

c:/workspace/ckupre/plots/deis/rd_45898.mxd 06-06-08 EP

Legend

Proposed Unit

Contours 100 ft.

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Stream Class I

Stream Class II

Stream Class III

96 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

45899 MP 0.63 Road 45803 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.70 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.70 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 97
Site Specific Design Criteria 

Road 45899 

ROAD LOCATION: The road location climbs @ 15% through timber with sideslopes 30-60%. 

WETLANDS: The proposed road crosses about 25 feet of wetland in Alternatives 2 and 3. The 

wetland type is muskeg/forested mosaic. Minimize the road footprint through the wetlands and 

provide adequate hillslope drainage (33 CFR BMPs 1, 3). Wetlands were unavoidable on some 

portions of the location due to safety, engineering design constraints and consideration for other 

resources. Alternatives to the location on wetlands would mean longer higher cost roads that may 

have impacted similar areas of wetlands (BMP 14.2). Overlay construction is recommended to 

minimize disturbance to the wetland and ensure hydraulic connectivity of the roaded wetland with the 

surrounding areas (BMPs 12.5 and 14.17). This road meets silviculture exemption for 404 permitting 

through Army Corps of Engineers. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located at MP 1.55 of road 45803. During periods of high rainfall 

(as defined in current Regional specifications), blasting operations will be suspended at quarries near 

potentially unstable sites where ground vibration may induce mass movement (BMP 14.6). Also 

during these periods, road construction that requires rock supplied from quarries shall be suspended 

in high risk areas on roads where rock hauling would increase the risk of mass failure (BMP 14.7). 

Follow BMP 14.18 for development and rehabilitation of rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

98 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
270 45899

45805

45803

45805

6314S

0 660 1,320 2,640

Feet

Road 45899

c:/workspace/ckupre/plots/deis/rd_45899.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 99
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

 45886 6314 MP 3.15 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.09 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.09 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic during the life of these 

timber sale activities. They may remain open from five to ten years after this timber sale for other activities including fire wood 

removal; these roads would be constructed or placed in a self maintaining hydrologic status. This would include the placement of 

drivable water bars or dips at all drainage culvert locations to direct water across the road in event that the culvert plugs. Other design 

elements like oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and physically blocked or 

natural vegetation allowed to eliminate motorized access. Drainage structures would remain in place with additional cross drains 

(water bars and dips), and the road would be considered stored. A review will be conducted at the time of closure for any additional 

resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

100 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Site Specific Design Criteria 

Road 45886 

ROAD LOCATION: The road is located on fairly flat ground which slopes down hill at approximately 

5% grade through timber. Road location will be adjusted to avoid first stream crossing if possible. 

 

WETLANDS: The proposed road does not cross wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located near the beginning of road at intersection of 6314 at MP 

3.40. During periods of high rainfall (as defined in current Regional specifications), blasting 

operations will be suspended at quarries near potentially unstable sites where ground vibration may 

induce mass movement (BMP 14.6). Also during these periods, road construction that requires rock 

supplied from quarries shall be suspended in high risk areas on roads where rock hauling would 

increase the risk of mass failure (BMP 14.7). Follow BMP 14.18 for development and rehabilitation of 

rock sources. 

STREAM CROSSINGS: 

1) MP: 0.09 AHMU: I Channel Type: MM1 BF Width: 2.9ft Incision: 1.5ft Gradient: 6% 

Structure: 30ft log stringer bridge 

Narrative: Maintain fish migration and avoid diverting surface drainage channels. Timing restriction 

will be determined before implementation. (BMPs 14.6, 14.14, 14.17) 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 101
314

905

318

1

313

310

315

312

6330

45887

45886

6337

6326

6314

45001

45002

6329

6314

6328

0 660 1,320 2,640

Feet

Road 45886

c:/workspace/ckupre/plots/deis/rd_45886.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

102 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
Road Management Objective

Project System Land Use Designation

Central Kupreanof EIS Kake 

Route No Route Name Begin Terminus End Terminus 

 45887 6314 MP 3.65 

Begin MP Length Status Map Quarter Quad Photo year, roll, photos 

0.00 0.10 Planned 

General Design Criteria and Elements

Functional Service Design 

Class Life Surface Width Speed Critical Vehicle Design Vehicle

Local LI Shot rock 14' 10 Log truck Log truck 

Intended Purpose/Future Use

Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. 

Maintenance Criteria

Bmp Emp Operational Maintenance Level 

(Current Condition)

Objective Maintenance Level 

(Desired Future Condition)

0.00 0.10 2 1 

Maintenance Narrative

Road will be maintained in “Active” status while road is open during timber haul; post timber haul road will be stored and 

maintained in “Inactive” status. 

AFR&P Regs. “Active” status: Keep culverts, catch basins, ditches and ditch blocks functional. Grade as needed to 

maintain crown and running surface. Control roadside brush to maintain sight distance. 

AFR&P Regs. “Inactive” status: Road is stored. Remove or bypass all drainage structures to restore natural drainage 

patterns, add water bars as needed to control runoff, and seed and fertilize disturbed soils. The road will be placed in a 

self maintaining state. 

Operation Criteria

Highway Safety Act: No Jurisdiction: National Forest ownership 

 Traffic Encourage: Hikers, bicycles 

 Management 

 Strategies Accept: High clearance vehicles 

 Discourage: N/A 

 Prohibit: N/A 

 Eliminate: Motorized vehicles on closed section 

Travel Management Narrative

All newly constructed NFS road will be managed as a maintenance level 2 open to motorized vehicle traffic 

during the life of these timber sale activities. They may remain open from five to ten years after this timber sale 

for other activities including fire wood removal; these roads would be constructed or placed in a self 

maintaining hydrologic status. This would include the placement of drivable water bars or dips at all drainage 

culvert locations to direct water across the road in event that the culvert plugs. Other design elements like 

oversized culverts may be used to help reduce the need for routine drainage maintenance. 

These roads would be intermittent service roads (maintenance level one) within ten years of timber harvest and 

physically blocked or natural vegetation allowed to eliminate motorized access. Drainage structures would 

remain in place with additional cross drains (water bars and dips), and the road would be considered stored. A 

review will be conducted at the time of closure for any additional resource concerns. 

Approved__________________________________________________ ________________________ 

 District Ranger Date 

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 103
Site Specific Design Criteria 

Road 45887 

ROAD LOCATION: The start of the road follows an old decommissioned temporary road that is 

grown over. The road is located on fairly flat ground which slopes down hill at approximately 5% 

grade through timber. 

WETLANDS: The proposed road does not cross wetland. 

EROSION CONTROL: An erosion control plan for construction and maintenance will be developed 

by the contractor and approved by the Contracting Officer (BMP 14.5). All areas of organic or mineral 

soil exposed during construction shall be grass seeded and fertilized (BMP 12.17, 14.8) 

ROCK PITS: Possible rock pit is located near the beginning of road at intersection of 6314 at MP 

3.40. During periods of high rainfall (as defined in current Regional specifications), blasting 

operations will be suspended at quarries near potentially unstable sites where ground vibration may 

induce mass movement (BMP 14.6). Also during these periods, road construction that requires rock 

supplied from quarries shall be suspended in high risk areas on roads where rock hauling would 

increase the risk of mass failure (BMP 14.7). Follow BMP 14.18 for development and rehabilitation of 

rock sources. 

STREAM CROSSINGS: There are no stream crossings that require site-specific design 

consideration for volume of flow, fish habitat, or other design complexity. 

104 ▪ Appendix B Central Kupreanof Timber Harvest FEIS
314

1

905

313

315

316

6330

45887

45886

6337

6314

45001

45002

6327

6329

6314

6328

0 660 1,320 2,640

Feet

Road 45887

c:/workspace/ckupre/plots/deis/rd_45887.mxd 06-06-08 EP

Legend

Proposed Unit

Road Suitable for Passenger Vehicles (ML3)

High Clearance Vehicle Road (ML2)

Basic Custodial Care (Closed Road) (ML1)

New NFS Designated Road Construction (ML2)

Reconstructed Road

New Temporary Road Construction

Contours 100 ft.

Stream Class I

Stream Class II

Stream Class III

Central Kupreanof Timber Harvest FEIS Appendix B ▪ 105
 

Appendix C 

Catalog of Events 
Catalog of Events 

Introduction 

The following is a summary of past, present and reasonably 

foreseeable future thinning, timber harvest, and non-timber related 

activities on Kupreanof Island. This catalog is intended to serve as an 

aid for analyzing cumulative effects on Kupreanof Island. VCU was 

selected as the unit of land division for this catalog. The acreages 

presented in this table are generated from GIS and may vary slightly 

from on-the-ground acres. While these tables are based on the most 

current and complete information available, they should not be 

considered absolute. 

Central Kupreanof Timber Harvest FEIS Appendix C ▪ 1
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

422 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 485

422 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 82

422 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 275

422 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 275

423 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 304

423 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 78 

423 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 418 

424 N/A N/A 40 Partial Cut Clearcut - beach harvest 40 424

Bohemia 

Mountain 

Timber Sale 

EA

1982 N/A

Sale designed to harvest 18 clearcut units and construct 28.9 

miles of raod. The sale never sold due to poor market 

conditions, but a specified road (Road No. 6030) was built. 

N/A 

424

Bohemia Mtn. 

Timber Sale 

EIS

1995 882 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and Two-aged silviculture prescription. Also see VCU 

442.

230 

424

Bohemia Mtn. 

Timber Sale 

EIS

1995 Originally 882 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and Two-aged silviculture prescription. Also see VCU 

442.

260 

424

Bohemia Mtn. 

Timber Sale 

EIS

1995 Originally 882 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and Two-aged silviculture prescription. Also see VCU 

442.

16

424

Bohemia Mtn. 

Timber Sale 

EIS

1995 Originally 882 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and Two-aged silviculture prescription. Also see VCU 

442.

28 

2 ▪ Appendix C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

425

Bohemia Mtn 

Timber Sale 

EIS, Pipeline 

Timber Sale 

EA, and 

Cathedral 

Timber Sale 

EA

1989 

---- ----

330 Combination

Clearcut harvest in 8 units selected from prior NEPA docs. 

175 acres from Bohemia Timber Sale (Units 502, 503, 504, 

and 505); Also see VCU 426 where 4 units were pulled from 

the Pipeline Timber Sale.

332 

425 Hamilton River EA 1974 400 Hamilton River Clearcut harvest with 59 acres being from withthrow. Also see VCU 426 37425 Hamilton River EA 1974 Originally 400 Hamilton River Clearcut harvest with 59 acres being from withthrow. Also see VCU 426 7 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 100

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 644 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 90

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 416 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 143

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 186 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 61 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 122

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 106 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 166 

425 N/A N/A N/A Kake - Non FS Sales Acreage estimated by reviewing aerial photos 572 

425 Small sales 2008 60

6367 Small 

Timber Sale 

Project

Commerical timber harvest within 200 feet of existing FSR 

6367 from approximately 0.1 to 1.4. An estimated 200mbf of 

timber from 60 acres harvested through small sales. 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

426

Bohemia Mtn 

Timber Sale 

EIS, Pipeline 

Timber Sale 

EA, and 

Cathedral 

Timber Sale 

EA

1989 

---- ----

275 Combination

Four units cleared on Pipeline Timber sale were sold here in 

clearcut harvest. Also see VCU 424 where other 4 units from 

Bohemia Sale were harvested by clearcut method.

27

426 Pre-Nepa N/A N/A Hamilton North N/A 18 426 Hamilton River EA 1974 415 Hamilton River Clearcut harvest with 59 acres being from withthrow. Also See VCU 425. 19 

426 Hamilton River EA 1974 Originally 415 Hamilton River Clearcut harvest with 59 acres being from withthrow. Also See VCU 425. 39

426

Hamilton Creek 

South Timber 

Sale EA

1975 433 Hamilton South Clearcut harvest using hi-lead cable yarding system. Also see VCU 4271 11

426

Hamilton Creek 

South Timber 

Sale EA

1975 Originally 433 Hamilton South Clearcut harvest using hi-lead cable yarding system. Also see VCU 4271 445 

426 N/A N/A N/A Little Hamilton N/A 24 426

North Irish 

Creek Timber 

Sale EIS

1977 700 North Irish Clearcut harvest. Not all units were harvested. Also see VCU 4271 and 429 47

426

North Irish 

Creek Timber 

Sale EIS

1977 Originally 700 North Irish Clearcut harvest. Not all units were harvested. Also see VCU 4271 and 429 15

426 N/A N/A N/A Trio N/A 17 426

Central 

Kupreanof 

Timber Harvest 

EIS

Planned 

2009

Timber harvest from roaded areas. Also see VCUs 427.1, 

429, 436, 438

4270 Pre-Nepa N/A N/A Unidentified N/A 13 

4271

Hamilton Creek 

South Timber 

Sale EA

1975 626 Hamilton South Clearcut harvest using hi-lead cable yarding system. 10

4 

▪ Appendix 

C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

4271

Hamilton Creek 

South Timber 

Sale EA

1975 Originally 626 Hamilton South Clearcut harvest using hi-lead cable yarding system. 62

4271 N/A N/A N/A Kake - Non FS Sale N/A 17 

4271

North Irish 

Creek Timber 

Sale EIS

1977 600 North Irish Clearcut harvest. Not all units were harvested. Also see VCU 426 and 429 29

4271

North Irish 

Creek Timber 

Sale EIS

1977 Originally 600 North Irish Clearcut harvest. Not all units were harvested. Also see VCU 426 and 429 87 

4271

Central 

Kupreanof 

Timber Harvest 

EIS

Planned 

2009

Timber harvest from roaded areas. Also see VCUs 426, 429, 

436, 438

428 Pre-Nepa N/A N/A Unidentified N/A 83 429

Shamrock 

Timber Sale 

ROD

1996 Originally 945 Clover Also see VCU 436 and 438 54 

429

Shamrock 

Timber Sale 

ROD

1996 Originally 945 Clover Also see VCU 436 and 438 152 

429

Shamrock 

Timber Sale 

ROD

1996 Originally 945 Clover Also see VCU 436 and 438 12

429

Shamrock 

Timber Sale 

ROD

1996 945 Shamrock Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also see VCU 436 and 438 21

429

Shamrock 

Timber Sale 

ROD

1996 Originally 945 Shamrock Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also see VCU 436 and 438 96 

429

Shamrock 

Timber Sale 

ROD

1996 Originally 945 Shamrock Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also see VCU 436 and 438 12

429

North Irish 

Creek Timber 

Sale EIS

1977 600 North Irish Clearcut harvest. Not all units were harvested. Also see VCU 426 and 4271 16

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

429

Central 

Kupreanof 

Timber Harvest 

EIS

Planned 

2009

Timber harvest from roaded areas. Also see VCUs 426, 

427.1, 436, 438

430 Pre-Nepa N/A N/A Kup Is. SW Shore N/A 59 

430 Pre-Nepa N/A N/A Skiff Island N/A 10430 Pre-Nepa N/A N/A Skiff Island N/A 10430 Pre-Nepa N/A N/A Unidentified N/A 12 430 Pre-Nepa N/A N/A Unidentified N/A 29 431 Pre-Nepa N/A N/A Pt. Barrie N/A 16431 Pre-Nepa N/A N/A Skiff Island N/A 4 431 Pre-Nepa N/A N/A Totem Pole #1 N/A 31 431 Pre-Nepa N/A N/A Totem Pole #1 N/A 93 431 Pre-Nepa N/A N/A Unidentified N/A 16 431 Pre-Nepa N/A N/A Unidentified N/A 20 431 Pre-Nepa N/A N/A Unidentified N/A 25 431 Pre-Nepa N/A N/A Unidentified N/A 29 431 Pre-Nepa N/A N/A Unidentified N/A 13 431 Pre-Nepa N/A N/A Unidentified N/A 12 431 Pre-Nepa N/A N/A Yellow-Island N/A 79 431 Pre-Nepa N/A N/A Yellow-Island N/A 112 431 Pre-Nepa N/A N/A Yellow-Island N/A 43 431 Pre-Nepa N/A N/A Yellow-Island N/A 31432 Pre-Nepa N/A N/A Little Totem N/A 13 432 Pre-Nepa N/A N/A Totem Bay #1 N/A 66 432 Pre-Nepa N/A N/A Totem Bay #1 N/A 81 432 Pre-Nepa N/A N/A Totem Bay #1 N/A 40 432 Pre-Nepa N/A N/A Totem Bay #1 N/A 28 432 Pre-Nepa N/A N/A Totem Bay #2 N/A 18 432 Pre-Nepa N/A N/A Totem Bay #2 N/A 73 432 Pre-Nepa N/A N/A Totem Pole N/A 54 432 Pre-Nepa N/A N/A Totem Pt N/A 18 432 Pre-Nepa N/A N/A Unidentified N/A 135 432 Pre-Nepa N/A N/A Unidentified N/A 22 432 Pre-Nepa N/A N/A Unidentified N/A 7 432 Pre-Nepa N/A N/A Unidentified N/A 5 

6 

▪ Appendix 

C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

432

Totem Timber 

Sale - South 

Kupreanof EA

1984 2404 Clearcut harvest and road construction activities planned. 

433 Pre-Nepa N/A N/A Douglas Bay #1 N/A 10433 Pre-Nepa N/A N/A Douglas Bay #2 N/A 19433 Pre-Nepa N/A N/A Douglas Bay #3 N/A 54 433 Pre-Nepa N/A N/A Douglas Bay #3 N/A 37 433 Unidentified N/A N/A Unidentified N/A 73 433 Unidentified N/A N/A Unidentified N/A 17434 Little Duncan 14

434 Mitchell Pt. Blowdown 15

434 Mitchell Pt. Blowdown 21 

434 Mitchell Pt. Blowdown 63 

434 Mitchell Pt. Salvage 96 

434 Mitchell Pt. Salvage 24 

434 Mitchell Pt. Salvage 11 

434 Mitchell Pt. Salvage 56 

434 Mitchell Pt. Salvage 24434 Pre-Nepa N/A N/A SW Duncan Canal N/A 74 

435 Pre-Nepa N/A N/A Duncan Peninsula N/A 31 435 Pre-Nepa N/A Little Duncan Little Duncan N/A 32 

435 Pre-Nepa N/A N/A Little Duncan N/A 13435 Pre-Nepa N/A N/A SW Duncan Canal N/A 52 

435 Pre-Nepa N/A N/A SW Duncan Canal N/A 20 435 Pre-Nepa N/A N/A Rookery Island N/A 60 435 Pre-Nepa N/A N/A Unidentified N/A 17 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

435 Pre-Nepa N/A N/A Unidentified N/A 25 435 Pre-Nepa N/A N/A Unidentified N/A 6 

436

Shamrock 

Timber Sale 

ROD

1996 459 Clover Also see VCU 429 and 438 14 

436

Shamrock 

Timber Sale 

ROD

1996 Originally 459 Clover Also see VCU 429 and 438 17

436

Shamrock 

Timber Sale 

ROD

1996 Originally 459 Clover Also see VCU 429 and 438 117 

436

Shamrock 

Timber Sale 

ROD

1996 Originally 459 Shamrock Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also see VCU 429 and 438 97 

436

Central 

Kupreanof 

Timber Harvest 

EIS

Planned 

2009

Timber harvest from roaded areas. Also see VCUs 426, 

427.1, 429, 438

437

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 757 Bowen Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 13 

437

South 

Lindenberg 

Timber Sale 

EIS

1996 757 Dakota

Clearcut (majority) and partial harvest using skyline, hi-lead, 

helicopter, and shovel yarding systems. Road construction 

and pit development also performed.

10 

437

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 757 Fingerpoint Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 142 

437

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 757 Lindenberg Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 11

437

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 757 South Central Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 30 

8 ▪ Appendix C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

437

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 757 South Pass Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 31 

437

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 757 South Saddle Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 55 

437

Toncan Timber 

Sale - 

Lindenberg 

Peninsula EA

1984 903 Toncan Clearcut timber harvest and road building activities. 393 

437

Toncan Timber 

Sale - 

Lindenberg 

Peninsula EA

1984 Originally 903 Toncan Clearcut timber harvest and road building activities. 434 

437

Toncan Timber 

Sale - 

Lindenberg 

Peninsula EA

1984 Originally 903 Toncan Clearcut timber harvest and road building activities. 102 

437 Pre-Nepa N/A N/A Duncan Canal East N/A 9 437 Pre-Nepa N/A N/A Ranger Sale N/A 28 437

Tonka Mtn. 

Timber Sale 

EA

1976 1784 Tonka Mt.

Clearcut and partial harvest using hi-lead and partial 

suspension cable yarding systems. Road construction 

activities included.

35 

437

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 1784 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 38

437

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 1784 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 25

437

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 1784 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 31 

437

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 1784 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 153 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

437

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 1784 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 492 

437 Pre-Nepa N/A N/A Unidentified N/A 5 437 Pre-Nepa N/A N/A Unidentified N/A 28 437 Pre-Nepa N/A N/A Waterfall Cr. N/A 62 437 Pre-Nepa N/A N/A Waterfall Cr. N/A 68 437

MitkofKupreanof 

Small Timber 

Sale EA

1991 92 White Alice Salvage Salvage timber harvest and associated road building using cable logging systems. Even-aged silviculture prescription. 89 

437 Tonka EIS Planned 2009 Timber harvest and related infrastructure development within Phase I areas on South Lindenberg Peninsula (also in VCU 439 and 447)

438 Pre-Nepa N/A N/A Little Duncan N/A 60 438 Pre-Nepa N/A N/A Little Duncan N/A 23 438

Shamrock 

Timber Sale 

EIS

1995 Originally 240 Clover Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also See VCU 429 and 436 54 

438

Shamrock 

Timber Sale 

EIS

1995 240 Shamrock Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also See VCU 429 and 436 87 

438

Shamrock 

Timber Sale 

EIS

1995 Originally 240 Shamrock Timber harvest using hi-lead (majority), skyline, and shovel yarding systems. Also See VCU 429 and 436 9 

438

Central 

Kupreanof 

Timber Harvest 

EIS

Planned 

2009

Timber harvest from roaded areas. Also see VCUs 426, 

427.1, 429, 436

439

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 793 South Lindy Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 13

439

South 

Lindenberg 

Timber Sale 

EIS

1996 793 South Park Re- Sale Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 13 

10 ▪ Appendix C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

439

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 793 South Sand Re- Offer Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 23 

439

Toncan Timber 

Sale - 

Lindenberg 

Peninsula EA 

1984 521 Toncan Clearcut timber harvest and road building activities. 70 

439

Toncan Timber 

Sale - 

Lindenberg 

Peninsula EA 

1984 Originally 521 Toncan Clearcut timber harvest and road building activities. 49

439 Tonka EIS Planned 2009 Timber harvest and related infrastructure development within Phase I areas on South Lindenberg Peninsula (also in VCU 437 and 447)

4411 Pre-Nepa N/A N/A Partial-cut N/A 19 4411 Pre-Nepa N/A N/A Partial-cut N/A 283 4411 Pre-Nepa N/A N/A Partial-cut N/A 73 

442

Portage Bay - 

12 Mile Timber 

Sale

1975 229 Alp Portage

Timber harvest and associated road building activities using 

the clearcut silvicultural prescription using both hi-lead and 

aerial logging systems. Construction of a logging camp and a 

Log Transfer Facility. Even-aged silviculture prescription.

19

442

Portage Bay - 

12 Mile Timber 

Sale

1975 Originally 229 Alp Portage

Timber harvest and associated road building activities using 

the clearcut silvicultural prescription using both hi-lead and 

aerial logging systems. Construction of a logging camp and a 

Log Transfer Facility. Even-aged silviculture prescription. 

22 

442

Bohemia Mtn 

Timber Sale 

FEIS ('91) and 

FSEIS ('95)

1995 343 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and two-aged silviculture prescription. Also see VCU 

424.

77 

442

Bohemia Mtn 

Timber Sale 

FEIS ('91) and 

FSEIS ('95)

1995 Originally 343 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and two-aged silviculture prescription. Also see VCU 

424.

90 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

442

Bohemia Mtn 

Timber Sale 

FEIS ('91) and 

FSEIS ('95)

1995 Originally 343 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and two-aged silviculture prescription. Also see VCU 

424.

26 

442

Bohemia Mtn 

Timber Sale 

FEIS ('91) and 

FSEIS ('95)

1995 Originally 343 Bohemia

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and two-aged silviculture prescription. Also see VCU 

424.

82 

442

Bohemia Mtn 

Timber Sale 

FEIS ('91) and 

FSEIS ('95)

1995 Originally 343 Goose

Timber harvest and associated road building activities using a 

combination of helicopter and cable logging systems. Evenaged and two-aged silviculture prescription. Also see VCU 

424.

69 

442 Pre-Nepa N/A 272 Partial Cut

Pre-industrial scale logging from about 1913 to early '50s. 

Vast majority of harvest was clearcut; some selective harvest 

using A-fram logging systems and focusing on hi-value trees 

for sawing canary boxes, lumber, airplanes, and construction 

of fish traps. Even-aged silviculture prescription.

10 

442 Pre-Nepa N/A Originally 272 Partial Cut

Pre-industrial scale logging from about 1913 to early '50s. 

Vast majority of harvest was clearcut; some selective harvest 

using A-fram logging systems and focusing on hi-value trees 

for sawing canary boxes, lumber, airplanes, and construction 

of fish traps. Even-aged silviculture prescription.

16 

442 Pre-Nepa N/A Originally 272 Partial Cut

Pre-industrial scale logging from about 1913 to early '50s. 

Vast majority of harvest was clearcut; some selective harvest 

using A-fram logging systems and focusing on hi-value trees 

for sawing canary boxes, lumber, airplanes, and construction 

of fish traps. Even-aged silviculture prescription.

16

442 Pre-Nepa N/A Originally 272 Partial Cut

Pre-industrial scale logging from about 1913 to early '50s. 

Vast majority of harvest was clearcut; some selective harvest 

using A-fram logging systems and focusing on hi-value trees 

for sawing canary boxes, lumber, airplanes, and construction 

of fish traps. Even-aged silviculture prescription.

20 

12 

▪ Appendix 

C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

442 Pre-Nepa N/A Originally 272 Partial Cut

Pre-industrial scale logging from about 1913 to early '50s. 

Vast majority of harvest was clearcut; some selective harvest 

using A-fram logging systems and focusing on hi-value trees 

for sawing canary boxes, lumber, airplanes, and construction 

of fish traps. Even-aged silviculture prescription.

55 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

442 Pre-Nepa N/A N/A Portage Bay

 Timber Harvest using a crawler type tractor swing logging 

system. Even-aged silviculture prescription. Salvage sale 

was for salvage of blowdown timber

31 

442 Portage Bay

 Timber Harvest using a crawler type tractor swing logging 

system. Even-aged silviculture prescription. Salvage sale 

was for salvage of blowdown timber

16 

442

Portage Bay 

Salvage 

Timber Sale

1991 Portage Bay Salvage The proposed sale consists of nine timber harvest units with a total acreage of 144 acres. The units range in size from 4 to 26 acres. All units will be accessed via existing roads. 30 

442

Portage Bay 

Salvage 

Timber Sale

1991 Portage Bay Salvage The proposed sale consists of nine timber harvest units with a total acreage of 144 acres. The units range in size from 4 to 26 acres. All units will be accessed via existing roads. 12 

442 Pre-Nepa N/A N/A Portage Bay West #2 10442 Pre-Nepa N/A N/A Portage Bay West #2 29 

442 Portage Bay Slide 9 

442 SPUDD 11 442

Todahl Timber 

Sale-Kupreanof 

Island EA

1983 81 Todahl

Timber harvest and associated road building activities using 

the clearcut silvicultural prescription using both hi-lead cable 

yarding systems. Even-aged silviculture prescription.

72 

442 N/A N/A N/A Todahl Scattered 3 443 Pre-Nepa 1959 N/A Todahl Creek 1, 2 and 3 Creek sales for timber harvests using a crawler type tractor swing and hi-lead cable logging system. Even-aged silviculture prescription. 10 

443 Pre-Nepa 1960 N/A Todahl Creek 1, 2 and 3 Creek sales for timber harvests using a crawler type tractor swing and hi-lead cable logging system. Even-aged silviculture prescription. 77 443

Todahl Timber 

Sale-Kupreanof 

Island EA

1983 1000 Todahl 

Timber harvest and associated road building activities using 

partial cut silviculture prescription and helicopter logging 

systems. Two Aged silviculture prescription. 

46

14 

▪ Appendix 

C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

443

Todahl Timber 

Sale-Kupreanof 

Island EA

1983 Originally 1000 Todahl Timber harvest and associated road building activities using partial cut silviculture prescription and helicopter logging systems. Two Aged silviculture prescription. 485 

443 N/A N/A N/A Todahl Scattered 625 443

Todahl 

Backline 

Timber Harvest 

EA

1998 123 Todahl

444

Portage Bay - 

12 Mile Timber 

Sale EIS and 

Missionary 

Timber Sale 

EA

1975 (12 

Mile) and 

1989

1899 Alp Portage

Timber harvest and associated road building activities using hilead cable logging and aerial systems. Construction of 

logging camp and log transfer facility (12 Mile). Even-aged 

silviculture prescription.

32

444

Portage Bay - 

12 Mile Timber 

Sale EIS and 

Missionary 

Timber Sale 

EA

1975 (12 

Mile) and 

1989

Originally 

1899 Alp Portage

Timber harvest and associated road building activities using hilead cable logging and aerial systems. Construction of 

logging camp and log transfer facility (12 Mile). Even-aged 

silviculture prescription.

64

444

Portage Bay - 

12 Mile Timber 

Sale EIS and 

Missionary 

Timber Sale 

EA

1975 (12 

Mile) and 

1989

Originally 

1899 Alp Portage

Timber harvest and associated road building activities using hilead cable logging and aerial systems. Construction of 

logging camp and log transfer facility (12 Mile). Even-aged 

silviculture prescription.

48

444

Portage Bay - 

12 Mile Timber 

Sale EIS and 

Missionary 

Timber Sale 

EA

1975 (12 

Mile) and 

1989

Originally 

1899 Alp Portage

Timber harvest and associated road building activities using hilead cable logging and aerial systems. Construction of 

logging camp and log transfer facility (12 Mile). Even-aged 

silviculture prescription.

22

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

444

Alternatives to 

Clearcut 

Research 

Study EA

1996 360 ATC Study the effects of various silvicultural prescriptions. Even- aged and Uneven-aged silviculture prescription. 405 

444 Portage 88 

444

MitkofKupreanof 

Small Timber 

Sale EA

1991 164 Portage Bay Salvage Salvage timber harvest and associated road building using cable logging systems. Even-aged silviculture prescription. 132 

444 Scott Peak ROD 2006 348 Not sold as of April 2007 Approximately 8.3mmbf of timber available for harvest. 

445 N/A N/A N/A Partial Cut N/A 47 445 N/A N/A N/A Partial Cut N/A 68 445 N/A N/A N/A Partial Cut N/A 15 447

South 

Lindenberg 

Timber Sale 

EIS

1996 498 Bowen

Clearcut (majority) and partial harvest using skyline, hi-lead, 

helicopter, and shovel yarding systems. Road construction 

and pit development also performed. 

10 

447

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 498 FingerPoint Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 43

447

South 

Lindenberg 

Timber Sale 

EIS

1996 Originally 498 Lindenberg Clearcut (majority) and partial harvest using skyline, hi-lead, helicopter, and shovel yarding systems. Road construction and pit development also performed. 24 

447 N/A N/A N/A KAKE-Non FS Sales Estimated acreage 59 

447 Tatonka 4 

447

Tonka Mtn. 

Timber Sale 

EA

1976 844 Tonka Mt.

Clearcut and partial harvest using hi-lead and partial 

suspension cable yarding systems. Road construction 

activities included.

47 

447

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 844 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 14

447

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 844 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 89 

16 ▪ Appendix C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubT

Acre

Treate

Yea

447

Tonka Mtn. 

Timber Sale 

EA

1976 Originally 844 Tonka Mt. Clearcut and partial harvest using hi-lead and partial suspension cable yarding systems. Road construction activities included. 22 

447 Pre-Nepa N/A N/A Unidentified N/A 7 447 Tonka EIS Planned 2009 Timber harvest and related infrastructure development within Phase I areas on South Lindenberg Peninsula (also in VCU 437 and 447)

448 Pre-Nepa N/A N/A Grief Island N/A 33 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubTotal 

Acres 

Treated by 

Year

Year 

Treated

425 Hamilton River 213 1987425 Hamilton River 148 1988425 N/A N/A N/A Kake - Non FS Sales N/A 541 1979 

425 N/A N/A N/A Kake - Non FS Sales N/A 494 1982 

425 N/A N/A N/A Kake - Non FS Sales N/A 110 1983 

425 N/A N/A N/A Kake - Non FS Sales N/A 693 1984 

425 N/A N/A N/A Kake - Non FS Sales N/A 369 1985 

425 N/A N/A N/A Kake - Non FS Sales N/A 454 1986 

425 N/A N/A N/A Kake - Non FS Sales N/A 222 1987 

425 N/A N/A N/A Kake - Non FS Sales N/A 207 1988 

425 N/A N/A N/A Kake - Non FS Sales N/A 54 1992 

425 N/A N/A N/A Kake - Non FS Sales N/A 63 1993 

425 N/A N/A N/A Kake - Non FS Sales N/A 322 1994 

425 N/A N/A N/A Kake - Non FS Sales N/A 43 1995 

426 Hamilton North 18 1987 

426 Hamilton River 147 1987 

18 ▪ Appendix C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubTotal 

Acres 

Treated by 

Year

Year 

Treated

426 Hamilton South 83 2003 

426 Unidentified 106 2003 426

FY 2006 

Precommerical 

Thinning Project

2006 292 Big John

This project thinned 8 overstocked 

second growth stands to a 

systematic spacing in order to 

promote the diameter and height 

growth of the largest, best-formed 

trees in the stand(717 acres total). 

Also see VCU 4271.

292 2006

4271

FY 2006 

Precommerical 

Thinning Project

2006 425 Big John

This project thinned 8 overstocked 

second growth stands to a 

systematic spacing in order to 

promote the diameter and height 

growth of the largest, best-formed 

trees in the stand (717 acres total). 

Also see VCU 426.

425 2006

4270 Entrance Island 58 1990 

4270 Hamilton South 34 2003 

431 Totem Pole #1 81 1990 

431 Yellow-Island 349 1983 431 56 1995431 Unidentified 25 1995 432 Totem Bay 26 1989 432 53 1990432 54 1986433 Douglas Bay 189 1984 433 206 1986

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubTotal 

Acres 

Treated by 

Year

Year 

Treated

433 38 1988433 8 1990433 Mitchell Point Salvage 3 1987 

433 Unidentified 159 1987 433 81 1988434 Little Level Is. 44 1983 434 43 1984434 Level Island 57 1983 434 20 1986434 Mitchell Point Salvage 71 1984 

434 104 1985434 190 1986434 56 1987434 132 1995434 Unidentified 11 1954 434 36 1983434 27 1984434 142 1985434 Duncan Tree Thinning Project 2009 285 Duncan Tree Thinning Project Thinning two overstocked second growth stands S

435 Duncan Tree Thinning Project 2009 285 Duncan Tree Thinning Project Thinning two overstocked second growth stands S

435 Little Duncan 31 1995 437 Ranger Sale 28 1989 

20 

▪ Appendix 

C Central Kuprean
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubTotal 

Acres 

Treated by 

Year

Year 

Treated

437 Tonka/Overlook Tree Thinning 2009 1006 Tonka PCT Pre-commercial thinning of 23 overstocked young growth stands 

438 Little Duncan 23 1990 438 Unidentified 47 1990 442 AK Pulp Co. 94 2002442 Portage Bay West #2 23 1995

442 95 443 Todahl 17 1995 443 Unidentified 70 1992 444

Alaska Pulp 

Corp. Long-term 

Timber Contract

 190 AK Pulp Co 190 2000 

444 62 62 2002444 413 413 2004444 270 447 Blind River 8 1981447 Falls Creek 113 1984 447 249 1985

447 157 1988447 Unidentified 8 1978 447 146 1979447 48 1980447 92 1981447 51 1982447 190 1983447 Tonka/Overlook Tree Thinning 2009 1006 Tonka PCT Pre-commercial thinning of 23 overstocked young growth stands 

447 32 1984448 AK Pulp Co 10 1992 

Central Kupreanof Timber Harvest FEIS 
VCU

Decision 

Document or 

Activity Name

Year 

Signed

Unit Acres 

Planned Sale Name Description

SubTotal 

Acres 

Treated by 

Year

Year 

Treated

448 158 1994448 Blowdown Salvage 9 1994

448 17 2004448 Grief Island 32 1989

22 

▪ Appendix 

C Central Kuprean
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

All Kupreanof Landscape Analysis 2000 Identify ecosystem dynamics on Island, includ

projects that would implement Forest Plan w

All Access and Travel Mangement EA Planned in 2009

Analyze and identify the most efficient road 

Ranger District. Will include determining future 

trails and the identification of roads and trails 

and be decommis

422 Transportation Kake to Seal Point Access 2004

Plans to upgrade and pave the road from 

the 6000/6040 junction. Road will be rea

and two bridges will be replaced. Implem

VCU 423

423 Facilities Kake Bunkhouse Sewage Replacement 2001 The proposed activities include replacing 

drain line on the 

423 Transportation Kake to Seal Point Access 2004

Plans to upgrade and pave the road from 

the 6000/6040 junction. Road will be rea

and two bridges will be replaced. Implem

VCU 422

423 Special Use SeaAlaska Timber Corp. Road Use Permit 2006

One-year road permit for SeaAlaska fo

Road 6040. Use for commercial transp

property. Also see 

423 Special Use Renewal of Existing Special Use Authorizations 2006 Renew special use authorizations for 

communication f

424 Transportation Goose Lake Road Extension EA 1985

Extend the existing road from Portage Ba

System. The project was not fully i

construction in VCU 442. Road built is i

(Timber)

424 Transportation Safety Improvements on Kupreanof Is 1998

Repair deteriorating turnouts and road a

rock pit in close proximity to maintenanc

and 427

424 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 425, 426, 4

425 Mining/Transporta tion Small Boat Harbor Development 1980

Quarry site is a limestone monolith. Dev

face. Approximately 6 acres of alrea

permanently altered by the quarry. Road 

the quarry development would require the 

approximately 1000ft along the road in o

facilities. An estimated 1 acre area of inte

Point would be permanently covered by 

was never imple

Central Kupreanof Timber Harvest FEIS 
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

425 Recreation/ Maintenance Hamilton Creek Trail CE 1993 Resurface 4,400 feet of trail using grav

tread, and conduct maintenance at 3 s

trailhead and directional signs, and resu

425 Recreation Little Hamilton Day Use Area 1994 Proposed day u425 Transportation Vegetation Removal for Kake Airport 1996

Special permit issued to State of Alaska t

of Forest Land to aid in navigation and 

airport.

425 Recreation Seal Point Recreation Area EA 1997 Construction of a boat ramp, placement 

sites, and resurfaced parking area 

425 Transportation Safety Improvements on Kupreanof Is 1998

Repair deteriorating turnouts and road a

rock pit in close proximity to maintenanc

and 427

425 Special Use Kake Red Cedar Special Interest Area 1999 The area has historically been used to 

Native crafts and firewo

425 Recreation/ Maintenance Goose Lake Trail Maintenance CE 2000 Resurface to maintain existing trail. Proje

linear feet of trail and installa

425 Recreation/ Maintenance Cathedral Falls CE 2000 Resurface to maintain existing trail. Proje

linear feet of gravel turnpike a

425 Administration Replacement of Kake Crew Quarters Facility 2003 Replace existing crew bunkhouse a425 Transportation Kake to Seal Point Access 2004

Plans to reconstruct 7 miles of forest roa

the existing corridor of FS Road 6040 

changes. As of 3/2007 pro

425 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 426, 4

425 Special Use State of Alaska Special Use Permit 2005

A 10-year special use permit issued to th

Transportation and Public Facilities to a

maintain visibility for navigation a

425 Special Use SeaAlaska Timber Corp. Road Use Permit 2006

One-year road permit for SeaAlaska fo

Road 6040. Use for commercial transp

property. Also see 

426 Transportation

Construction of One Mile of Road as an 

Alternative Facility under the North Irish Creek 

Timber Sale Contract (DN and FONSI)

1990

This proposed road would connect Road

designed and built to Forest Service spec

the scope of the timber sale contract, 

preparation of the North Irish C

24 ▪ Appendix C Central Kuprean
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

426 Transportation Safety Improvements on Kupreanof Is 1998

Repair deteriorating turnouts and road a

rock pit in close proximity to maintenanc

and 427

426 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 425, 4

427 Transportation Safety Improvements on Kupreanof Is 1998

Repair deteriorating turnouts and road a

rock pit in close proximity to maintenanc

and 426

427 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 425, 4

4271 Transportation Safety Improvements on Kupreanof Is 1998

Repair deteriorating turnouts and road a

rock pit in close proximity to maintenanc

and 426

4271 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 425, 4

428 Fisheries Enhancement Irish Creek Fish Pass 1978 Vertical slot fish pass was 

428 Special Use Tent Platform 2003

The tent platform at the mouth Tunehe

temporary shelter in conjunction with non

activities

428 Aquatic Farm Aquatic Farm Proposal 2005 On state of Alaska land - state recom

tidelands in Rocky Pass for the c

428 Special Use Permit Equipment Storage at Little Duncan Bay 2007 Permit re-iss

429 Fisheries Enhancement Upper Keku Creek Fishway CE 1983 Built in 1984 to provide fish passa

429 Fisheries Enhancement Keku Cascades Modification CE 1985

Project goal is to reduce water velocites d

falls/cascade on Upper Keku to permit gr

to pass upstream. Initial implement

modifications in 

429 Special Use Tent Platform Construction at Irish Lakes 1999 Five-year Special Use Permit for constru

fishing 120 feet from 

429 Transportation Four Leaf Timber Sale Borrow Pits 2000 Nine borrow pits proposed for road cons

Leaf Timber Sale. Also see 

429 Special Use Tent Platform Special Use Re-Authorization at Irish Lakes 2004 Five-year Special Use Permit for constru

fishing 120 feet from 

429 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 425, 4

430

Central Kupreanof Timber Harvest FEIS 
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

431432 Transportation Four Prospective Terminal Transfer Facilities Along the S and SE Coast of Kupreanof Island 1983 See VCU 433 and VCU 434 - Pro433 Transportation Four Prospective Terminal Transfer Facilities Along the S and SE Coast of Kupreanof Island 1983 See VCU 432 and VCU 434 - Pro434 Fisheries Enhancement Kah Sheets Creek Fish Pass 1982

Two barrier falls inhibit spawning salm

increase anadromous fish usage. An ea

attempted in the mid-1960s. Project faile

ice damage. Project nev

434 Transportation Four Prospective Terminal Transfer Facilities Along the S and SE Coast of Kupreanof Island 1983 See VCU 432 and VCU 433 - Pro

434 Recreation/ Maintenance Kah Sheets Lake Trail CE 1993 Resurface to maintain existing trail (

installation of trailhead signs and ma

434 Special Use Renewal of Existing Special Use Authorizations 2006 Crab pot storage at Little Level 435 Transportation Little Duncan Blowdown Log Transfer Point 1976 Project never imp435 Recreation Castle River Trail 1979 New trail between the Castle Flats 435 Recreation Breiland Slough Cabin Site Improvements 1998 Proposal includes constructing a gr435 Minerals/ Geology Mineral Exploration CE 1998

Construct camp for 8 and conduct min

August through September. All access 

inches in diameter and up to 600 ft deep) 

samples. Water from nearby sources 

operation

435 Administration Kah Sheets Electronic Site Designation and Site Plan 2002 Construct permanent electronic site for 

area from Port Protection to Point Bake

Alascom, I

435 Special Use Special use permit for equipment storage at Little Duncan Bay 2007 Permit re-iss

436 Transportation Four Leaf Timber Sale Borrow Pits 2000 Nine borrow pits proposed for road cons

Leaf Timber Sale. Also see 

436 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 425, 4

437 Maintenance Reconstruction of the Tonka Mountain Log Transfer Facility on Kupreanof Island EA 1989 Replacing existing LTF with combination 

supported machinery pad, and modera

removeable skid system, expe

26 ▪ Appendix C Central Kuprean
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

437 Fisheries Enhancement Mitchell Creek Fishpass 1991

Installation of a ladder in 1992 for anad

upstream areas for spawning and rearing

barrier falls above the creek's mouth, 

eastern shore of Du

437 Fisheries Enhancement Creating Pool Habitat for Coho Salmon in Leprechaun Creek CE 1992 Created rearing pools in bedrock area of 

debris for cover and to flush pools of g

437 Fisheries Enhancement Creating Pool Habitat for Coho Salmon in Leprechaun Creek CE 1993 Continued work to Leprechan Creek for e

deepening water behind logs to 

437 Fisheries Enhancement Imprinting Coho with Morpholine, an Artificial Scent 1994 Project used artificial scents to imprint ju

mile section of Michell Creek (below a 

437 Recreation Gravel Trail to Access Mitchell Creek Fishpass CE 2005 Create trail to access existing log road to 

fishpass. Implemen

437 Fisheries Enhancement Mitchell Creek Fishpass Stem-wall Extension 2007 Extended the existing concrete stem-wa

increase the efficiency of the inlet to the 

438 Transportation Four Leaf Timber Sale Borrow Pits 2000 Nine borrow pits proposed for road cons

Leaf Timber Sale. Also see 

438 Transportation Kake Deferred Maintenance CE 2005 Perform maintenance on all mainline road 

Also affects VCU's 424, 425, 4

439 Habitat Improvement Duncan Creek Barrier Modification Enhancement Project-Kup. Is. EA 1977 Three barriers modified to allow for a

watershed above the

439 Habitat Improvement Duncan Creek Barrier Modification Enhancement Project-Kup. Is. DN and FONSI 1998 Further modification of a 30 ft high casca

the Duncan Creek fishpass. Explosives w

channel to improve passage for coho sa

439 Special Use Tent Platform Construction Near Duncan Creek 2001 Special Use Permit through 2005 for c

hunting fishing near old ha

439 Transportation South Lindenberg Road Realignment 2002

PRD rerouted proposed FS road #43500 

area. The new route is accessible from e

main channel of Dun

439 Special Use Tent Platform Construction Near Duncan Creek 2005 Special Use Permit from 2005 through 

platform for hunting fishing near 

439 Special Use Special Use Permit for Isolated Cabin near Ohmer Slough on Duncan Canal (DM) 2005 A five year special use permit issued to 

Hunt for an isolated cabin near Ohm

439 Special Use Special Use Permit for Isolated Cabin near Ohmer Slough on Duncan Canal (DM) 2005 A five year special use permit issued to W

cabin near Ohmer Slough 

Central Kupreanof Timber Harvest FEIS 
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

439 Special Use Special Use Permit for Isolated Cabin near Ohmer Slough on Duncan Canal (DM) 2005 A five year special use permit issued to 

cabin near Ohmer Slough 

439 Fisheries Enhancement Duncan Creek Barrier 2 Modification II 2007

Excavate 13.3 yd^3 of bedrock, loose b

add 1.4 yd^3 of concrete for wall const

bottom of a 200m long cascade to ease t

Implemented in 

440 Minerals/ Geology Duncan Canal Mineral Exploration - CE with DM 2000

Near Taylor Creek, authorize explorato

holes, 2 inches in diameter and 300 to 1

Some vegetation clearing for drilling pl

areas need

440 Special Use Outfitter/Guide Temporary Camp 2000 Camp is a temporary “no trace type” ca

guided fishing a big game hunts. L

440 Recreation Towers Lake Cabin - Decommission 2006 Dismantle and remove or burn abando

4411 Recreation Duncan Salt Chuck West Cabin Project 1991 District is considering replacement of the 

removal to one of three 

442 Recreation Portage Bay Administrative Cabin No Record Administrative Cabin in the Portage Ba

public cabin in 

442 Recreation Trail Construction No Record Construction of trail from Petersburg Cree

445)

442 Transportation Goose Lake Road Extension 1985

Extend the existing road from Portage Ba

System. The project was not fully im

construction in VCD 424. Road built is i

(Timber)

442 Fisheries Enhancement Portage Creek Dual Fishway EA 1993 Two fish passages constructed on Portag

is a vertical slot and the upper fishp

442 Mainitenance Log Transfer Facilities Maintenance - National Pollution Discharge Elimination System CE 1993 Improve maintenance at Log Transfer Fa

District to control transp

442 Recreation West Point Cabin Construction 1994 Construction of recreation cabin nea442 Special use Special Use Permit for an Isolated Cabin at Portage Bay 2005 A five year special use permit issued to H

isolated cabin at Portage Bay 

442 Recreation West Point Cabin Construction 2006

Improvements: Construction of a retaini

to halt erosion. Reconstruction of 40

Fredrick Sound to impro

443 Fisheries Enhancement Stocking Kane Lake 1964 Arctic Grayling planted in Kane Lak

28 ▪ Appendix C Central Kuprean
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

443 Special Use Outfitter/Guide Temporary Camp 2001

Proposed outfitter/guide temporary “n

campsite would be used in association w

up to four clients and one or two guides. 

end of Kupreanof Island, w

443 Watershed Restoration Portage Bay Landslide Seeding Project CE 2006 Seeding and fertilizing of 10 acres of 

landslide

444 Habitat Improvement Twelvemile Creek Hardwood Planting (DM) 1996 Four areas (2 slides and 2 rockpits) w

(cottonwood and 

444 Minerals/ Geology Mineral Exploration CE 2000 Conduct mineral explorations in area from 

from April through October of 2001

444 Minerals/ Geology Kupreanof Island Recerational Mineral Suction Dredge Permit Proposal (DM) 2006 Permit the use of a 2.5 inch diameter s

(Coho Creek, Skoags Creek, Towers Arm 

and their tributaries on Kupreanof Is

445 Recreation Trail Construction No Record Construction of trail from Petersburg Cree

442)

445 Recreation Petersburg Lake Trail Construction 1986

Four miles of proposed boardwalk trail 

north shore of Petersburg Creek. The ex

of old logging road near the lower re

Petersburg C

445 Recreation Petersburg Lake Trail Reconstruction 1993 Propose to re-route the trail to avoid Sha

to meet the eligibility criteria for the Nati

445 Recreation Petersburg Lake Cabin Reconstruction Project 2001 Reconstruct and relocate the Petersb

Petersburg Creek - Duncan Salt Chuck W

445 Special Use Special Use Permit for an Isolated Cabin at Petersburg Creek 2005 A five year special use permit issued to K

cabin at Petersbu

445 Special Use Special Use Permit for an Isolated Cabin at Petersburg Creek 2005

A five year special use permit issued to J

for an isolated cabin at P

445 Special Use Special Use Permit for an Isolated Cabin at Petersburg Creek 2005 A five year special use permit issued to 

cabin at Petersbu

445 Recreation Petersburg Mountain Trail Reconstruction 2006

Hardening and maintenance of approx

section of trail. All culverts will be remo

Ditches along this section will be cleared 

middle and upper sections of the existing 

a combination of natural, durable tread an

integrated. Also see VC

Central Kupreanof Timber Harvest FEIS 
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

445 Special Use Special Use Permit for Isolated Cabin near Petersburg Creek (DM) 2006 Special use permit to new owner of an ex

authorized the removal of a deteriorated 

with structures that are the same siz

445 Recreation Petersburg Lake Trail Reroute 2007

Reroute a 1900 foot section of Petersburg 

Creek - Duncan Salt Chuck Wilderness b

bank has removed much of existing trai

completed in 2

445 Habitat Improvement Petersburg Creek - Duncan Salt Chuck Wilderness Brass Buttons Control Project - EA Planned in 2007 Control of non-native species Cotula 

Possible control methods: herbicides, b

hand pullin

446 Recreation Petersburg Mountain Trail Reconstruction 2006

Hardening and maintenance of approx

section of trail. All culverts will be remo

Ditches along this section will be cleared 

middle and upper sections of the existing 

a combination of natural, durable tread an

integrated. Also see VC

447 Special Interest YCC Brush-Clearing Project at Cemetery Behind Sasby Island 1978 Brush removal at th

447 Transportation Tonka Mountain LFT Relocation Alternative Site 2B 1988 Project was never im

447 Administration/ Maintenance Lindenburg Peak Communications Site 1990 Consists of the construction of one 4m x 4

two associated prop

447 Administration/ Maintenance 1996 Communication Site Plan for Lindenberg Peak and Amend the Communication Site Special Use Permit 1996 Commercial facilities owner applied to am

enlarge and upgrade the facilities at this 

the commercial communication 

447 Administration/ Maintenance 1998 Communication Site Plan for Lindenberg Peak and Amend the Communication Site Special Use Permit 1998 AP&T Wireless applied for permit to am

upgrading their facilities at Lindenberg P

properties removed and new 

447 Special Use Management Lindenburg Peak Communications Site Facility Upgrade Implemetation planned for 2008. 2007

Ap&T Wireless proposes to upgrade e

including: removing existing tower, inst

antennas, moving existing fuel tank, and 

and walkw

447 Transportation Kupreanof Right of Way, CE / DM 31.1b 1999 Authorized reduction and transfer of F

through Lot 14, City 

447 Special Use National Guard Training Activities 2000 National Guard Train447 Land Acquisition from Alaska Mental Health Trust Land Office 2003 Petersburg Creek Parcel 447 Special Use Communication Facilities and Power Transmission Lines Renewal Authorizations 2006 Renew special use authorizations for 

communication f

30 ▪ Appendix C Central Kuprean
VCU Activity /Use Decision Document or Activity Name Year Signed Descriptio

447 Recreation Petersburg Mountain Trail Reconstruction 2006

Hardening and maintenance of approx

section of trail. All culverts will be remo

Ditches along this section will be cleared 

middle and upper sections of the existing 

a combination of natural, durable tread an

integrated. Also see VC

Other Special Use Authorized Crabpot Storage CE 2009 Authorized crab pot storage allowed on 

OTHER Special Use Authorized Crabpot Storage DM 1995 Outlines areas where crabpot storage 

Ranger Dist

OTHER Special Use Renewal of Existing Special Use Authorizations 2000 Eight permit holders have special use p

wish to renew their authorization

Central Kupreanof Timber Harvest FEIS 
Appendix D 

Agency Responses 

to Public Comments 

on the Central 

Kupreanof Timber 

Harvest Draft 

Environmental 

Impact Statement 

Response to Comments on Draft EIS 

Introduction 

Appendix D is the Forest Service response to comments received for 

the Central Kupreanof Timber Harvest Draft Environmental Impact 

Statement (Draft EIS). 

Regulatory Guidance on Use of Public Comment 

Response to comments should be the underlying purpose behind the 

structure of any comment analysis process. CEQ regulations provide 

clear guidance on both the intent of soliciting public comment and 

how comment should be used. These regulations require agencies to 

“assess and consider comments both individually and collectively” (40 

CFR 1503.4). 

Analysis and Incorporation of Public Comment 

Agencies, organizations, and individuals submitted written comments 

on the Central Kupreanof Timber Harvest Draft EIS; the 

interdisciplinary team (IDT) thoroughly read and objectively analyzed 

all the comment letters received. Letters from individuals and 

organization were considered both individually and collectively, as 

many of the letters had the same or similar concerns. The comments 

were annotated and sorted by topic. In order to avoid repetition and 

extensive cross-referencing, and to provide a more comprehensive 

response, we have categorize concerns by topic and offered a 

consolidated response to the concerns. Comments fell into two broad 

categories: 

Those within the scope of the project: 

Most comments within the scope of this project have been 

incorporated into the Final EIS or analysis for the Final EIS to the 

extent practicable. Some comments ask for clarification or additional 

information in the Final EIS. Other comments requested certain 

information be considered, requested modification to any alternative, 

or suggested a new alternative altogether. 

Those outside the scope of the project: 

Many comments are addressed through Forest Plan or other direction. 

Some comments disagreed with the Forest Plan and other regulations 

decided at a different level, which makes them beyond the project area 

or speculation that does not involve reasonably foreseeable future 

projects are also beyond the scope of this document. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 1

Appendix D
Letters received during the 45-day comment period from Federal and 

State agencies, organizations, and individuals are published in this 

appendix. The tables below offer a reference to pages where individual 

annotated letters can be found as well as cross-reference responses. 

Table D-1 Individuals, Organizations and Agencies Submitting 

Comments on the Central Kupreanof Timber Harvest Project 

Commenter Response 

Abbreviation Page 

Alaska Forest Association AFA 81 

David Beebe Beebe 84 

US Department of the Interior USDI 88 

Environmental Protection Agency EPA 91 

Greenpeace/Cascadia Wildlands 

Project/Juneau Group of the 

Sierra Club/Natural Resources 

Defense Council/Eric Lee/Becky 

Knight/Dave Beebe 

GP 96 

National Oceanic and Atmospheric 

Administration NOAA 113 

Organized Village of Kake OVK 116 

Southeast Alaska Environmental 

Conservation Council/Sitka 

Conservation Council 

SCS 118 

State of Alaska Department of 

Natural Resources State 162 

Trout Unlimited TU 173 

The Wilderness Society WS 176 

Rebecca Knight BK 182 

David Randrup DR 183 

2 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Table D-2 Comment Categories and Response Page Numbers

Resource Issue Comment (s) 

Response 

Page 

Number 

Aquatics Roads/Fish 

Crossings 

State HC-1, State 

HC-3, State HC-7, 

NOAA-4, USDI-6 

11 

 State HC-4 11 

 State HC-5 11 

 State HC-12, TU-5 12 

 NOAA-2 12 

 State HC-13 13 

 GP XIII-2, and 3 13 

 GP XIII-4 14 

 GP XIII-6 14 

 GP XIII-9 15 

 Road Cards State HC-7, USDI-6 15 

 State HC-8, USDI-6 15 

 State HC-10 16 

 State HC-9 16 

 State HC-11 16 

 State HC-6 16 

 State RC-4 17 

 SCS V-5 17 

 Temporary Roads GP XIII-8 17 

Watersheds/Water 

Quality 

State HC-2, NOAA3, SCS VIII-7, 

USDI-4 

17 

 EPA-1 18 

 TU-3 18 

 OVK-5 19 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 3

Appendix D
Resource Issue Comment (s) 

Response 

Page 

Number 

Aquatics Watersheds/Water 

Quality 

TU-1, WS-3, SCS 

VIII-4 20 

 TU-4 20 

 DR-4 21 

 Beebe-2 22 

 GPXIII-1 22 

 GPXIII-5 23 

 GP XIII-7, SCS VIII2 23 

 SCS VIII-6 24 

 EPA-8 24 

 Habitat State HC-14, SCS 

VIII-3 25 

 SCS VIII-5 25 

 NOAA-1 26 

Climate Change General 

EPA-7, SCS X-2, 

SCS XI-2, SCS XI-3, 

SCS XI-4 

26 

Carbon 

Sequestration 

BK-4, SCS XI-1 27 

Invasives General EPA-5 27 

Minerals General DR-12 28 

NEPA General GP I-1 28 

 

GP III-1, GP III-2, 

SCS I-1, GP IV-1, 

GP IV-2, SCS II-1, 

SCS II-2, SCS II-3, 

SCS II-4, GP V-3, 

SCS VI-11, GP V-1 

29 

 SCS I-2 32 

 SCS I-3, GP V-14 32 

4 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Resource Issue Comment (s) 

Response 

Page 

Number 

NEPA General SCS I-4 32 

 BK-5 33 

Inventoried 

Roadless Areas General SCS IV-2 34 

 SCS IV-3, GP XIV-1 34 

 SCS IV-1 35 

 WS-4, WS-5 35 

Silviculture Alaska yellowcedar 

SCS X-1 36 

 SCS III-2 36 

 SCS X-2 37 

 Redcedar SCS X-3 38 

 Clearcutting SCS X-4 38 

 EPA-10 39 

 Windthrow State W-1 39 

Phase One Lands/ 

Suitability 

WS-2 40 

Large Tree/OldGrowth 

Highgrading 

SCS X-5 

40 

Unit Suggestions General AFA-8 40 

 AFA-9 41 

 AFA-10 41 

 AFA-11 41 

Socioeconomics General Beebe-3, SCS III-7 42 

 SCS III-5 42 

 SCS III-6 43 

Soils General Beebe-4 45 

 NOAA-5, 

EPA-9 

45 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 5

Appendix D
Resource Issue Comment (s) 

Response 

Page 

Number 

Timber 

Economics Supply/Demand AFA-1 45 

 AFA-3 46 

 AFA-4 46 

 AFA-5 47 

 DR-13 48 

 AFA-7 48 

 BK-1, BK-3, SCS X6, WS-1, GP II-1 48 

 Economics State EC-1, GP II-1, 

SCS III-4 50 

 SCS III-1 51 

 AFA-6, State EC-2 52 

 State EC-3 53 

Small Sales and 

Microsales 

Beebe-1, SCS II-5 53 

Financial 

Efficiency Analysis 

SCS III-3, GP XVI-1 54 

Transportation General State RC-1 55 

 State RC-2, 

SCS V-2 

55 

 State RC-3 56 

 GP XV-1, GP XV-2, 

SCS V-3 56 

 

SCS V-4, SCS VIII-1 

GP XV-3, GP XV-5, 

GP XV-7 

56 

 GP XV-4 58 

 GP XV-6 58 

 GP XV-8 58 

 EPA-3 59 

6 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Resource Issue Comment (s) 

Response 

Page 

Number 

Wildlife Biological Studies DR-9 59 

 DR-10 60 

 Bald Eagles USDI-5 60 

 Deer BK-2 60 

 GP V-11, 

State WC-8 

61 

 GP V-13 61 

 SCS VI-10 62 

 DR-3 64 

 DR-5 64 

 Goshawks 

USDI-1, USDI-2, 

State WC-6, OVK-3, 

SCS VI-14, SCS VI15 

65 

 Marten 

State WC-7, OVK-1, 

OVK-3, SCS VI-6, 

SCS VI-7, SCS VI-8, 

EPA-4 

65 

Wolf/Road 

Densities 

State WS-6, GP V12, OVK-2, SCS VI9, State WC-4, GP 

V-10, GP V-4, SCS 

V-1 

66 

 Black Bear OVK-4, SCS VI-4, 

SCS VI-5 68 

 Subsistence WS-7, OVK-6, SCS 

VI-21 68 

 WS-8, SCS VI-22 68 

 GP V-12, GP V-12a, 

State WC-8 69 

 SCS VI-20 69 

 SCS VI-23 70 

 SCS VI-19 70 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 7

Appendix D
Resource Issue Comment (s) 

Response 

Page 

Number 

Wildlife Subsistence State ANILCA -3 71 

 SCS VI-24 71 

Old-Growth 

Reserves (OGRs) 

DR-1 71 

 DR-2 72 

 State WC-1, SCS VI16 72 

 

State WC-5, GP V17, OVK-3, SCS VI17, SCS VI-18, 

73 

Productive OldGrowth (POG) 

GP V-2, GP V-6, GP 

V-7, SCS VI-2, SCS 

VI-3, SCS VI-5a 

73 

 Roads State ANILCA-1 74 

 State ANILCA-2 75 

 GP V-8 75 

 SCS V-1 75 

 Wildlife Retention DR-6, DR-7 76 

 DR-8 77 

 Wildlife Effects DR-11 77 

 GP V-5, SCS VI-1 78 

Volume 

Strata/Coarse 

Canopy 

USDI-3, State WC-2, 

State WC-3, GP V17 78 

8 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Resource Issue Comment (s) 

Response 

Page 

Number 

Wildlife General 

GP V-16, OVK-3, 

SCS VI-12, SCS VI13 79 

 GP V-9 79 

 GP V-15 80 

 AFA-2 80 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 9

Appendix D
10 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Aquatics 

State HC-1, State HC-3, State HC-7, NOAA-4, USDI-6

The State raised the concern that the proposed culvert sizes 

indicated on the road cards will not pass fish, that stream data is 

generic for stream/channel type, and that there is a lack of field 

verified data. The State also recommends that all bridges, 

specifically on Road 45897, provide for fish passage on all Class I 

and II crossings. 

Response: 

Proposed road-stream crossings on road 45897 were not field verified 

prior to the DEIS. However, any additional streams mapped during 

layout would be assessed for fish habitat, and fish passage would be 

applied to structure design (BMP 14.17). All crossings on fish-bearing 

streams will receive Title 16 consultation prior to implementation to 

ensure structures are adequate, and BMPs will be applied to all 

crossings as appropriate. A slope stability investigation will be 

completed by a soil specialist prior to implementation in areas where 

the proposed road crosses side slopes greater than 67%. The on-site 

investigation will follow Forest Plan protocols. Additional information 

has been added to the FEIS road cards. ADFG will review the fish 

stream crossings for Title 16 MOU concurrence. 

State HC-4 

Crossing information pertaining to reconstructed roads should be 

disclosed. 

Response: 

All crossings on fish-bearing streams will receive Title 16 consultation 

prior to implementation to ensure structures are adequate, and BMPs 

will be applied to all crossings as appropriate. 

State HC-5

More information is needed to determine if stream crossing 

structures are designed and constructed in accordance with FRPA 

standards as well as the soil/water conservation handbook. 

Response: 

Additional road-stream crossing information has been added to the 

FEIS Road Cards. 

Roads/Fish 

Crossings 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 11 Appendix D
All crossings on fish-bearing streams will receive Title 16 consultation 

prior to implementation to ensure structures are adequate, and BMPs 

will be applied to all crossings as appropriate. 

State HC-12, TU-5

The DEIS doesn’t recognize the cumulative impacts to fish habitat 

from past road construction, or the cumulative impact of the 

proposed 60 miles of road and 256 stream crossings. 

Response: 

The DEIS ( pg. 3-107) acknowledges the past activities influencing 

watershed fisheries and hydrology including miles of NFS and 

temporary roads as measured through road densities and percent of 

basin in roads, stream crossings as measured through crossing 

densities and potential effect to hydrologic function, and the number of 

crossings impeding fish passage (red fish culverts). We appreciate 

stakeholder concern about the loss of fish habitat upstream of culverts 

restricting fish passage and acknowledge the need for a more detailed 

analysis. In response, an additional analysis of the culverts that do not 

meet fish passage has been included in the FEIS. This analysis 

includes an estimate of the amount of fish habitat impacted by the red 

fish crossings. Field surveys were used where available otherwise the 

amount of habitat was estimated using GIS layers and aerial 

photography. 

See also NOAA-2 in the Roads and Fish Crossings section of this Appendix. 

NOAA-2

The 61 culverts not meeting fish passage should be described in 

further detail along with the corresponding habitat impacted. 

Culverts should be repaired as part of timber sale to meet Forest 

Standards and to provide consistency with the Clean Water Act. 

Response: 

The Tongass National Forest is also concerned about the loss of fish 

habitat upstream of culverts restricting fish passage and has corrected 

more than 250 red crossings throughout the Forest during the last 

several years. Many of these have been on the Petersburg Ranger 

District. It may not be advisable or feasible to replace all existing red 

culverts with fish passage designed crossings. Many of the crossings 

have very limited amounts of fish habitat upstream and it may be more 

advantageous to mitigate the effects through the Clean Water Act 404 

permit process. An interagency group has made progress on a model 

that would help make management recommendations for red culverts 

which reduce or restrict fish passage. The model was tested in 2006 

and the preliminary findings are available. The model requires 

refinement and additional data needs to be collected before it can be 

12 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
used for all culverts on the forest. The removal or replacement of red 

culverts to improve fish passage has been done and will continue to be 

done when funding opportunities are available. Fish passage on many 

of these culverts may be corrected through the proposed road closures 

identified in the Petersburg Access Travel Management Environmental 

Assessment, planned in 2009. Culverts on roads not associated with 

the proposed timber harvest or future thinning activities may use 

stewardship contracts for removal. The removal of four red crossings 

described in Chapter 3 of the FEIS is associated with the closure of 1.7 

miles of road used for the timber sale. Correcting passage on these 

culverts would create a reduction in the cumulative impacts to fish 

passage. 

See also HC-12, TU-5 in the Roads and Fish Crossings section of this 

Appendix. 

State HC-13

The State would like clarification pertaining to the 19 possible 

culverts to be fixed with this project and the indirect effect of 

closure of 2.0 miles of road. 

Response: 

Fish passage at up to nineteen red crossings may be corrected as part 

of the stewardship opportunities identified through the RAP process, 

and depending on ATM review and decisions in 2009. The removal of 

four red crossings described in Chapter 3 of the FEIS is associated 

with the closure of 1.69 miles of road used for the timber sale. The 

FEIS clarifies the distinction between culverts prioritized for closure 

through ATM recommendations and those related to closure of timber 

haul roads in the FEIS. 

GP XIII-3, GP XIII-2

Clarification requested as to the relation of the numbers in Table 

3-24 of the DEIS in correlation to road density. 

Response: 

As described in the DEIS (3-99) the density values in Table 3-24 are 

used to help quantify the risk of flow-related impacts to aquatic 

systems, and these densities are low in all project-area watersheds. The 

Cederholm value of 2.5% of basin area in roads was used in their study 

as a threshold to determine which basins were more likely to have 

accumulations of fine sediment in streambeds. In this analysis the 

value was used as a relative comparison to the basins within the 

Central Kupreanof project area, for which all values are below 1%. 

This is a conservative comparison since roads built in this project area 

use higher quality rock blasted or drilled from nearby quarries, as 

opposed to native material containing finer particles typically used for 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 13 Appendix D
road construction elsewhere. In response to your comment and those 

of other stakeholders regarding disclosing fish passage problems 

where they occur, additional red pipe analysis has been added to the 

FEIS. This analysis includes an estimate of the amount of fish habitat 

impacted by the culverts. Field surveys were used where available 

otherwise the amount of habitat was estimated using GIS layers and 

aerial photography. 

See also responses to State HC-12; TU-5 and NOAA-2 in the Roads and Fish 

Crossings section of this Appendix. 

GP XIII-4

Analysis should consider impacts of the delay in needed repairs 

due to building new roads. 

Response: 

Maintenance and reconditioning of existing National Forest System 

(NFS) roads is an ongoing process that occurs on a periodic basis. The 

maintenance and reconditioning of NFS roads in the Project Area may 

be in the process of implementation, before, during and after the 

project planning process through separate service contracts to reduce 

the backlog of deferred maintenance. Reconditioning roads may be 

done to comply with best management practices, maintain the existing 

infrastructure for the proposed timber sale, future harvest entries, and 

other National Forest management activities. 

See response to NOAA-2; HC-12 for further discussion related to red fish 

culverts in the Roads and Fish Crossings section of this appendix.

GP XIII-6

Road closure is speculative and won’t mitigate road impacts to 

fish. 

Response: 

The protections in the Forest Plan provided through Riparian 

Standards and Guidelines and Soil and Water Conservation Handbook 

guidance (BMPs) are described in the Unit and Road Cards in the 

DEIS, Volume B, Appendix B (B-4, B-236) and in Appendix B of the 

FEIS . BMPs related to stream protection categories and riparian 

buffers provided through the Tongass Timber Reform Act (TTRA) are 

monitored annually and reported in the Tongass National Forest 

Monitoring and Evaluation Reports, with results indicating a high 

degree of implementation compliance. The DEIS (3-108 through 3-

112) explains the expected effects of road storage, as does the Aquatic 

Resource Report (p17-19; p22-23). These include lower maintenance 

needs, decreased potential for sediment delivery to streams from the 

failure of drainage structures, a lower amount of potential groundwater 

interception by road cuts, lower number of miles in the stream network 

14 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
through removal of those portions associated with ditches, improving 

natural drainage patterns, reducing the risk of culvert plugging and 

stream diversion, and lowering the risk of road failures at stream 

crossings. While the effects were discussed, road storage was never 

analyzed or intended as a mitigation measure. 

See Response to Greenpeace XIII-3 in the Road and Fish Crossing section of 

this Appendix for discussion of the red culvert analysis included in the FEIS. 

GP XIII-9

Discuss the road storage strategy versus just maintaining roads on 

stream crossings. Assuming a road will have to be rebuilt at some 

point, is pulling structures creating more or less impact on fish? 

Response: 

All options to remove or retain culverts will be analyzed under the 

RAP process and the District ATM scheduled for completion in 2009, 

and discussed in the DEIS (pg. 3-50). Additionally, a road 

rehabilitation plan for the Hamilton watershed will be integrated into 

the ATM regarding specific recommendations for road closures. We 

recognize pulling all culverts may not be the most appropriate action 

in all cases. Decisions regarding closure methods are determined 

primarily by known resource concerns and future road management 

objectives for a particular road. Impacts to fish habitat related to 

stream crossings are discussed in the DEIS (pg. 3-100). Forest roads 

must be constructed and maintained in accordance with BMPs to 

ensure flow and circulation patterns and chemical and biological 

characteristics of the waters are not impaired, as per the Clean Water 

Act (404)(f)(1)(E). 

State HC-7, USDI-6

Road 45897- There was a question concerning the no Class II fish 

call and a question regarding culvert design. 

Response: 

Information for the first major stream crossing labeled as Class III was 

field verified. The transition from Class I to Class III was due to a fish 

barrier. Class II field verification has been added, and structure designs 

have been corrected in the FEIS Road Card for Road 45897. 

State HC-8, USDI-6

Road 45808- Fish passage with proposed gradient would be 

difficult. 

Response: 

The FEIS Road Card for Road 45808 has been corrected. 

Road Cards 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 15 Appendix D
State HC-10

Road 45887- Concerned about temporary road fish crossings. 

Response: 

The DEIS (3-105) indicates that bridges will be installed at all 

crossings on streams with fish habitat on proposed temporary roads, 

and would be removed as part of the road’s decommissioning 

following the completion of harvest activities. 

State HC-9

Commenter suggests relocating road to avoid stream crossing. 

Response: 

The road is located on fairly flat ground which slopes down hill at 

approximately 5% grade through timber. Will add comment to road 

card and review during implementation. 

State HC-11

Road 45892 crosses an alluvial fan (commenter suggests moving 

road location to the apex of fan), and has numerous Class III 

crossings proposed. 

Response: 

Options to locate road at apex of alluvial fan will be explored during 

implementation. All applicable Forest Plan Standards and Guidelines, 

Forest Service Manual and Handbooks and (BMPs) will be 

incorporated during design, construction and maintenance of roads. 

Best Management Practices (BMPs) are used to assure soil and water 

resources are considered in transportation planning activities. Any side 

slopes of greater than 67% would be mitigated by full bench 

construction and slope stabilization, if necessary. 

State HC-6

Explain why road 6326 doesn’t show up on the USFS GIS roads 

layer but appears to already have been built according to aerial 

photos. 

Response: 

Road 6326 was a part of the North Irish Timber Sale NEPA document. 

The 0.5 portion proposed for new NFS construction in Central 

Kupreanof was authorized and built as a temporary road in the North 

Irish Timber Sale, and therefore does not show up on the USFS GIS 

roads layer. The adjacent unit was not harvested in North Irish and the 

section of temporary road was coded as decommissioned. The new 

construction proposed in the Central Kupreanof Timber Sale document 

will address the RCS concerns noted in your comments.

16 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
State RC-4

The road cards for 6327 and 45891 do not indicate that bridges 

will be used for crossing the large v-notches along these roads as 

required by AFRPA Best Management Practices. 

Response: 

The potential need for a 60-foot bridge is noted on 6327, but not on 

45891. The road Card for 45891 has been corrected to read a 20-foot 

deep V- notch is crossed at 10+50 feet; a 40 foot bridge may be 

required. All applicable Forest Plan Standards and Guidelines, Forest 

Service Manual and Handbooks and (BMPs) will be incorporated 

during design, construction and maintenance of roads. 

SCS V-5

Drop road 45803 and 45808 due to various habitat impacts. 

Response: 

Existing Road 45803 (with minimal reconstruction) accesses unit 273 

in Alternatives 2 and 4. This road is extended in Alternative 3, 

accessing several units. Existing Road 45808 is currently partially 

open and used in all action alternatives to access timber. Alternatives 2 

and 3 propose reconstruction of the last part of this road to access 

timber. Where these roads already exist, they provide infrastructure to 

the proposed activities and access timber without the cost of new 

construction. 

See also responses to SCS IV-1, SCS IV-2, and SCS IV-3 in the 

Inventoried Roadless Areas section of this Appendix. 

GP XIII-8

Explain stream crossings in Alternative 3 over Class I and II 

streams. 

Response: 

The requirement in the DEIS to use log stringer bridges to cross Class 

I and II streams does not require any specific engineering design that 

would in and of itself make a road become specified (NFS) road. It is 

appropriate to require such crossings on temporary roads to implement 

BMPs. 

State HC-2, NOAA-3, SCS VIII-7, USDI-4

Commenter is concerned about rafting logs at the Hamilton Bay 

LTF as there has been a history of impaired waters. 

Response: 

Stakeholder concern for the potential degradation of water quality due 

Temporary 

Roads 

Watersheds/ 

Water Quality 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 17 Appendix D
to bark accumulation from rafting logs is acknowledged and 

appreciated. The Hamilton Bay LTF is permitted under the EPA 

General Permit AK-G70-0019 to raft or barge logs. It is important to 

retain the option to raft logs in order to provide flexibility to Timber 

Operators regarding cost and equipment needs. Provisions within the 

Timber Sale contract are used to minimize the potential for bark 

accumulation. Provisions summarized in T-845 for LTF Operations, 

Maintenance, and Monitoring account for maintaining the area of the 

LTF free of solid wastes, including wood and bark, to be removed and 

disposed of at a permitted location. In response to comments received, 

an additional analysis comparing historic timber volume to proposed 

volume by alternative was conducted. Results present a wide range of 

potential scenarios for bark accumulation, with values primarily based 

on the volume of timber through the LTF in a given year, and the 

assumptions of the comparison. In the absence of a known decay / 

flushing rate of bark at the site, conclusions are not rigorous and 

should be considered “best guesses”. Results indicate the loss rate of 

bark through decay / flushing exceeds the accumulation rate up to 

approximately 12MBF a year through the LTF, beyond which 

accumulation will occur. The site, therefore, may be sensitive to 

multiple years of rafting large volumes of timber. Dive surveys have 

been requested at the end of each season and at the end of the timber 

sale in the past, but may be requested for shorter intervals according to 

site conditions. Bark accumulation will be monitored and if the 

accumulation exceeds EPA standards, appropriate action will be taken. 

EPA-1

Explain how CWA (Clean Water Act) antidegradation regulations 

are being met. 

Response: 

The State of Alaska’s antidegradation policy states that (1) existing 

water uses and the level of water quality necessary to protect existing 

uses must be maintained and protected; and (2) if the quality of a water 

exceeds levels necessary to support propagation of fish, shellfish, and 

wildlife and recreation in and on the water, that quality must be 

maintained and protected (ADEC 2008). We expect the application of 

BMPs to ensure that existing water quality and uses will be maintained 

and protected. 

TU-3

Trout Unlimited would like a watershed analysis conducted prior 

to management activities. 

Response: 

Thank you for your concern. Guidance concerning circumstances 

requiring a formal watershed analysis are described in Appendix C 

18 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
beginning C-1 of the Forest Plan. Circumstances include adjustments 

to Forest-wide Riparian Standards and Guidelines, before authorizing 

management in a public water system source watershed, and any other 

time a line officer determines a watershed analysis is necessary to 

make an informed decision. These circumstances do not apply to the 

Central Kupreanof watersheds. Watersheds within the project area 

were analyzed in some detail in the FEIS and Aquatics Resource 

Report. Watersheds were quantified in terms of location, climate, 

geology, hydrology, stream density, road density, harvest history, 

landslide inventory, and disturbance regimes including erosion and 

mass movement hazard. District-wide road condition surveys were 

used in conjunction with GIS to determine number of existing stream 

crossings as well as streams requiring additional information or field 

verification. Field surveys were conducted to verify fish presence or 

absence, fish species, stream class and channel type, and to map 

streams in the proposed harvest units and surrounding areas within 

project area watersheds using Global Positioning System (GPS). This 

information was combined with available water quality and fish 

distribution data for an overall watershed characterization. The line 

officer has determined that this level of analysis is sufficient to 

characterize conditions and analyze the effects of the proposed action 

on aquatic resources within the project area. 

OVK-5

OVK is concerned about the cumulative effects of sediment 

delivery to salmon steams, and how this may ultimately affect the 

overall harvest of salmon by OVK members, fisherman and black 

bears. 

Response: 

The Cumulative Watershed Effects section in Chapter 3 describes the 

past, present, and activities in the foreseeable future that can impact 

aquatic resources within project area watersheds. The protections in 

the Forest Plan provided through Riparian Standards and Guidelines 

and Soil and Water Conservation Handbook guidance (BMPs) are 

described in the Unit and Road Cards in the DEIS, Volume B, 

Appendix B (B-4, B-236) and Appendix B of the FEIS. BMPs related 

to stream protection categories and riparian buffers provided through 

the Tongass Timber Reform Act (TTRA) are monitored annually in 

the Tongass National Forest Monitoring and Evaluation Reports, with 

results indicating a high degree of implementation compliance. The 

potential for sediment delivery to streams resulting from timber 

harvest decreases with the passage of time and subsequent vegetation 

regrowth. Hydrologic recovery following harvest due to regrowth of 

vegetation in harvested areas is expected to require between 10 and 30 

years (DEIS p. 3-97). The watersheds affected by the proposed project 

have low levels of cumulative harvest and continue to produce clean 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 19 Appendix D
water and support anadromous and resident fish populations (DEIS, 

Tables 3-22, 3-27). These watersheds are expected to continue to 

support these beneficial uses into the future, regardless of which 

alternative is selected. 

TU-1, WS-3, SCS VIII-4

Both ADF&G and The Nature Conservancy/Audubon Society 

have watershed ranking systems that rate the Irish/Keku Lakes 

system (VCU429), the upper Castle River area (VCU 436), and 

Duncan Bay (438) as high value watersheds that should be 

removed from this project. 

Response: 

Thank you for your comment and concern for these watersheds. We 

recognize many of our stakeholders have developed other systems for 

rating the health/value of watersheds across the Tongass National 

Forest, and that several watersheds including Castle River, Hamilton 

River, Irish/Keku Creek, and West Duncan Canal were determined to 

be high-value watersheds under these rating systems. 

The Tongass National Forest is working cooperatively with many 

stakeholders to use these systems in combination with our own 

Watershed Restoration Plans for determining restoration needs 

throughout the Forest. 

The 2008 Forest Plan directs the multiple-use of our forest resources 

through Land Use Designations applied to VCUs across the Forest. 

Approximately 60% of each of the above watersheds were designated 

in the Forest Plan for Timber Production, and were analyzed for this 

project according to Forest Plan direction. Harvest levels in these 

watersheds are currently low and will continue to have cumulative 

harvest levels below 6 percent for all alternatives (DEIS, Table 3-30).

TU-4

Protection of upper portions of watersheds is important to 

preserving fish habitat throughout the entire stream system. 

Response: 

Headwater streams are protected according to standards established in 

the Forest Plan Riparian Buffer Standards and Guidelines (Appendix 

B), the Aquatic Habitat Management Handbook (FSH 2090.21_30), 

and the application of appropriate BMPs. The DEIS (Appendix B-3) 

summarizes the application of Riparian Management Areas (RMAs) 

and BMPs. See also the DEIS (3-125) for a discussion of wind 

disturbance regarding the concern expressed in the 1997 document 

referenced in your comments. Preliminary results from recent 

monitoring efforts indicate a high degree of success Forest-wide 

20 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
regarding the effectiveness of windfirm buffers. Results from annual 

Tongass Monitoring and Evaluation Reports (USDA Forest Service, 

2007) indicate a very high level of compliance with BMP 

implementation for fish habitat, and soil and water resources. Three 

case study watersheds have been established to determine the 

effectiveness of BMPs for providing protection for these resources. 

Provisional results from this study have been added the FEIS planning 

file (Thompson and Tucker, 2007). 

DR-4

Commenter is concerned about the impacts of road building to 

Castle River and its tributaries, as well as to other fish bearing 

streams within the project area. 

Response: 

We discuss the potential for sediment delivery to streams and the 

associated impacts in the DEIS p.3-104 and the Aquatic Resource 

Report beginning on page 16. We rely on the BMPs in the Soil and 

Water Conservation Handbook (FSH 2509.22) and described in Unit 

and Road Cards in the DEIS Appendix B for maintaining EPA water 

quality standards for designated beneficial uses. The Forest Plan 

Monitoring and Evaluation Plan emphasizes monitoring to ensure 

BMPs are implemented as planned. The Forest Service’s 

implementation and monitoring of BMPs satisfies the requirements of 

the Alaska Non-point Source Pollution Control Strategy and is 

approved by the U.S. EPA, thereby ensuring that USFS activities are 

consistent with the Clean Water Act. The 2007 Tongass National 

Forest Monitoring and Evaluation Report 

(http://www.fs.fed.us/r10/tongass/projects/tlmp/2007_monitoring_repo

rt) indicates that soil and water BMPs were implemented and 

monitored 218 times, with two departures from full implementation 

noted and corrected through mitigation. In response to stakeholder 

concerns about water quality the Forest Service is conducting a study 

in which continuous water quality monitoring instruments were 

installed in three case-study watersheds to determine if BMPs are 

effective in meeting water quality standards. Provisional results from 

this study are available and has been added the FEIS planning file. 

Headwater streams are protected according to standards established in 

the Forest Plan Riparian Buffer Standards and Guidelines (Appendix 

B), the Aquatic Habitat Management Handbook (FSH 2090.21_30), 

and the application of appropriate BMPs. The application of Riparian 

Management Areas (RMA) to Class III and IV headwater streams, as 

well as Class I and II fish streams lower in the watershed, ensures a 

riparian buffer designed to minimize the risk of increased sediment 

delivery. Windfirm buffers are applied in addition to the RMA in those 

areas more prone to windthrow. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 21 Appendix D
Beebe-2

Address the effects of rafting logs at Hamilton Bay, and how bark 

accumulations may affect commercial fishing in the bay. 

Response: 

Your concern for the potential impacts of rafting logs at the Hamilton 

LTF, as well as your observations of conditions in the bay is 

appreciated. We acknowledge that log rafts associated with the 

Hamilton LTF could displace and interfere with commercial fishing 

activities. A description of the potential adverse effects on Marine 

EFH due to LTF activities can be found in the DEIS (p.3-120). An 

Environmental Risk assessment from Alaska Department of Natural 

Resources Division of Mining, Land, and Water under ADL 107727 

for the Hamilton Bay LTF was conducted as part of the proposed LTF 

project, and found no significant environmental risk associated with 

the project. Additionally, the LTF was reviewed for Alaska Coastal 

Marine Program consistency two times and was found consistent with 

ACMP. The Hamilton Bay LTF is permitted under the EPA General 

Permit AK-G70-0019 to raft and barge logs, and the Forest Service 

will retain the flexibility to raft logs if needed. Provisions within the 

Timber Sale contract are used to minimize the potential for bark 

accumulation. Provisions summarized in T-845 for LTF Operations, 

Maintenance, and Monitoring account for maintaining the area of the 

LTF free of solid wastes, including wood and bark, to be removed and 

disposed of at a permitted location. Dive surveys have been requested 

at the end of each season and at the end of the timber sale in the past, 

but may be requested for shorter intervals according to site conditions. 

Bark accumulation will be monitored and if the accumulation exceeds 

EPA standards, appropriate action will be taken. 

GP XIII-1

Please consider impacts of the proposed action on both increased 

peak flows and decreased low flows as a result of the 

implementation of proposed activities. 

Response: 

The potential for increased peak flows are discussed in the DEIS (3-

105). Some of these effects including bed surface fining, smoothing of 

stream channels, and filling of pools were discussed in the Aquatics 

Resource Report (p16). A discussion of low flow was added to the 

FEIS and Aquatics Resource Report. 

22 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
GP XIII-5

Discuss the impact of introducing fine sediment in stream channels 

on salmon habitat, and explain why this delivery would not 

degrade water quality enough to fully maintain the designated 

beneficial use, specifically fish habitat. 

Response: 

We discuss the potential for sediment delivery to streams and the 

associated impacts in the DEIS p.3-104 and the Aquatic Resource 

Report beginning page 16. We rely on the BMPs in the Soil and Water 

Conservation Handbook (FSH 2509.22) and described in Unit and 

Road Cards in the DEIS Appendix B for maintaining EPA water 

quality standards for designated beneficial uses. The Forest Plan 

Monitoring and Evaluation Plan emphasizes monitoring to ensure 

BMPs are implemented as planned. The Forest Service’s 

implementation and monitoring of BMPs satisfies the requirements of 

the Alaska Non-point Source Pollution Control Strategy and is 

approved by the U.S. EPA, thereby ensuring that USFS activities are 

consistent with the Clean Water Act. The 2007 Tongass National 

Forest Monitoring and Evaluation Report 

(http://www.fs.fed.us/r10/tongass/projects/tlmp/2007_monitoring_repo

rt) indicates that soil and water BMPs were implemented and 

monitored 218 times, with two departures from full implementation 

noted and corrected through mitigation. In response to stakeholder 

concerns about water quality the Forest Service is conducting a study 

in which continuous water quality monitoring instruments were 

installed in three case-study watersheds to determine if BMPs are 

effective in meeting water quality standards. Provisional results from 

this study are currently available and have been added to the planning 

file. 

GP XIII-7, SCS VIII-2

Defend the use of a watershed scale analysis, and evaluate past 

harvests at the scale of riparian forests. 

Response: 

Thank you for your comment to reconsider the scale used in the 

analysis. The scale used for determining effects to hydrology and 

fisheries resources and the rationale is described in the DEIS p.3-107. 

This scale (6th level HUC) is recognized by the US Geological Survey 

and is the commonly accepted scale for these project level analyses. 

Past riparian harvest has been quantified by watershed and added to 

the Aquatics Resource Report. Ensuring USFS activities are consistent 

with EPA water quality standards for beneficial uses is ensured 

through BMPs described in the Unit and Road Cards. Maintenance of 

beneficial uses occurs on a site-by-site basis regarding road building 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 23 Appendix D
activities. The 2007 Tongass National Forest Monitoring and 

Evaluation Report (USDA Forest Service, 2007) indicates that soil and 

water BMPs were implemented and monitored 218 times, with two 

departures from full implementation noted and corrected through 

mitigation. In response to stakeholder concerns about water quality the 

Forest Service is conducting a study in which continuous water quality 

monitoring instruments were installed in three case-study watersheds 

to determine if BMPs are effective in meeting water quality standards 

for turbidity and temperature. Provisional results from this study are 

available and have been added to the planning file. 

SCS VIII-6

Discuss stream temperature considerations in detail and the 

cumulative effects of climate change and land management in 

relation to fisheries. 

Response: 

All significant stream channels (Class I-III) within proposed units in 

this project will receive buffers as per the Stream Channel Protection 

Measures outlined in Appendix B of the DEIS. Class IV streams will 

be protected following Best Management Practices also outlined in 

Appendix B of the EIS. Long-term effects of timber harvesting and 

road building on summer low flows are not well studied. In response 

to your concerns about temperature exceedance on Hamilton Creek, 

this is a large, low gradient stream. The entire length of this stream has 

been reconnoitered in early Spring as well as late summer. The stream 

is of sufficient width that the (intact) riparian canopy cannot 

effectively shade large portions of its length. The exceedance of 

temperature standards referred to in the DEIS page 3-97 is therefore 

assumed to be a normal response to ambient conditions for this stream. 

Recent data from three case-study watersheds on Prince of Wales 

Island indicate temperature limits are exceeded even in unmanaged 

watersheds under conditions of higher than normal air temperature. 

Recent correspondence with USGS personnel indicated the 20 C 

temperature standard is exceeded in most years on approximately half 

of non-glacial streams in southeast Alaska for which water 

temperature records have been collected (Solin pers. comm., 2009) 

Additional information regarding preliminary results from the USFS 

study have been added to the planning record. 

EPA-8

Develop monitoring plans that include instream measures of water 

quality. 

Response: 

The Forest Plan Monitoring and Evaluation Plan emphasizes 

monitoring to ensure BMPs are implemented as planned. Monitoring, 

24 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
including instream measures of water quality and aquatic habitat 

occurs at the Forest scale and is reported in the annual Forest Plan 

Monitoring and Evaluation Reports. The Forest Service’s 

implementation and monitoring of BMPs satisfies the requirements of 

the Alaska Non-point Source Pollution Control Strategy and is 

approved by the U.S. EPA, thereby ensuring that USFS activities are 

consistent with the Clean Water Act. The 2007 Tongass National 

Forest Monitoring and Evaluation Report (USDA Forest Service, 

2007) indicates that soil and water BMPs were implemented and 

monitored 218 times, with two departures from full implementation 

noted and corrected through mitigation. A study is currently underway 

and is in the calibration period in which continuous water quality 

monitoring instruments were installed in three case-study watersheds 

to determine if BMPs are effective in meeting water quality standards. 

Provisional results from this study are available and will be added to 

the planning file (Thompson and Tucker, 2007). 

State HC-14, SCS VIII-3

Commenter is concerned that field crews are not capturing the 

upper extent of fish habitat. Please provide a summary of field 

methods used to determine fish presence and habitat extent. 

Response: 

Employees are trained to determine stream class by using both fish 

presence and stream channel characteristics. Relative changes in 

stream gradient, flow, pool quality and frequency and barriers to 

upstream movement are used to determine extent of fish habitat 

upstream of the last fish detection. A more detailed explanation of 

field methods can be found in the Aquatics resource report under 

“Watershed characterization and field data collection” in the planning 

record. Petersburg Ranger District began additional quality control 

measures in 2008 which included revisiting approximately 30% of the 

proposed units assessed by seasonal technicians during the summer. 

The work continued into late November. We welcome ADF&G 

participation in determining the extent of fish habitat either in the 

initial data gathering phase or as part of our quality control effort in 

the late summer/fall. 

SCS VIII-5

Commenter is concerned about the impacts of increased road 

building, access and timber harvest on the fall/winter runs of 

Steelhead in the Castle and Hamilton watersheds. ADF&G 

considers these runs to be unique features to these watersheds that 

require extra protection. 

Response: 

The Riparian, Soil and Water, and Timber Standards and Guidelines in 

Habitat 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 25 Appendix D
the Forest Plan (Appendix B) provide guidance regarding protection of 

fisheries habitat and project planning. Additional guidance is provided 

in the Aquatic Habitat Management Handbook (FSH 2090.21_30), and 

the application of appropriate BMPs related to timber harvest and road 

building. Annual Tongass monitoring reports have found a high level 

of compliance with BMPs (see responses to TU-4 and EPA-8 for more 

detail and links to reports). Concern for these populations is 

acknowledged and seems to be related to two primary factors based on 

stakeholder comments: proper identification of fish habitat during field 

reconnaissance and increased access to these populations via the road 

system. Regarding proper identification of habitat, see response to 

State HC-14 and SCS VIII-3 for a discussion of field methods. In 

response to concerns about fall use of streams by steelhead or other 

resident populations, we established a quality control effort to revisit a 

portion of the streams identified in the summer season to verify fish 

habitat calls and ensure proper BMP protection for fish streams (see 

State HC-14 response). ADF&G hunting and fishing regulations limit 

the taking of steelhead and coho populations and would be applicable 

in these locations. 

NOAA-1

NMFS stated that they concur with the USFS call that timber 

harvest may adversely affect EFH. 

Response: 

The NMFS concurrence with the Forest Service Essential Fish Habitat 

determination is noted. 

Climate Change 

 EPA-7, SCS X-2, SCS XI-2, SCS XI-3, SCS XI-4

Include the effects of climate change in the analysis for this EIS. 

Response: 

The effects of climate change on the natural resources of the Tongass 

are highly uncertain, especially over the long run, and likely to be 

small, especially over the next ten to 15 years. There is a risk that 

climate change may result in increased blowdown, increased tree 

mortality from insects and disease, increased fire frequency and 

severity, adverse effects on air quality, changes to vegetation, streams, 

fish and wildlife habitat, and subsistence and recreation uses of the 

National Forest. The 2008 Forest Plan FEIS contains considerable 

information on potential climate change effects on resources such as 

General 

26 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
yellow cedar (FEIS 3-19), hydrology (FEIS 3-50), fisheries (FEIS 3-

92), plants (FEIS 3-116), forest health (FEIS 3-125). The various 

resources analyses have been pulled together in the document "Climate 

Change Related Information from the 2008 Forest Plan ROD, Forest 

Plan and FEIS," incorporated here by reference. This document has 

been placed in the project record. Summary information will be added 

under climate change in the Central Kupreanof Final EIS in Chapter 3 

under "Other Resources: Climate Change”. 

BK-4, SCS XI-1

Commenter suggested that the Tongass be managed for/reserved 

for carbon sequestration. 

Response: 

The proposed action is consistent with current Forest Plan standards 

and guidelines for their respective Land Use Designations. The Forest 

Plan addresses carbon sequestration (p.3-17 to 3-20). 

Invasive Species 

EPA-5

Please include in the FEIS a discussion pertaining to noxious weed 

monitoring, and control in the project area. 

Response: 

An invasive plant risk assessment for the Central Kupreanof project 

was completed and included in the project record in compliance with 

FSM 2080 R!0 TNF Supplement 2000-2007-1 and Executive Order 

13112. This risk assessment clarifies the management concerns, 

objectives and mitigation measures proposed to address invasive plant 

species for the Central Kupreanof project. This assessment and 

discussion about invasive plant species is provided on pages 3-60 to 3-

65 of the DEIS. 

Carbon 

Sequestration 

General 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 27 Appendix D
Minerals 

DR-12

Please clarify if there are mining claims in LUDs 4350, 4360, and 

4380. 

Response: 

Currently, there are no valid mining claims located within the project 

area. The last known mineral exploration activity that occurred in the 

project area was core drilling operation near Taylor Creek in 2000 (see 

Special Uses, Lands and Minerals Resource Report in the project 

record.) VCU 435 is not within the project area boundary. 

NEPA Responses 

GP I-1

There is little evidence to support the claim that there has been 

consultation with State and Federal Agencies, and the Organized 

Village of Kake, during the planning process. 

Response: 

In Chapter 1 of the DEIS (pp. 13-15), there is a summary of public 

involvement and consultation activities conducted so far for this 

project. It includes two public mailings, open houses held in both 

Petersburg and Kake, and publication of the Notice of Intent. The 

section also summarizes the other federal and state agencies that have 

been consulted on this project and through release of the DEIS. 

Finally, consultation with federally recognized tribal governments and 

corporations has also been summarized including a visit with OVK in 

May of 2008. 

The Central Kupreanof project record also documents the particulars 

of the public involvement and consultation activities summarized 

above. It provides documentation that public mailings went to federal 

and state agencies as well as tribal governments and corporation as 

well as the team’s response to public comments. Consultation letters 

were sent to tribal governments and corporations as well. Forest 

Service archeologists met with OVK staff to discuss Central 

Kupreanof heritage resources. Wildlife biologists met with ADF&G 

wildlife biologist to discuss OGRs and the Central Kupreanof project. 

General 

General 

28 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
An interagency trip was proposed in 2006. The record provides copies 

of the letters sent out and documentation of agency contact. However, 

due to lack of response and interest, as well as scheduling conflicts, the 

trip was canceled with a standing invitation to those agencies to 

contact the team leader to schedule trips to the project area. No one 

contacted the team leader with interest in scheduling a trip. 

The interdisciplinary team continues to meet with state and federal 

agencies as well as consultation with tribal governments and 

corporations in response to DEIS comments and ANILCA subsistence 

concerns and hearings. 

GP III-1, GP III-2; SCS I-1, GP IV-1, GP IV-2, SCS II-1, SCS II-2, 

SCS II-3, SCS II-4 GP V-3, SCS VI-11, GP V-1

Explain why a larger range of alternatives were not considered in 

this document, as well as why such a large range of volume was 

included within the considered alternatives. 

Response: 

The interdisciplinary team was encouraged to create a range of 

alternatives that responded to the Significant Issues, and that had 

measurable differences between them based on the units of measures 

used by the Significant Issues; rather than relying, on changing volume 

amounts to create that range. However, as the alternatives responded to 

different Issues, volume was affected. History of alternative 

development shows this project in response to Issues did consider a 

range of volume from approximately 16.8 mmbf to 70 mmbf (while 

the position statement also looked at the larger woodpile of the project 

area). 

Chapter 1, “Other Issues and Concerns” explains how individual 

resources were considered in identifying Significant Issues and the 

rationale for eliminating them as driving an alternative. Chapter 2 

(pages 9-11) in the DEIS summarizes the alternatives considered but 

eliminated from detailed study. We realize it was not a complete 

summary and additional summary from the Central Kupreanof Issue 

Development and Alternative Review document located in the project 

record has been added in the FEIS. It outlines the range of alternatives 

developed and considered in finalizing the alternatives to bring 

forward for detailed study. 

Project history shows that multiple roadless alternatives, wildlife and 

deer habitat/subsistence driven alternatives, and timber economic 

alternatives were developed. These alternatives are documented in the 

project record. 

Other resources were considered for Significant Issues and to see if 

they would drive an alternative. This information is in the issue 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 29 Appendix D
development and alternative review document and has been added to 

the FEIS. Fisheries, hydrology, watersheds, recreation, wildlife, highgrading cedar, plants, micro-sale opportunities, socioeconomics and 

subsistence were all considered and eliminated from driving an 

alternative (see FEIS chapter 2). Additional information has been 

added to micro-sales and small sale concerns and is included below. 

By design, the developed alternatives also respond to concerns about 

other resources that ultimately did not drive an alternative, such as 

harvest in the Castle River watershed (Alternative 4 in the DEIS stays 

out of this watershed). Consideration for wildlife habitat was part of 

the design for the proposed action. 

The DEIS explains specifically how deer habitat/subsistence 

alternatives were considered and how ultimately, because the proposed 

action incorporated additional consideration of habitat and landscape 

connectivity (responded to concerns), deer habitat was eliminated from 

further consideration as a Significant Issue. The history section of the 

Issue Development and Alternative Review document (doc.# 403 in 

the project record) also records how the team dealt with deer habitat as 

an issue. It states: “An alternative was looked at that responded to deer 

habitat concerns but eliminated from further study because the project 

area occurs over a large area and the estimated effects were already 

considered low. Also, the Forest Plan addresses wildlife through the 

Conservation Strategy, standards and guidelines (such as the legacy 

standard), LUDs, the matrix, and OGRs. The Forest Plan predicts 

reduction in habitat and this project is line with those predictions. The 

Forest Plan predicts that less than 39% of the POG, on all land 

ownerships and in the biogeographic province, will be harvested after 

100 years of implementing the plan. Currently we are well below this 

prediction with only 28% of POG being harvested on all land 

ownerships. However, elements of design from this eliminated 

alternative were incorporated into the Proposed Action. Specifically, 

units were ranked for highest habitat value. Those with highest value 

were recommended for avoidance of harvest or partial retention. Also, 

in areas of concentrated past and proposed timber harvest, units were 

avoided or prescribed with partial retention” (p.8). 

An alternative designed to supply on small mills would not meet the 

need to provide an economics reliable supply of timber to a forest 

products industry which includes processing facilities and timber sale 

purchasers of varying size and capacity. Such an alternative would not 

meet the need to provide an adequate supply for the larger mills of 

Southeast Alaska industry. Each action alternative in the Central 

Kupreanof project includes many harvest units suitable for small 

timber sale offerings. 

The timber volume in any action alternatives could be separated 

administratively into timber sales of varying size and complexity. 

30 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Please see the “Opportunities for Small Sales” section in Chapter 3 (p. 

3-17). 

The Tongass micro-sale program is based on purchaser requests for 

timber rather than the Forest Service identifying and offering timber 

for sale. A micro-sale is a timber sale that may consist of dead or down 

timber or small amounts of green timber, which has been proposed by 

a prospective purchaser. Please see “Opportunities for Microsales” in 

chapter 3 (p.3-18). On page 1-3 of the DEIS, decisions to be made 

include a microsale program along specified existing NFS roads. This 

option has been analyzed in each of the resource sections and would 

support the needs of Kake. The Record of Decision will include 

whether or not to implement this program along the Kake road system. 

Finally, the proposed action through alternative development and 

response to public concerns underwent minor revision as documented 

in the Issue Development and Alternative Review document. NEPA 

allows for the modification of the proposed action throughout project 

development; no substantial changes were made and no changes to the 

purpose and need of the project or project area. The first public 

mailing (2006) indicated this project could propose a range of timber 

harvest levels of up to 80 mmbf. The estimated volume in the NOI was 

from a Summary and not the stated purpose and need in the Federal 

Register. The overall purpose and need has not changed nor has the 

area analyzed for the Central Kupreanof project changed since scoping 

began. The volume is an estimate that will continue to be refined as the 

analysis progresses. Volume is an important measure used to estimate 

activities needed and effects caused by those activities, and it us used 

consistently among all alternative throughout the analysis process, The 

precise volume to be sold is not calculated until after the decision is 

made, units are laid-out on the ground and more precise measurement 

are made, and the appraisal process is followed. This is the Forest 

Service timber sale preparation process found in the Forest Service 

Manual 2400 and Forest Service Handbook 2409.18. 

The proposed action does not represent a maximum or upper limit for 

harvest. One of the identified Significant Issues is timber supply and 

economics. In response to this Issue, Alternative 3 was developed. By 

increasing the available volume and hence the unit pool selection, 

Alternative 3 offers a greater flexibility to respond to changing 

markets and sale packaging. Alternative 3 may be offered as one sale 

package or several of varying size. Alternative 3 is within the scope of 

the purpose and need. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 31 Appendix D
SCS I-2

Commenter feels that the Purpose and Need of this document does 

not take into account the needs of small, local mills within 

Southeast Alaska. Specifically, the purpose and need is intended 

to provide “shelf” volume, and is designed only to accommodate 

large timber sales. 

Response: 

The DEIS states the purpose and need in Chapter 1 on page 2. The 

second bullet states one of the purposes of this project is “to seek to 

provide a timber supply sufficient to meet the annual market demand 

for Tongass timber and the market demand for the planning cycle.” 

Appendix A in the DEIS and FEIS explains how the Forest Service 

develops forecasts about future timber market demand, market demand 

for the planning cycle (Appendix A pages 7-10) and annual market 

demand (Appendix A pages 10-12). This project contributes to the 

short-term and long-term goals for the Tongass timber sale programs. 

It also considers both local needs as well as regional (Southeast) needs 

in the opportunity to design both small sales and medium to larger 

sales from the action alternatives. 

SCS I-3, GP V-14

Unit cards do not provide adequate information. 

Response: 

The main purpose of the unit cards is to identify site-specific concerns 

with unique responses. These cards are used in implementation, as the 

selected alternative (if an action alternative) is “laid out” on the 

ground. It alerts implementation specialists of the unique design 

features of a unit. For example specifying stream/channel types and 

corresponding buffers, or that a nest is in the unit. Unit cards are not 

intended to summarize field notes. Information from field surveys is 

included in the project record and used during the analysis of each 

resource (wildlife, soils, streams, roads, plants, etc). 

SCS I-4

Commenter feels that an inadequate amount of information has 

been provided in the DEIS and Project Record. 

Response: 

40 CDFR 1502.15 directs “The environmental impact statement shall 

succinctly describe the environment of the area(s) to be affected or 

created by the alternatives under consideration. The descriptions shall 

be no longer than is necessary to understand the effects of the 

alternatives. Data and analyses in a statement shall be commensurate 

32 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
with the importance of the impact, with less important material 

summarized, consolidated, or simply referenced. Agencies shall avoid 

useless bulk in statements and shall concentrate effort and attention on 

important issues. Verbose descriptions of the affected environment are 

themselves no measure of the adequacy of an environmental impact 

statement.” 

The DEIS discloses the information used to make a reasoned choice 

between alternatives including the potential effects of each alternative 

in accordance with 40 CFR 1500-1508. Each analysis section defines 

the analysis boundary and rationale, analysis method, unit of measure, 

affected environment and environmental consequences (including 

direct, indirect and cumulative effects) of the proposed activities. 

Supporting information for the analysis and the rationale of methods 

(data, field notes, and references) are included in the project record. 

The FEIS will include the wildlife biological evaluation as an 

appendix. 

All analysis and supporting documents can be found in the project 

record. Tiering to the analysis done for the Forest Plan or referencing 

to the project record documents supports this analysis. Elements 

incorporated into the Central Kupreanof address 40 CFR 1500.4 (b) – 

Prepare analytic rather than encyclopedic EISs; 40 CFR 1500.4 (c) – 

discussing only briefly issues other than significant ones; 40 CFR 

1500.4 (f) – Emphasizing the portions that are useful to the decision 

maker and reducing background material; 40 CFR 1500.4 (g) – 

deemphasize insignificant issues; 40 CFR 1502.2(b) – Impacts shall be 

discussed in proportion to their significance, brief discussions of other 

than significant issues. The “Significant Issues” section of Chapter 1 

(DEIS p. 15-17) identifies the decision maker’s significant issues. 

The project record is available in electronic format with a hyperlinked 

index to the actual documents. The project record follows a schema, 

dividing information by category (project management, public 

involvement, etc) and resource. Each category/resource section is 

further divided out into reports, correspondence, references and data. 

The index also provides a general description of each document as 

well as authors and dates for easy reference. 

BK-5

Commenter expressed the preference that the Forest Service 

choose the No Action Alternative for this project. 

Response: 

We have noted your preference for selection of the No Action 

alternative and have clarified language in Chapter 1 under the “No 

Timber Harvest” consideration. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 33 Appendix D
Inventoried Roadless Areas 

SCS IV-2

Fish and wildlife values should be reviewed as part of the roadless 

analysis. 

Response: 

Approximately 81% of the project area is in roadless areas. Specific 

resource information about the project area and thus the roadless areas 

are in the specific resource section. For instance aquatic values are 

disclosed in Hydrology/Fisheries section. Wildlife values are analyzed 

in the wildlife section. The DEIS references these sections on page 3-

23. Because of the high percentage of roadless area in the project area, 

it was decided not to duplicate this information. 

Cutting units were not used as a level of analysis. Resources and 

values were analyzed at scales appropriate to each resource and 

defined in each resource section. 

The Roadless analysis highlights special features of the roadless areas 

according to the 2003 Tongass Land Management Plan Revision SEIS 

(Central Kupreanof DEIS p. 3-25 to 3-27) and which were reviewed 

for this project. It includes analysis of whether the unique attributes 

would be affected by the proposed activities as well as potential 

changes to the biological value of old-growth forest and scenic 

conditions (p.3-28 to 3-33). No alternative would alter any special 

feature or attraction of any roadless area within the project area. 

SCS IV-3, GP XIV-1

Concerns were expressed whether it was legal to build roads and 

harvest in Inventoried Roadless Areas under the temporary 

exemption from the 2001 Roadless Rule. Due to the legal conflicts 

associated with the Roadless Rule the commenter feels that no 

entries should occur until the Rule is finalized. 

Response: 

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

framework guiding roadless. 

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

authority over construction and reconstruction of roads and the cutting, 

sale or removal of timber in Inventoried Roadless Areas. 

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

careful consideration of activities in Inventoried Roadless Areas while 

General 

34 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
long term roadless policy is developed. The effects on the Roadless 

Areas are described in the Final EIS. 

SCS IV-1

The DEIS should analyze economic costs and benefits specific to 

the Roadless Area as timber harvested from Roadless Areas 

greatly increase logging costs. 

Response: 

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

roads need to be built adding to the costs of the timber sale. However, 

this is true whenever new roads are needed, even in roaded areas, and 

the development of infrastructure reduces costs for future timber sales. 

In Chapter 2 of the DEIS, Table 2-1 compares the effects of the 

Alternatives. Under Issue 1 for Timber Supply and Sale Economics, it 

shows that the alternative with the most proposed road miles has the 

lowest indicated bid value economics associated with it. It contrasts 

against Alternative 4 which minimized new road construction and 

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

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

compared to the economics for each alternative. 

WS-4, WS-5

Explain how VCUs were rated and then subsequently included in 

the various Phases for the Tongass Timber Sale Program Adaptive 

Management Strategy. 

Response: 

Commenter noted that VCU 4360 Upper Castle River had no acreage 

as shown in Planning Record #1637 (VCU Attributes + Summary 

Development of Phases), allocated to Phase 1 document and believes 

was erroneously allocated to Phase 1. It should be noted that this 

spreadsheet was just a tool to help allocated various VCU’s to the 

different Phases. The published Map with the Record of Decision for 

the 2008 Forest Plan Amendment is the final word on whether an area 

is within each Phase. Subsequent analysis was conducted on the 

coverage developed and used for the map. Values for that analysis to 

determine such things as ASQ were developed from that coverage not 

the spreadsheet the commenter references. Tweaking of VCU’s was 

done after the spreadsheet was originally developed and may or may 

not have been updated in the matrix. The Forest was aware of 

rankings and in the case of VCU 4360, it should be noted that this 

VCU was split in the Map for the Record of Decision base on yarding 

capabilities. See also figure 1. Timber Sale Program Adaptive 

Management Strategy page 65 of the Record of Decision. Even within 

Phase 1 there are Moderate Value Roadless areas that are included. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 35 Appendix D
 

Silviculture 

SCS X-1

Address “high-grading” of cedar within the Project Area. 

Response: 

All alternatives are consistent with current Forest Plan standards and 

guidelines for their respective Land Use Designations. Currently there 

is no direction to modify harvest activities based on Alaska yellowcedar decline. Previously harvested units in the area have Alaska 

yellow-cedar regeneration in them and it is favored during 

precommercial thinning operations to further increase it viability. 

Alaska yellow-cedar comprises 18 percent of the volume of all the 

stands surveyed in the project area, 15 percent of the volume proposed 

for harvest in Alternative 2 is Alaska yellow-cedar, 14 percent of the 

volume proposed for harvest in Alternative 3 is Alaska yellow-cedar, 

and 13 percent of the volume proposed for harvest in Alternative 4 is 

Alaska yellow-cedar. 

SCS III-2

Explain how harvest in the project area will effect cedar 

composition and may aid in yellow-cedar decline. 

Response: 

The Central Kupreanof Timber Harvest project area encompasses 

152,517 acres and of these acres 143,329 acres are forested. Of the 

forested acres 4,233 are in existing young growth and the project area 

has been determined to contain 31,622 acres that are currently suitable 

and available for timber harvest. Alaska yellow-cedar and Western 

redcedar occurs in the areas suitable and available for timber harvest 

and also occurs on both unsuitable and non-productive forested lands, 

lands where large commercial timber sales cannot be planned. Alaska 

yellow-cedar regeneration is being found in newly regenerated units 

within the project area and is favored during precommercial thinning 

operations to increase the amount of cedar within a stand. 

A sufficient amount of cedar volume currently exists along the road 

system and could be made available through a small sale or a 

microsale. Additional opportunities to make cedar available for local 

small industry would be created through new road construction 

Alaska yellowcedar 

36 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
as these new roads would access stands having cedar that are not 

proposed for harvest with this project. 

All alternatives are consistent with current Forest Plan standards and 

guidelines for their respective Land Use Designations. Currently there 

is no direction to modify harvest activities based on Alaska Yellowcedar decline which is naturally occurring on approximately 22,000 

acres (Forest Health Protection Report 2008) of the project area. 

Table 3-4 of the DEIS displays the amount of timber volume harvested 

by species by alternative. Stand Examinations show that 68 percent of 

the volume for the project unit pool is Western hemlock, 14 percent is 

Sitka spruce, 18 percent is Alaska Yellow-cedar, and less than .1 

percent is Western redcedar. Details are available for individual units 

and are currently stored in the Natural Resource Information System.

Also, please see SCS II-5 in the Timber Economics section under Small 

Sales and Microsales in this appendix. 

SCS X-2

Address the cumulative effects of climate change in relation to 

timber harvest. 

Response: 

The current research indicates that there is a cascade of factors 

responsible for Alaska Yellow-cedar decline. Soil drainage is the most 

important factor to consider. The association of Alaska yellow-cedar 

decline with set soils has been well documented. Alaska yellow-cedar 

trees growing on poorly drained soils have shallow root systems that 

are predisposed to freezing. Poor soil drainage forces the majority of 

fine roots of these trees to be shallow (Hennon et al 2007). Open 

canopy conditions increase exposure but do not alone result in Alaska 

yellow-cedar decline. The decline does not appear to occur on better 

drained sites nor does it seem to appear in younger healthy trees, even 

on wet soils. 

The majority of areas proposed for harvest are better drained sites 

where Alaska yellow-cedar decline is not as likely to occur. Within a 

few years following harvest activities, tree regeneration will occupy 

the openings created. This cover will provide an insulating effect not 

found within the open canopied old-growth cedar stands where decline 

is prominent. For these reasons, the openings created by harvest 

would not predispose residual Alaska yellow-cedar to decline. 

 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 37 Appendix D
SCS X-3

Address the harvest of redcedar within the project area as well as 

the effect of harvesting redcedar in the northern end of its range. 

Response: 

Minor amounts of western redcedar are scattered across the project 

area and some incidental trees will be harvested along with the rest of 

the stand. Some of the previously harvested units in the area have 

western redcedar in the regeneration and it is favored during 

precommercial thinning operations to further increase its viability. 

The North Hamilton River Redcedar Area, approximately 80 acres in 

size is within the project area boundary in the northwestern section and 

is not part of the volume being considered for harvest. This area is 

identified as being unique because of the high proportion of redcedar it 

contains and the young growth stand adjacent to this area also has a 

high proportion of redcedar. Also see response to SCS X-2 under 

Alaska yellow-cedar for information on areas unavailable for timber 

harvest within the project area. 

SCS X-4

Provide the rationale for even-aged management prescriptions 

within the project area. 

Response: 

In the 2008 Tongass land and Resource Management Plan under the 

Standards and Guidelines for Timber pp. 4-71 through 4-72, it is stated 

under I. Regeneration Methods that: 

A. Regeneration methods refer to the manner in which a new 

stand is created. There are three categories of regeneration 

systems: even-aged, two-aged, and uneven-aged silvicultural 

systems. Even-aged systems include clearcutting, seed tree, and 

shelterwood. Two0aged systems include clearcutting with 

reserves, seed tree with reserves, and shelterwood with reserves. 

Uneven-aged systems include single-tree selection, group 

selection, and group selection with reserves. 

I. Consider silvicultural systems other than clearcutting to meet 

other resource objectives at the project level. As part of the 

project NEPA process, analyze current scientific information 

related to the applicability of alternative timber harvest methods. 

II. Even-Aged Systems 

A. Apply even-aged silvicultural methods in such a way that 

isolated stands of timber will not be created. Avoid locating 

harvest units where future harvest activities will destroy 

Redcedar 

Clearcutting

38 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
regeneration under earlier regeneration harvest activities. 

B. Clearcutting is an even-aged regeneration method. There are a 

number of supportive reasons for the use of this method in 

Alaska’s western hemlock-Sitka spruce forests. These include 

excellent regeneration of desired species, effective dwarf 

mistletoe control, viable harvest economics, and compatibility 

with standard logging systems. 

Forest Service Manual (FSM) 2470-R-10-2400-2005-1 further clarifies 

limitations on clearcutting and states it may be used to minimize the 

occurrence of diseases (dwarf mistletoe), windthrow, logging damage, 

and to provide for the establishment and growth of desired trees. As 

stated in the DEIS, (p.3-29) clearcutting is used so that residual trees 

are not damaged by conventional logging systems. Even-aged 

management has not been prescribed where it conflicts with other 

resources. 

EPA-10

Utilize methods other than even-aged management when possible, 

and especially within scenic viewsheds and sensitive watersheds. 

Response: 

All the proposed units meet or exceed the Forest Plan standards and 

guidelines with the prescribed silvicultural systems and are consistent 

their respective Land Use Designations (LUD). See also Scenery 

section in Chapter 3. 

State W-1

Address the concern pertaining to the lack of additional protection 

measures along the edges of units and stream buffers to provide 

protection from windthrow. 

Response: 

As stated in the document field surveys found very little evidence of 

windthrow along existing unit boundaries and stream buffers. Surveys 

in proposed units also found only minor amounts of windthrow. The 

project area is predominately located inland and has low topographic 

relief, which are both factors in lessening the effects of wind on leave 

trees. As a result of these surveys and the contributing risk factors the 

risk of windthrow in the study area is considered low and additional 

windthrow protection measures are not recommended. Stands located 

to the south of the project area along the southern coast of Kupreanof 

Island would have a higher wind risk rating as stated in the Kupreanof 

Island Analysis. The Threemile Timber Sale FEIS that you refer to is 

on a separate island, along the coast, with greater topographic relief, 

and does show signs of windthrow along older unit boundaries and 

Windthrow 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 39 Appendix D
would also have a higher risk of windthrow along stand boundaries 

and stream buffers. 

WS-2

Commenter questions the suitability of lands within the Project 

Area for timber management activities. 

Response: 

Timber Suitability Analysis was an issue brought up by the Wilderness 

Society during their appeal of the 2008 Forest Plan Amendment. 

Original issue was that the Tongass revised Forest Plan (Plan 

Amendment) failed to adequately conduct the analysis of timber 

suitability in violation of the NFMA. Appendix A of the Forest Plan 

describes the process followed to identify the lands on the Tongass NF 

that are suitable for timber production. Land classification for the 

project area is discussed in the Timber and Vegetation section of 

Chapter 3 of this FEIS. 

SCS X-5

Address the concern that old-growth is being “high-graded.” 

Response: 

The Forest Plan discusses large tree productive old-growth in the 

Biodiversity section beginning on page 3-127 (Forest Plan FEIS). 

Particularly it discusses the existing condition of the Kupreanof/Mitkof 

Island biogeographic province on pages 3-159 to 3-160. Currently 

65% of the original large tree POG remains (see also Table 3.9-7). 

With full implementation of Alternative 6, the Plan predicts that 51% 

of large tree POG will remain with 30% protected with old-growth 

reserves. Please also see discussion on coarse canopy (which equates 

to large tree old-growth) in the wildlife responses. Refer to 3-149 in 

this FEIS for a discussion on single tree selection. 

Unit Suggestions 

AFA-8

Drop units 222, 223, 224, 267, 268, 269, 274, 275, 276, 277, 279, 280 

and 281. 

Response: 

The Forest Service has the opportunity to include, or not include, units 

Phase 

One/Suitability 

Large Tree/OldGrowth 

Highgrading 

General 

40 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
that have been cleared through the NEPA process during sale 

preparation and packaging. If these units are cleared, and at the time 

of sale preparation market conditions do not allow for a positive sale 

that includes these units, the Forest Service has the flexibility at that 

time to defer these units. Part of our purpose with this project is 

seeking to provide a timber supply sufficient to meet the annual 

market demand for Tongass National Forest timber and the market 

demand for the planning cycle. One way to do this is to have a large 

unit pool to allow us flexibility when offering sales. Some of the units 

will have higher economic value than others but will remain in the 

pool to maximize our ability to offer sales in differing economic 

climates. 

At this stage of the project it would be difficult and cost prohibitive to 

add new units to the project. In the future we would be interested in 

hearing your ideas earlier in the planning process during scoping. We 

are currently doing this with the State of Alaska DNR on future 

projects. Thank you for your interest. 

AFA-9

Enlarge units 241, 243, 246, 248, 265, 270 and 272. 

Response: 

Although areas adjacent to units 241, 243, 246, 248 and 270 are 

forested, the timber outside of the planned units is of relatively low 

volume per acre and low economic value. Minor adjustments will be 

made to the unit boundaries at the time of implementation if 

determined to be appropriate. 

AFA-10

Drop helicopter portion and expand cable logging portion of units 

261, 262, and 266. 

Response: 

On-site soil stability investigations determined these portions of units 

261 and 262 require helicopter yarding due to soils, steepness and 

terrain. Unit 262 has no planned road access to allow for cable 

yarding. Unit 266 has no areas designated for helicopter yarding. 

AFA-11

Place a unit between unit 274 and 275. 

Response: 

Because of recently harvested managed stand exists between units 274 

and 275 adding an additional unit in this location would exceed 

opening size limitations set by the National Forest Management Act 

(NFMA) regulations and Forest Plan (4-72) standards.

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 41 Appendix D
Socioeconomics 

Beebe-3, SCS III-7

The DEIS needs to analyze further the impacts of this project to 

tourism and recreation. 

Response: 

The Forest Plan analyzed recreation and tourism economics at the 

regional level since it is often difficult to pinpoint at the project level. 

For example, it would be a guess at best estimating how much of the 

gasoline sold in Kake is used for recreating in the project area, since 

there are other NFS lands and non-NFS lands on the Kake road 

system. 

The Central Kupreanof project proposes 3 acres of harvest in the 

Rocky Pass Inventoried Roadless Area which is in the vicinity of 

Rocky Pass and Big John Bay. Less than 1% (0.05%) of the roadless 

area would be affected. No timber harvest is allowed in the immediate 

vicinity of Big John Bay and Rocky Pass because they are in nondevelopment LUDs of Semi-remote Recreation and Remote 

Recreation. No effects would be apparent in the foreground of these 

areas and the middleground and background effects described in the 

Scenery section of the DEIS are within the standards and guidelines 

allowed in the Forest Plan. 

No outfitters and guides currently use the project area so there are no 

direct economic effects to them. Some timber harvest would be 

noticeable from a distance from recreation areas like Rocky Pass as 

described in the Scenery section. 

SCS III-5

Commenter is requesting a more detailed social and economic 

analysis for this project. 

Response: 

The Forest Service Manual [FSM 1970.6] states, in part, that “the 

responsible line officer determines the scope, appropriate level, and 

complexity of economic and social analysis needed.” The Central 

Kupreanof project is a timber sale project, and was proposed to 

respond to the goals and objectives identified by the Forest Plan for the 

timber resource and to help move the project area toward the desired 

condition identified in the Forest Plan for the lands within the Timber 

Production and Modified Landscape LUDs. 

General 

42 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
The Forest Service is not required to quantify the non-market benefits 

and costs associated with every timber sale. However, the Forest 

service is required to “ensure that unquantified environmental 

amenities and values [are] given appropriate consideration in decisionmaking along with economic and technical considerations” [42 USC 

4332(2)(B)]. The Central Kupreanof Timber Sale EIS discusses the 

potential effects of the project on the non-market values, such as 

subsistence, wildlife, recreation, fisheries, water quality, soils, and 

wetlands as well as the impacts to the inventoried roadless areas. The 

analysis of the project’s potential effects on these non-market values is 

reasonable and consistent with Forest Service Manual and Handbook 

guidance regarding social and economic analyses. 

SCS III-6

Acknowledge the economic effects of this project on other 

economic sectors, not just on the timber economy. 

Response: 

The fact that such benefits and activities as commercial fishing, 

tourism, mining, recreation, and subsistence are not assigned monetary 

values and quantified in the economic efficiency analysis does not 

lessen their importance in the overall decision-making process. 

Decision makers routinely choose alternatives that do not maximize 

present net value. The Forest Service Manual states that decision 

makers must “(c)onsider economic efficiency, along with other factors 

(emphasis added), in making decisions and in implementing and 

reviewing projects, programs, and budgets” (FSM 1970.3(3)). 

A large portion of the EIS is spent evaluating potential effects that 

cannot be reasonably assigned a monetary value at this time. The type 

of benefits identified on this subject may be generally classified as 

ecosystem services. Ecosystem services are those services and 

benefits provided by healthy ecosystems. Definitions of ecosystem 

services can be broad and include both use and non-use values. A 

number of different definitions have been identified, including a 

typology developed by the Millennium Ecosystem Assessment (2005), 

which is featured on the Forest Service’s Ecosystem Services website. 

The Assessment identifies four general categories of ecosystem 

services: provisioning, regulating, cultural, and supporting. Interest in 

ecosystem services has increased in recent years, and economists have 

made useful progress in developing and improving methods and 

techniques that can be used to value non-market ecosystem services. 

Recognizing the potential utility of the ecosystem services concept, the 

Forest Service recently proposed that ecosystem services be used as a 

framework for describing and evaluating the many benefits associated 

with NFS lands and established an Ecosystem Services web site 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 43 Appendix D
(http://www.fs.fed.us/ecosystemservices/) that provides detailed 

information and resources, identifies And discusses Forest service 

efforts in this area, and issues a regular Ecosystem Services newsletter. 

In addition, the Forest Service’s Pacific Northwest Research Station 

(PNW) recently issued a technical report that attempts to define an 

economics research program to describe ecosystem services (Kline 

2006). Kline (2006, pg. 7) identifies several key challenges or steps 

that re involved in applying the ecosystem services concept. These 

include defining a typology of ecosystem services or, in other words, 

defining what to measure and how to measure it. An important aspect 

of this measure involves, in Kline’s (2006, pg. 10) words: “translating 

ecosystem complexity into manageable sets of well-defined ecosystem 

metrics.” The next challenge is to determine how these metrics are 

affected by specific Forest policy and management actions and then 

identifying these effects in terms of measurable units or outputs that 

can be assigned monetary values in a way that will allow meaningful 

comparison between alternatives. The third challenge is to measure 

the value of these units or outputs in monetary terms that accurately 

reflect the societal values of these services. 

As Kline (2006, pg. 15) notes, “total ecosystem values provide little 

guidance to policy or management decisions unless these decisions can 

be expressed as marginal or incremental changes in ecosystem 

services.” Evaluating the impacts of the alternatives on, for example 

deer, would require estimating the actual number (or at least a 

reasonable range) of deer that would be affected, negatively or 

positively, by the alternatives. This type of analysis would also be 

required for salmon, marine mammals, moose, berries, and so on. The 

ecological impact assessments presented in this EIS follow standard 

scientific approaches to these types of analysis and typically assess 

impacts in terms of probability and risk, not in numbers of affected 

deer or salmon, etc. The difficulties associated with identifying 

production relationships and the corresponding units of measurements 

is, as noted earlier, generally considered one of the main challenges 

currently facing ecosystem services analysis. Kline (2006, pg. 11) 

notes that, in general, “ecologists have not been forthcoming with the 

types of ecosystem output measures economists typically desire or 

expect for formal economic analysis” and because “ecology is not 

particularly well suited to prediction, production relationships may be 

highly or purely uncertain.” 

44 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Soils 

 

Beebe-4

Commenter is concerned about the ecological implications of 

removing precommercial thinning debris from units. 

Response: 

Where vegetation management is proposed on the Central Kupreanof 

project area the soils are relatively rich in organic matter and carbon. 

Soils at risk of losing productivity through biomass removal are those 

that have not accumulated very much organic matter. On the Tongass 

these soils include the young soils (entisols and inceptisols in recently 

deglaciated areas like the Yakutat Forelands and near the glaciers of 

the Juneau Icefields). 

NOAA-5, EPA-9

Address the effects of management activities in areas with a mass 

movement index of high hazard. 

Response: 

All slopes within the project area that exceed 72% have been 

investigated in the field as directed in the Forest Plan. Slopes that 

were determined to be unstable were mitigated by either removal from 

the unit or the logging systems were modified to minimize soil 

disturbance to an acceptable level. 

Timber Economics, Demand 

and Financial Efficiency 

AFA-1

Alternative 4 needs to be reworked to become a viable timber 

sale, and the helicopter portion of Alternative 3 should be dropped 

as there is too little volume to justify mobilizing operations. 

Response: 

The Forest service has the opportunity to include or not include units 

General 

Supply and 

Demand 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 45 Appendix D
that have been cleared through the NEPA process during sale 

preparation and packaging. If these units are cleared, and at the time 

of sale preparation market conditions do not allow for a positive sale 

that includes these units, the Forest Service has the flexibility to defer 

these units. 

AFA-3

Commenter believes that the discussion of forest products 

employments does not adequately describe the “massive decline” 

in industry employment. 

Response: 

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

of the DEIS is intended to provide an overview of recent trends. It is 

not intended to illustrate the full extent of the reduction in wood 

products employment that has occurred since it peaked in 1990. The 

Purpose and Need for the Central Kupreanof EIS tier to the Tongass 

Land and Resource Management Plan FEIS (January 2008) which 

provides a more detailed discussion of the wood products industry 

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

AFA-4

Address the statements made in Appendix A-15 concerning Pool 3 

volume under contract. Commenter feels that the goals presented 

in this section are too low and will not achieve the goal of 

establishing a viable timber economy. 

Response: 

This is project-level analysis and just one part of the total Tongass 

timber program; the timber economic and supply issue tiers to the 

Forest Plan analysis. The “pools of timber” or pipeline volume 

described on page A-13 of the DEIS is intended to help achieve an 

even flow of timber sale offerings to meet market demand. The goal 

for volume under contract is based on derived annual demand which is 

used to set short-term goals as described on A-9. More detailed 

information regarding timber sale planning and market demand is in 

the Forest Plan Amendment FEIS and ROD, and in Brackley and 

Haynes (2008). 

Please refer to the response to comment AFA-5 in this section for more 

information regarding the need for an integrated forest products 

industry. 

46 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
AFA-5

Address the goal, as stated by the Secretary of Agriculture, of 

restoring a fully integrated manufacturing industry on the 

Tongass. 

Response: 

This was not included in Appendix A but was addressed in the Forest 

Plan Record of Decision (p. 17) which states- "Need for an Integrated 

Forest Products Industry in Southeast Alaska. Beyond the question of 

what the market demand for timber is likely to be over the next 10 to 

15 years, I also considered what supply would be needed to provide an 

opportunity to reestablish an integrated forest products industry in 

Southeast Alaska. ... [Therefore] I selected Alternative 6, which has an 

ASQ substantially above recent harvest levels, in part to provide such 

opportunities—and to ensure they are not foreclosed." 

As for your comments about the Secretary of Agriculture, this is a 

reference to a September 2008 memorandum to the Chief of the Forest 

Service from the Under Secretary, Natural Resources and 

Environment, which provided guidance concerning implementation of 

the Forest Plan. 

Direction: The Under Secretary’s direction on this topic reads as 

follows: 

I am also directing the Forest to develop a work plan and 

proposed budget necessary to offer four ten-year timber sales, 

each with an average volume of 15-20 MMBF per year. These 

longer sales, each are the best way to provide sufficient 

assurances to support the necessary investment in new and 

upgraded manufacturing facilities. 

Response to the Direction: A work plan and proposed budget 

necessary to offer four ten-year timber sales, each with an average 

volume of 15-20 million board feet (MMBF) per year is planned. Four 

sales are located on the Forest and have been identified. The Forest 

has contacted the Tongass Futures Roundtable and the State of Alaska, 

and invited both parties to participate in this effort. The Tongass will 

work directly with the Framework Committee of the Roundtable and 

directly with the State’s Division of Forestry to determine where these 

projects would most appropriately serve their intended purpose. Under 

the MOU with the State and with the TNC (part of Roundtalbe), they 

have been actively involved in developing Project Plans. 

 In a reply to that memorandum sent in January 2009, the Regional 

Forester informed the Chief that to respond to Part 4 of the Under 

Secretary's guidance, titled: A Fully Integrated Forest Products 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 47 Appendix D
Industry (Ten-Year Contracts), the following has been accomplished: 

Locations were identified where each of the four ten-year timber sales 

could be developed, preparation of position statements for the two 

highest-priority ten-year sales has begun, and the development of a 

proposed budget for work related to the ten-year sales has been started. 

These locations are: Wrangell Island; the Thorne Bay to Control Lake 

area on Prince of Wales Island; Northwest Revilla Island, and 

Zarembo Island. 

. 

DR-13 

Clarify whether the current timber demand is above or below the 

levels of 5 and 10 years ago. 

Response: 

Forest Plan Amendment FEIS Volume 1, pp. 3-504 - 3-510 discusses 

market demand for Tongass timber. As displayed on page 3-506 of the 

Forest Plan Amendment, existing market demand is higher than 5 and 

10 years ago but currently lower than 15 years ago. 

AFA-7

Commenter believes that the Forest Service is severely 

underestimating the demand for timber on the Tongass, and 

questions the methods the Forest Service uses to come to these 

conclusions. 

Response: 

Please see the 2008 Tongass Land and Resource Management Plan 

Record of Decision, page 30, which discusses “Morse methodology”. 

This methodology is the means by which the Forest Service seeks to 

meet demand. The Morse methodology’s establishes a system that 

seeks to build and maintain sufficient volume of timber under contract. 

BK-1, BK-3, GPII-1, SCSX-6, WS-1

The purpose of the Central Kupreanof project, as disclosed by the 

district ranger in a radio story but not in the DEIS, is to put 

timber "on the shelf," not to meet a real need in the foreseeable 

future. There is no immediate demand for this sale and it is in 

conflict with the Tongass Timber Reform Act (TTRA). There 

needs to be an updated and accurate timber demand analysis. 

Response:

The Tongass Timber Reform Act (TTRA), Section 101 is briefly 

discussed in the Central Kupreanof Appendix A. This Act provides 

direction to seek to provide a supply of timber both to meet the annual 

market demand and to meet the annual market demand for each 

planning cycle. The planning cycle market demand is a forecast of the 

48 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
long-term demand for timber from the Tongass derived from trends in 

international demand for end products manufactured from such timber. 

Based on these long-term projections, the Forest Service also estimates 

annual market demand in order to determine how much timber volume 

needs to be analyzed through the NEPA process to enable the outyear 

offerings. In order to do the necessary fieldwork and analysis to 

meet the requirements of NEPA, these projects need to begin years in 

advance before the sale is proposed to be offered. Otherwise, a 

situation like current one develops. Currently, very few options for 

timber sales to offer occur on the Tongass. Many of the previous 

decisions were withdrawn with the Settlement Agreement (need ##) 

that involved the Forest Plan Amendment. This has limited the sale 

volume available to certain areas of the Tongass which may not be the 

most economical to offer at this time. 

Also, looking at only supplying the current need eliminates the 

possibility of any future expansion for the timber industry. If the 

timber industry is to reach the goal of a fully integrated industry, then 

a steady, reliable supply of timber volume needs to exist. Interest has 

been expressed in the future young-growth timber harvest. However, 

in order to do this requires a steady supply of timber to allow operators 

to make the investment of equipment and to keep trained employees 

gainfully employed until enough young-growth reaches true economic 

value. Interest has been expressed for additional factors of the wood 

products industry to supply fuel for heating community buildings and 

homes. This sector of the industry also needs to be able to rely on a 

steady workforce with knowledge of Southeast Alaska conditions. 

The community of Kake has been recently suffered economic setbacks as various economic sectors are no longer present. Central 

Kupreanof Timber Harvest project will provide opportunities for small 

sales and microsales but will give the flexibility for a larger timber sale 

and provides possible stewardship opportunities for the community of 

Kake. If there is truly not a need for a larger sale and only smaller 

sales are sold, then the environmental effects will be less than 

indicated in the EIS but no negative environmental effect is caused by 

proposing larger sales. 

Brackley and Haynes (2008) state that several short and long-term 

changes point to an increase in demand for wood products from all 

sources, including Alaska. An example of a short term change is where 

softwood lumber production in Canada has slowed. Examples of long 

term changes is the interest in renewable energy applications, a 

projected steady increase in US population, and concurrent increasing 

demand for softwood products. They state that the probability of a 

future decrease in demand for lumber from all Pacific Rim markets is 

virtually zero. In fact, they argue that projected consumption in 

domestic markets alone will increase substantially. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 49 Appendix D
This project tiers to information regarding timber sale planning and 

market demand in the Tongass Land and Resource Management Plan 

FEIS (January 2008), pages 3-504 through 3-511, Tables 3.22-6, 3.22-

7, 3.22-8, and in Brackley and Haynes (2008). 

Please refer to responses for DR-13 and AFA- 7 in this section. 

State EC-1, GPII-1, SCS III-4 

Commenter does not agree with using the Wrangell mill as an 

appraisal point. 

Response: 

An appraisal point is the most advantageous location where raw 

materials or products can be sold (FSH 2409.18, 45.11). The 

Wrangell mill was used as the appraisal point for the Central 

Kupreanof EIS since the annual market demand for 2007, 2008 and 

2009 included the Wrangell sawmill. Silver Bay Logging, Inc., owner 

of the sawmill, was logging and processing logs at the mill in those 

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

2009. Instead they purchased sales from State of Alaska Mental 

Health Land that was extremely close to the mill. However, the mill 

capacity still remains at 65,000 MBF and could successfully mill a sale 

the size of the Central Kupreanof alternatives. In order to compare 

alternatives, the sale is considered as one sale although the volume 

may be sold in either one sale or multiple sales. The appraisal done 

prior to offering the sale for bid may be to the Wrangell mill or another 

mill depending on the size of the sale and whether the mill in Wrangell 

is operating. Since one of the values of the financial efficiency 

analysis is the relative ranking of alternatives, if another appraisal 

point is chosen, such as Klawock or Ketchikan, then all alternatives 

would decrease in value based on barging costs per MBF and show the 

same relative ranking. 

Although there are several sales available in the vicinity of the 

Wrangell mill, they do not currently represent the amount of timber 

volume necessary for a purchaser to make the investment in equipment 

and to obtain financial backing. Alcan is logging on Skipping Cow 

and began after the roads finished construction this season. 

Logging costs and road costs are updated with information collected 

annually from operating mills across the Tongass. This information is 

used to update the RV appraisal program and the NEAT-R program. 

Economics 

50 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
SCS III-1 

Commenter requested an accurate assessment of the number of 

jobs and the amount of revenue that the project will generate 

Response: 

Approval of export or interstate shipping is only granted after the sale 

is awarded. No timber volume is ‘pre-authorized’ for export or 

interstate shipping. If a purchaser wants to export timber overseas or 

ship out of Alaska; they are required to apply for a permit from the 

Regional Forester. Because of these uncertainties of what may be 

exported in the future what the operator would want to export, an 

accurate estimate of jobs in not available at this time. Therefore, the 

sawmilling jobs are displayed as a range of possibilities with the actual 

number of jobs supported probably somewhere within this range. 

However, the jobs per MBF used for this estimate is based on an 

average from operators and may vary depending on who buys the 

sales. 

Timber sales are sold to purchasers with differing business goals under 

changing market scenarios. Historically, the percentage of the volume 

harvested on the Tongass that has been shipped out of state has 

fluctuated widely. Given those variables, it is not possible to precisely 

predict what will be manufactured locally; hence, a range of 

employment and income figures is considered the most reasonable 

approach to display potential effects on jobs and income. 

The limited interstate shipment policy described in the Draft EIS (P. 3-

19) allows shipment of small-diameter, low-grade, unprocessed 

western hemlock and Sitka spruce logs to the lower 48 states (Bschor 

2007) and no more than 50 percent of the total sale volume can either 

be exported or shipped to the lower 48 states. These requests must be 

approved by the Regional Forester and have been granted in the past 

on a case-by-case basis. 

On August 8, 2008, the Regional Forester issued a time-limited 

authorization to export western hemlock and Sitka spruce which only 

applied to timber sales under contract as of June 30, 2008 and was not 

an addendum to the limited export policy. No more than 50 percent of 

the total sale volume may be exported or shipped to the lower 48 

states. This authorization was put in place to offset the dramatic 

increase in costs, coupled with a decline in orders and selling values 

experienced by Alaska’s timber industry at that time. It is difficult to 

determine whether these conditions will exist when timber from the 

Central Kupreanof project is offered for sale. This project may be 

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

costs, market scenarios and logging costs are subject to considerable 

change. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 51 Appendix D
The economic analysis for the Central Kupreanof project does not 

include adjustments to selling values based on this time-limited 

authorization. 

The amount of export is reported on this public website: 

http://www.fs.fed.us/r10/ro/policy-reports/for_mgmt/

The actual appraised sale value will be determined at the time of sale 

based on a statistically accurate cruise and the appraisal bulletin costs 

and revenues at that time. Many of the factors that will determine the 

exact amount of revenue will be dependent on the purchaser’s 

efficiency and business expertise and therefore not available at this 

time. 

AFA-6, State EC-2

Explain why an economic sale is not possible based on the analysis 

of the Forest Plan LSTA. 

Response: 

The Logging System and Transportation Analysis (LSTA) for the 

Central Kupreanof Project Area has been refined and updated through 

extensive field surveys including the collection of stand exam data 

within the harvest units and preliminary verification of logging 

systems and road locations. This process allows more in-depth and 

site-specific analysis of this area than was done for the Forest Plan. 

NEAT_R analysis for all action alternatives shows deficit indicated 

bid rates. Values and costs derived from NEAT_R are based on 

information collected in past years and represent a snapshot in time. 

Changes in regional and global timber markets and other factors such 

as fuel costs can dramatically affect stumpage values and logging costs 

at the time of implementation and harvest. 

The alternatives are designed to be one sale or split into more sales. 

Alternatives include enough volume to be flexible in the future should 

market conditions improve. Chapter 3 of the DEIS acknowledges the 

opportunities for small sales, microsales, and project opportunities 

within the three action alternatives. 

The values produced using the NEPA Economic Analysis Tool are 

meant to provide the Responsible Official with a relative ranking of 

economic value and not an absolute economic value. In the DEIS, the 

Central Kupreanof project was analyzed using the Residual Value 

Appraisal (RV) version of NEAT, which is the current Forest Service 

Handbook direction. Current market conditions and timber sale costs 

have influenced the economic viability of this project. 

52 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
State EC-3 

The state offered to modify alternative 3 to provide a more 

economic alternative. 

Response: 

The Forest Service continues to work with the State in developing 

economically and technically viable timber sales. The Forest Service 

acknowledges that there are various subsets of units and multiple sale 

packaging scenarios associated with each alternative that address 

economics. The Forest Service has the opportunity to include or not 

include units that have been cleared through the NEPA process during 

sale preparation and packaging. 

If these units are cleared, and at the time of sale preparation market 

conditions do not allow for a positive sale that includes these units, the 

Forest Service has the flexibility at that time to defer these units. 

Please see response to comments AFA-8 in the Unit Suggestions 

section of this Appendix. See also response to EC-2 in this section. 

Beebe-1, SCS II-5

Discuss what the local demand is for timber from this sale area. 

Commenter’s feel there is not demand for much timber, and only 

alternatives to offer small sales alternative should have been 

analyzed. 

Response: 

Since 2007, five residents of Kake have expressed interest in 

purchasing small sales and microsales from the Central Kupreanof 

Project Area. The 6367 Timber Sale, located in close proximity to the 

Central Kupreanof project area, was offered and sold to a resident of 

Kake in 2008. A second small sale, as well as a microsale along the 

Kake road system, is scheduled to be advertised in 2009. More 

information regarding small sales and microsales has been added to the 

FEIS. 

All action alternatives provide small sale and microsale opportunities. 

These opportunities include offering a subset of units from the larger 

unit-pool or by providing microsales through salvaging dead or down 

trees along said roads. Microsales were analyzed by each resource for 

each action alternative (see DEIS Ch. 3). The DEIS (Ch. 3 p.17) 

discusses opportunities for small sales. 

As documented in Appendix C (Catalog of Events) of the DEIS, 

examples of projects where a subset of units were offered as small 

sales include; Bohemia Mountain Timber Sale EIS (1991 and FSEIS 

1995), and the South Lindenberg EIS (1996). 

Small Sales and 

Microsales 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 53 Appendix D
SCS III-3, GP XVI-1

The Timber Financial Efficiency Analysis needs to discuss all costs 

including pre-roading, and administrative costs.

Response: 

NEPA requires the disclosure of effects on the human environment 

and not the administrative costs of managing timber sale projects. 

Administrative costs play no part in the economic justification of the 

project. They are administrative costs, not economic benefits of the 

project. Plus these costs are appropriated by Congress and although 

tied to certain line budget items, do not mandate that a profit is made 

by the Forest Service in using this money for a specific program. The 

Forest Service is not mandated to make money by offering timber for 

sale. The Timber program is not unusual in costing more to operate 

than the government receives in revenues from the program. Many 

programs on the Tongass NF generated no revenue, including the 

subsistence, heritage, inventory and monitoring, land management 

planning, geology, fish and wildlife management, most trail 

improvements and fire protection programs. 

NEAT-R calculates the costs of analysis, sale preparation and sale 

administration based on previous multiple year estimates. These 

estimated costs used to be reported annually in the Timber Sale 

Program Information Reporting System (TSPIRS). This program was 

developed in response to Congressional direction contained in the 

Conference Committee Report on the 1985 Interior Appropriations 

Bill. The impetus for this direction was concern over "below-cost" 

sales, and the desire to have better information for the benefits and 

costs of selling national forest timber. The system was "pilot-tested" in 

Fiscal Year (FY) 1987 and 1988, and was officially implemented in 

FY 1989. This system is no longer used since the Forest Service has 

changed over the years to a more ecosystem management style from 

the more timber focused management style of the 1980s. For example, 

the information collected during the field inventory on one timber sale 

project is used in many ways that benefit us in National Forest 

management and sometimes research. Due to the structure of the 

budget allocation, it is not possible to divide these costs out because 

the costs and the benefits are not directly traceable. However, these 

numbers continue to be used for budget allocation requests to 

Congress. The information from NEAT-R is located in the project 

record. 

Pre-roading is a process whereby roads are constructed into a NEPA 

cleared project area prior to and separate from a timber sale or other 

resource activity. The intent of pre-roading is to develop or expand the 

transportation network without requiring one resource to carry the 

entire burden of road construction costs. Pre-roading is an 

Financial 

Efficiency 

Analysis 

54 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
administrative decision that requires funding from Congress and is 

subject to the same environmental laws and regulations (NEPA, 

NFMA, etc.) as other federal actions. At this time there are no 

foreseeable plans for road construction in the project area other than 

those disclosed in the FEIS and there are no Congressional 

appropriations slated for the Central Kupreanof Timber Harvest 

Project. 

Transportation and Access 

Management 

State RC-1

Provide information detailing the Forest Service definition of the 

word “storage” in comparison to the State’s definition of storage 

or closed. 

Response: 

There were comments regarding the Forest Service’s use of the word 

storage and the State’s definition of storage or closed. Part of this 

confusion may have come from the erroneous definition of Road 

Storage in Chapter 4 in the DEIS. This definition has been corrected. 

When road closure is discussed, it is referring to the definition of 

Maintenance Level 1, which fits the Alaska Forest Resources and 

Practices Act definition of “inactive.” Roads closed, in storage or 

maintenance level 1 are left in a self-maintaining state and basic 

custodial maintenance is assigned. 

State RC-2, SCS V-2

Address concerns regarding the construction, use, maintenance, 

and decommissioning of temporary roads. 

Response: 

Concerns were expressed about the construction, use, maintenance, 

and decommissioning of temporary roads. Temporary roads do not 

access future timber lands and do not have resource concerns that 

require engineering controls in construction (log stringer bridges do 

not require engineering controls). Temporary roads are displayed on 

the unit cards along with site specific narrative information. 

Action on the ground for decommissioning ranges from blocking the 

entrance and removing drainage structures to obliterating the road, 

returning the natural contours, and replanting vegetation. (All bridges 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 55 Appendix D
and structures will be removed.) The end result is the stabilization and 

restoration of unneeded roads to a more natural state (36 CFR 212.1). 

State RC-3

Slopes greater than 67%, not 72%, should require full bench 

construction. 

Response: 

Chapter 3 page 52 does contain an error and the second bullet of the 

third paragraph should read “Side slopes of greater than 67% would be 

mitigated by full bench construction and slope stabilization if 

necessary.” This has been corrected in the Final EIS. All applicable 

Forest Plan Standards and Guidelines, Forest Service Manual and 

Handbook direction (including Best Management Practices) will be 

incorporated during design, construction and maintenance of roads. 

GP XV-1, GP XV-2, SCS V-3

Address the RAP and ATM process as related to this DEIS. 

Response: 

The RAP recommendations were incorporated into the road 

management objectives for roads associated with this project. A 

complete copy of the recommended RMOs for the Kake road system 

and addendum to the Kake RAP is located in the project record. This 

RAP will be used in the District ATM process. Decisions from the 

Central Kupreanof project will be incorporated by the ATM NEPA 

document and analyzed cumulatively with road management 

objectives and strategies across the District. The desired condition for 

the forest transportation system is guided in part by 36 CFR 212.5- 

Road Management. Part b provides guidance for determining the 

minimum road system needed. Recommendations for roads not used 

with this timber sale proposal will be carried forward and analyzed in 

the District’s Access Travel Management NEPA document. 

SCS V-4, SCS VIII-1, GP XV-3, GP XV-5, GP XV-7

Concerns were expressed concerning funding for new roads, 

completing backlogged maintenance, addressing red fish crossings 

and closing roads. 

Response: 

The costs associated with closing existing roads and additional 

maintenance will be addressed in the Petersburg District Access Travel 

Management (ATM) NEPA document rather than the Central 

Kupreanof Timber Harvest. The ATM document will look at 

maintenance costs across the District in terms of projected budgets, 

56 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
resource issues and potential road closure decisions. Logging costs 

include cost for road maintenance during the life of the sale and the 

work is performed by the Purchaser. Timber sales are not required to 

bear the costs of culvert repair or replacement. Limited funds are 

allocated by Congress for this purpose and will be appropriated 

according to priorities across the Forest. 

To address the backlog of maintenance for the Tongass, the demand 

for roads has primarily been a function of demand for access to timber 

resources. The amount and level of maintenance and repairs is 

dependent upon traffic management objectives and maintenance 

criteria. Maintenance of existing NFS roads is an ongoing process that 

occurs on a periodic basis. These tasks are performed to keep the roads 

in the safe and useful condition for which they were designed. 

All of the Central Kupreanof Timber Harvest roads are constructed 

and maintained for silvicultural activities and will apply the practices 

described in BMP 12.5. Therefore they meet the criteria for 

silvicultural exemption from permitting under the Clean Water Act 

Section 404. All work will also be in compliance with the Tongass 

Forest Plan Transportation standards and guidelines (starting page 4-

80). 

The Tongass National Forest is also concerned about the loss of fish 

habitat upstream of culverts restricting fish passage and has corrected 

more than 250 red crossings throughout the Forest during the last 

several years. Many of these have been on the Petersburg Ranger 

District. It may not be advisable or feasible to replace all existing red 

culverts with fish passage designed crossings. Many of the crossings 

have very limited amounts of fish habitat upstream and it may be more 

advantageous to mitigate the effects through the Clean Water Act 404 

permit process. An interagency group has made progress on a model 

that would help make management recommendations for red culverts 

which reduce or restrict fish passage. The model was tested in 2006 

and the preliminary findings are available. The model requires 

refinement and additional data needs to be collected before it can be 

used for all culverts on the forest. The removal or replacement of red 

culverts to improve fish passage has been done and will continue to be 

done when funding opportunities are available. Fish passage at up to 

nineteen red crossings may be corrected with the implementation of 

any of the action alternatives as part of the stewardship opportunities 

identified through the RAPS process, and depending on ATM review 

and decisions in 2009. The removal of 4 red crossings is associated 

with the closure of 1.69 miles of road used for the timber sale (in any 

action alternative). 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 57 Appendix D
GP XV-4

Build no new roads within Roadless Areas. 

Response: 

Alternative 4 builds no new roads in any inventoried roadless area as 

well as avoids harvest within their boundaries. The Tongass is 

currently exempt from the prohibition of timber harvest and building 

roads in inventoried roadless areas. While these activities would 

reduce roadless acres within the project area, the roadless values 

would remain unchanged or be minimally influenced by the proposed 

activities in all action alternatives. 

The effects of alternatives on roadless acres and values are disclosed 

on pages 3-23 to 3-35 of the DEIS. 

GP XV-6

Road Condition Surveys should be completed on all roads, and 

why do some roads not have complete road condition information. 

Response: 

Page 3-42 of the DEIS states that Forest Service personnel have 

conducted road condition surveys on many of the existing roads in the 

project area. This information can be found in the project record. 

Surveys for new road construction were completed during two field 

seasons for this project and incorporated into the resource report and 

new NFS road designs. 

Prior to implementation of the project, all existing and new roads will 

have ground surveys completed and incorporated into the final 

designs. All applicable Forest Plan Standards and Guidelines, Forest 

Service manual and handbooks (including BMPs) will be incorporated 

during design, construction and maintenance of roads. 

GP XV-8

This analysis should consider delays for litigation when discussing 

the benefits of closing roads, and needs to consider whether there 

will be funding to close roads in 5-10 years after the timber sale. 

Response: 

While litigation is a possibility, it is not considered a foreseeable 

action as it may or may not occur for a given project. Decisions from 

the Central Kupreanof project will be incorporated by the ATM NEPA 

document and analyzed cumulatively, including the decision to close 

any new road within 5-10 years after timber sale activities. The annual 

review of the Motor Vehicle Use Map and road management 

objectives will keep closure decisions active. The RMOs for the 

58 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
proposed new NFS and reconstructed roads note closure is desired 

within five to ten years of the timber sale. 

The ATM will address funding and implementation of existing road 

closures. We have several levels of closure and will still do annual 

maintenance as needed. 

EPA-3

Please include a discussion in the FEIS of the shift from National 

PDES to Alaska Pollutant Discharge Elimination system (APDES) 

Program and how this may affect your current LTF permits. 

Response: 

On October 31, 2008, the State of Alaska, Department of 

Environmental Conservation assumed authority over the Alaska 

Pollutant Discharge Elimination System (APDES). The general 

permit became effective on December 1, 2008. The Tongass NF 

submitted a request in the form of an adoption letter on February 10, 

2009, to ADEC to adopt the previously filed Notification, AK-G70-

0019, Hamilton Bay. This facility was previously authorized and 

operating under an administratively extended NPDES permit. Since 

the LTF operations have not materially changed since submission of 

the Notification it is anticipated that the permit will be adopted. 

Wildlife 

DR-9

Analyze the effects of road construction upon predation levels to 

deer and moose. 

Response: 

Open road and total road densities for the project area are provided on 

page 3-72 of the DEIS. It is recognized that increased road building 

may provide additional access for hunters/trappers and therefore with 

easier access, may create additional pressure in new areas. Cumulative 

total road densities for the project area, Kupreanof Island, and for 

Kupreanof/Mitkof Biogeographic Province by alternative have been 

included in the FEIS (see also response to “Wolves/Road Densities” in 

this appendix). The Subsistence section in Chapter 3 disclosed the 

effects of the project on access to wildlife resources and potential 

changes in competition. 

Biological 

Studies 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 59 Appendix D
DR-10

Provide an analysis of the deer, moose, bear and wolf populations 

within the Project Area. 

Response: 

The analysis found in the FEIS and the wildlife specialist report 

considers effects to all Management Indicator Species (MIS). The 

analysis used POG as the avenue to assess impacts of each action 

alternative on habitat for each MIS. The Forest Service has worked 

with ADF&G on various analyses, including deer pellet counts and 

harvest records. Field crews spent two years with up to 15 people per 

crew working on the proposed units looking for presence and absence 

of vegetation as it relates to wildlife species in the project area. 

ADF&G Quick Cruise Plots were conducted. These provided rated 

scores based on the quality of habitat. ADF&G does not anticipate 

changes to harvest limits of game species at this time. 

USDI-5

The potential effects to bald eagles need to be analyzed in the 

FEIS. 

Response: 

Bald eagles are protected by the “Bald and Golden Eagle Protection 

Act” and known nesting sites are cataloged by the USFW Service. 

Bald eagles usually nest close to salt water for predator/prey reasons. 

This catalog has been reviewed for this analysis and most known nests 

occur within the 1000’ beach buffer. Further analysis indicates that the 

closest known nest to a project road or unit is approximately 2,100 feet 

from the LTF. This nest has been there for many years. Minimal 

disturbance is expected because of the distance from the known nest 

site to the LTF road. The project is an “interior” timber proposal; 

therefore no habitat will be lost for bald eagles. 

No surveys are required by the Forest Plan; however, any new sites 

found during document preparation or sale implementation will be 

protected by the Bald and Golden Eagle Protection Act. 

BK-2

Address the lack of high quality deer habitat within the Project 

Area. 

Response: 

The DEIS acknowledges (3-72) that “The habitat in the project area is 

not capable of supporting large numbers of deer because this area on 

Kupreanof Island lacks large contiguous stands on high volume timber 

Bald Eagles 

Deer 

60 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
with high quality browse that deer rely on to provide cover and 

forage.” 

Proposed units were evaluated by conducting Alaska Department of 

Fish and Game (ADF&G) Quick Cruise plots within the project area, 

which evaluated the quality of available winter habitat within the 

project and depicts the relative quality of the winter deer habitat. 

These plots rated the quality of winter habitat from 0 to 100, 0 being 

the poorest and 100 being the best. The results indicated scores range 

from the low 30’s to the low 70’s within the project area. The 

importance of the higher value habitat was considered in the final 

design of the proposed action. Units with the relative highest deer 

habitat within the proposed units were removed from the alternative 

and the second highest units were recommended for partial harvest 

(see Central Kupreanof Timber Sale Issue Development and 

Alternative Review in project record). On page 3-67 of the DEIS, the 

methods section discussed use of deer quick cruise plots and how the 

results were analyzed. Again, habitat with the highest total scores was 

evaluated to make sure connectivity exists on the landscape. The 

methods discussion in the FEIS will be expanded to include more of 

this information. 

The majority of coarse canopy and consequently high volume strata 

within the project area is protected in old-growth reserves. 

GP V-11, State WC-8

The analysis of POG was not sufficient to back up judgments that 

were made regarding deer habitat; analysis should include deer 

habitat capability. 

Response: 

See the discussion under “POG Analysis” in this response to 

comments. The methods section in the FEIS was expanded to include 

the rationale as to why POG was chosen as a unit of measure for this 

project area. 

GP V-13

Explain how partial-cut prescriptions protect deer winter habitat. 

Response: 

Historic partial harvest treatments (50 percent retention) on the 

Tongass National Forest studied by Deal (2001) show that these 

treatments could provide deer food and habitat better than clearcut 

treatments. The light (1-25 percent basal area) and medium (26-50 

percent basal area) cutting intensity plots did not differ significantly in 

community structure from the uncut plots. Partial harvest stands do not 

show the dramatic rise and fall of blueberry abundance in stands 20 to 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 61 Appendix D
80 years after clearcutting. Deal also noted that the decrease in 

blueberry abundance following partial harvest was small when 

compared to that of clearcutting. Community plant structures in the 

forest of Southeast Alaska appear to be resilient to moderate ranges of 

partial cutting (up to 50 percent basal area removal). Overall, partial 

cutting maintained diverse and abundant plant understories 

comparable to the plant communities typically found in old-growth 

stands (Deal 2001). Alternative 2 incorporates partial harvest with 50-

60 percent retention in several units. These units would retain structure 

of the existing tree stand and help maintain wildlife values including 

potential travel corridors. 

Within the next 50 years, it is predicted that the deer habitat values in 

these stands would return to what they are presently (Deal and 

Tappeiner 2000, Deal 2001). 

SCS VI-10

Commenter does not think the deer model should be used. There 

is not an adequate discussion of deer habitat carrying capability, 

and the cumulative effects analysis needs to explain the lack of 

habitat in partial harvest units, winter related deer mortality, and 

climate change. 

Response: 

According to Hanley and Friberg (2009), all SDM categories are not 

equal. They found that grouping the seven SD classes into three 

supra-classes made sense statistically for the winter seasons. They 

placed SD4H in the small tree category because it produces the highest 

amount of deer forage during winter months (if it is available). The 

second category they called medium tree, which is composed of SD4S, 

SD4N, SD5H, SD5S and SD5N. Finally the large tree group, which 

comprised SD67, produced the lowest amount of winter forage for 

deer. These three supra-classes make up POG and this analysis shows 

that the best winter habitat is comprised of small and medium tree 

categories and the lumping of all POG into suitable habitat is 

consistent with the best science available to predict alternative effects 

on deer winter habitat. While looking at the currently available studies 

on deer in Southeast Alaska, one thing becomes evident; the categories 

that make the up medium tree class provides good deer winter habitat 

and grouping the POG together creates a conservative approach to deer 

habitat during the winter (Schoen and Kirchhoff 1990, Doer et al. 

2005, Farmer et al. 2006 and Schoen and Kirchhoff 2007 found in the 

Nature Conservancy Publication 2007). This analysis tiers to the 

Forest Plan Standards and Guidelines that require the consideration of 

Sitka black-tailed deer habitat needs as part of project analysis. As 

62 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
such, the reduction of POG habitat was used to analyze effects of all 

action alternatives. 

The Subsistence section in Chapter 3 of the DEIS talks about the 

effects of harsh winters on deer mortality (3-89 and 90) which has 

been expanded in the FEIS. Brainard (2007) provided a summary of 

transect efforts and snow conditions. During the spring of 2007, the 

Wrangell and Petersburg Ranger Districts conducted deer mortality 

transects over much of Game Management Unit 3. Transects were 

conducted on Zarembo, Woronkofski, Etolin ands Wrangell Islands on 

the Wrangell Ranger Districts; and Kuiu, Kupreanof, Mitkof and the 

Mainland on the Petersburg Ranger District. On Wrangell, the 

mortality averaged 0.8 deer/mi of transect. On Petersburg, the 

mortality averaged 0.4 deer/mi of transect. 

During the winter of 1971-1972, over 221 inches of snow was 

recorded in Petersburg, Alaska. The majority of snow fell during the 

months of December (51.3 inches), January (48.9 inches) and February 

(54.3 inches) with an additional 35 inches in March. While talking to 

colleagues who were working in the Petersburg area at that time, the 

snow covered almost all of the browse species that deer need to sustain 

them. It remained this way until late May, early June (Gerdes, Pers. 

Com. 2007). 

During the most recent winter, (2006-2007) we again had record 

snowfall (225 inches) in the area surrounding Petersburg. This 

snowfall occurred in a different manner. The high snow months 

occurred in November (62.7 inches), and again in March (87.8 inches). 

During the months of December (25.3), January (24.1 inches) and 

February (23.9 inches) snow levels were much lighter. Even with the 

high snowfall in March, the blueberry bushes were still not covered 

with snow and the snow melted around the tree bases. Deer tracks are 

evident and quite numerous in the snow as high as 500 feet in 

elevation. It appears the predicted high deer mortality due to the 

extreme snowfall conditions during this past winter did not occur. The 

Deer Mortality reporting data sheets for all transects are included in 

the planning record (Brainard, 2007). 

The effects of climate change are beyond the scope of a project 

analysis. Effects of climate change on wildlife resources were 

addressed in the Forest Plan. Changes due to climate change are 

difficult to predict. Species will respond to changing climates 

individually; some species and some individuals will be more sensitive 

and vulnerable than others (Millar et al. 2006). The degree of change is 

uncertain. 

Please, also see response to comments in the Climate Change section 

of this Appendix. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 63 Appendix D
DR-3

Harvest of timber and construction of roads decreases the value of 

the deer habitat in the Project Area. 

Response: 

On page 3-72 in the DEIS, the wildlife habitat analysis states that the 

project area is not capable of supporting large numbers of deer because 

this area lacks large contiguous stands of higher volume timber with 

high quality browse that deer rely on to provide cover and forage. 

The methods discussion in the FEIS has been expanded to include the 

rationale for using POG for the unit of measure. This discussion 

includes a better look at the existing condition of the project area. 

There is limited coarse canopy and high volume strata within the 

project area and particularly within proposed harvest units. The 

majority of coarse canopy and high volume strata is protected in oldgrowth reserves. 

Proposed units were evaluated by conducting ADF&G Quick Cruise 

plots within the project area, which evaluated the quality of available 

winter habitat within the project and depicts the relative quality of the 

winter deer habitat. These plots rated the quality of winter habitat 

from 0 to 100. Units with a score of zero are considered the poorest 

and 100 the best. The resulting scores on the project area ranged from 

the low 30’s to the low 70’s, which indicates that the majority of the 

project area has moderate to low value habitat. 

In the Shamrock analysis the biologist used HSI scores of 0.7 to 1.0 

for good habitat, 0.3 to 0.7 for average habitat and 0 to 0.3 for below 

average habitat. No acres of good habitat were recorded, 8.3 percent 

was considered average, 72.8 percent was considered below average 

and 19 percent of the acreage was considered unsuitable habitat 

because they scored zero HSI. The Shamrock EIS used the best 

information available at that time. Knowledge of how animals 

respond to habitat alterations has expanded so differences in analysis 

techniques are to be expected. 

DR-5

Explain how the low population of deer within the Project Area is 

not directly related to timber harvest. 

Response: 

You are correct with your detailed history. Much of this was covered 

in the Forest Plan (1997 and 2008). Brainard (1996) located in the 

planning record, addresses many of your concerns. Moose prefer 

different food than deer. The wolf population has increased because of 

the increase in prey populations (bear, moose, deer, beaver etc). Bear 

64 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
populations may have increased due to the increase in forage available 

due to old harvest units however, there is no evidence that this has 

actually occurred. In fact, restrictions to black bear hunting by nonresident and non-subsistence qualified residents have been put in place 

to maintain the black bear populations on both Unit 2 (POW) and Unit 

3 (Kupreanof, Kuiu, Mitkof etc). Food for deer is not the limiting 

factor for deer population. Severity of winter weather, predation, 

competition, and other stochastic events such as; wind storms, the size 

of deer rumen (which does not allow the deer to eat large quantities of 

food unlike moose and elk) are all limiting factors. All of these and 

other factors can cause deer to be below carrying capacity and thus not 

utilizing all the food available to them. 

USDI-1, USDI-2, State WC-6, OVK-3 SCS VI-14, SCS VI-15

Provide information detailing considerations to ensure Goshawk 

protection within the Project Area. 

Response: 

The DEIS indicates that more information on the Queen Charlotte 

Goshawk is available in the Biological Evaluation. The Wildlife BE is 

published in Appendix E of this FEIS. The DEIS discloses that there is 

high probability of goshawks occurring in the project area and there is 

a potential for a measurable effects to population in the analysis area 

(p3-69). However, all applicable Forest Plan Standards and Guidelines 

for goshawks will be applied in conjunction with reliance on the 

Conservation Strategy and Old-Growth Reserves to protect the 

species. Field surveys for the project were completed in 2006, 2007. 

These surveys were conducted using the most current inventory 

protocols. Field survey notes can be found in the planning record. If 

after two years of monitoring indicates no evidence that goshawks are 

present then buffers around “probable nests” may be subject to timber 

harvest. 

Nest buffers were applied to the 6 known nests in the project area in 

accordance with the Forest Plan (4-99). The Forest Plan FEIS 

discusses goshawk nest buffers in Appendix D (22-25, also last 

paragraph of page D-45, last paragraph of page D-47 through top of 

page D-48). 

State WC-7, OVK-1, OVK-3, SCS VI-6, SCS VI-7, SCS VI-8, 

EPA-4

The DEIS does not contain enough information concerning 

marten. 

Response: 

The DEIS analyzes marten in Chapter 3 on pages 70-71. The section 

discusses marten habitat, including those areas with higher value (high 

Goshawks 

Marten 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 65 Appendix D
volume old-growth coast habitats protected by beach fringe and 

riparian areas protected by riparian management area Standards and 

Guidelines). Current road density was provided with 

acknowledgement that increased road miles increases hunter and 

trapper access and potential pressure on marten. The analysis 

concludes that while there may be localized effects from the proposed 

activities there is not an anticipated effect to the marten populations. 

Marten are protected by the Forest Plan Standards and Guidelines, the 

Conservation Strategy, Old-Growth Reserves and beach buffers. This 

is expected to provide the habitat and prey to support marten. 

The 2008 Forest Plan standards and guidelines do not require 

identification of high value marten habitat or winter habitat. This 

requirement has been replaced with the Legacy Forest Structure 

Standard and Guidelines. Petersburg is listed as having no VCUs 

where retention is required (p. 4-90 and FEIS p. 3-279). 

State WS-6, GP V-12, OVK-2, SCS VI-9, State WC-4, GP V-10, 

GP V-4, SCS V-1

Address road density in the project area and its effect on wildlife. 

Response: 

Open road and total road densities for the project area are provided on 

page 3-72 of the DEIS and in Chapter 3 of the FEIS. It is recognized 

that increased road building may provide additional access for 

hunters/trappers. Road density was displayed at the project level 

because it is considered a closed road system and the smaller area 

would be more sensitive to project-level changes in miles of road. 

In response to comments, total road densities were run at the project 

level, Kupreanof Island-wide and at the biogeographic province. Total 

road densities for this analysis include open and closed NFS roads, as 

well as any private or State roads within the appropriate boundaries. 

Road layers of private and State roads may not be complete, for 

instance, Kake Tribal roads and actual densities may be higher. 

Municipal roads for Petersburg and the City of Kake were not included 

in the calculation. The following table provides the road densities at 

the different landscapes. Road densities can be found in the Wildlife 

section in Chapter 3. 

Wolf/Road 

Densities 

66 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Road densities 

(mi/mi2) 

Alt 1 Alt 2 Alt 3 Alt 4 

Project Area 

Open Road 

0.27 0.31 0.41 0.28 

Project Area 

Total Road 

0.33 0.36 0.44 0.33 

Kupreanof Island 

Total Road 

0.22 0.23 0.25 0.22 

Mitkof/Kupreanof 

Biogeographic 

Province Total 

Road 

0.31 0.32 0.34 0.32 

In consultation with ADF&G, concerns over different road density 

calculations, within the biogeographic province, were discussed. 

Roads were decommissioned or put into storage with the Scott Peak 

timber sale and additional roads in the biogeographic province have 

been closed using decommissioning and storage since the Scott Peak 

sale was analyzed. ADF&G specifically cited road densities published 

in the Scott Peak Timber Sale FEIS. In the Record of Decision (2006) 

for the Scott Peak FEIS, the erratum corrected (from the FEIS) the 

road density for all roads (including private and state) less than 1,200 

feet for the Mitkof/Kupreanof Biogeographic Province as currently 

0.44 miles per square mile. It also calculates cumulative effects road 

density of 0.456 miles per square mile. 

The DEIS cites the Forest Plan discussion of habitat carrying capacity 

for the Biogeographic Province (p. 3-72) in both the 1997 Forest Plan 

and the 2008 Forest Plan Amendment (analyses which used the deer 

model). It concludes with implementation of any action alternative, 

deer would still average between 17 and 15 deer per square mile. The 

2008 Forest Plan suggests using the most recent interagency deer 

habitat capability model for this analysis “unless alternate analysis 

tools are developed” (4-95). For this project, deer habitat was analyzed 

using Productive Old-Growth (POG) and utilizing the ADF&G Quick 

Cruise habitat plots in connection with local knowledge and field 

validation of deer habitat conditions. 

 Partial cuts are believed to maintain stand structure similar to un-cut 

old growth stands and the cutting had no significant effects on tree 

species composition (Deal and Tappeiner 2000). 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 67 Appendix D
OVK-4, SCS VI-4, SCS VI-5

Concern was expressed that black bears need to receive additional 

protection as black bear sport hunting has increased, and they are 

sensitive to harvest and road building activities. 

Response: 

We agree that riparian buffers are important to bears. All salmon 

streams are protected by Forest Plan S&Gs. 

Currently ADF&G monitors the bear harvest on Kupreanof Island with 

a two bear limit per resident with an average of 28 bears taken per year 

from 1998 to 2007. Alaska Department of Fish and Game has given us 

no indication of any black bear restrictions forthcoming within the 

project area. While specific brown bear Standards and Guidelines were 

established in the Forest Plan, specific black bear Standards and 

Guidelines have not been established by the Forest. 

State WS-7, OVK-6, SCS VI-21 

Expand the discussion of subsistence use for the residence of Kake 

and how it may be impacted by further harvest activities. 

Response: 

Goldschmidt and Haas provide maps of lands belonging to tribes of 

the Tlingit and Haida (1946) and specifically of the claims of the 

Natives of Kake (Chart 13). These maps show traditional and 

customary use of northern Kupreanof, Kuiu, the southern western 

shores of Baranof and the southern part of Admiralty Island. The 

Subsistence section in Chapter 3 discusses subsistence use areas of 

Kake, focusing mostly on the 5 WAAs identified in the Forest Plan. 

The Central Kupreanof FEIS has expanded this discussion to include 

use areas on Kuiu and Baranof. It now also includes information on 

how reliance on the resources of Admiralty has increased while access 

remains difficult for residents, especially in the winter hunting months. 

WS-8, SCS VI-22

Consider the effects on subsistence from other planned timber 

harvest activities in areas adjacent to the Project Area, such as the 

north end of Kuiu Island. 

Response: 

The wildlife habitat analysis considers adjacent areas of timber harvest 

in identifying cumulative effects. The DEIS under “Resource Analysis 

Area” specifically states that “It is possible animals move between 

Kuiu Island and Kupreanof Island, as a result several WAAs from 

Kuiu, as well as the WAAs from the Central Kupreanof project area 

will be included in the analysis” (DEIS p. 3-66). On page 3-84 under 

Black Bear 

Subsistence 

68 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
“Cumulative Effects: WAA,” it states the analysis included seven 

WAAs with three on Kuiu, as well as four WAAs on Kupreanof 

covering the Native Corporation lands (and past harvest of) near Kake. 

The analysis includes effects of timber sales at Kuiu, Threemile, and 

Crane Rowan. The DEIS discloses at this WAA level up to 28.3 

percent of POG could be harvested cumulatively. The FEIS analysis 

has been updated to exclude the Threemile Timber Harvest as this is 

no longer a valid NEPA decision therefore reducing predicted 

reasonably foreseeable future cumulative effects. 

The cumulative effects also analyzes effects at the Biogeographic 

Province including timber harvest on private lands and such timer 

sales as Bocephus, Scott Peak , Lindenburg, Finger Point, Overlook 

and Woodpecker timber sales. The analysis shows that up to 30.2 

percent of POG could be harvested cumulatively. 

GP V-12, GP V-12a, State WC-8

Expand the discussion relating to deer habitat capability. 

Response: 

The Forest Plan Standards and Guidelines referred to specifically talks 

about the management of the wolf (S&G XIV.A.). The DEIS cites the 

Forest Plan discussion of habitat carrying capacity for the 

Biogeographic Province (p. 3-72) in both the 1997 Forest Plan and the 

amended 2008 Plan (analyses which used the deer model). It 

concludes with implementation of any action alternative, deer would 

still average between 17 and 15 deer per square mile. The 2008 Forest 

Plan suggests using the most recent interagency deer habitat capability 

model for this analysis “unless alternate analysis tools are developed” 

(p. 4-95). For this project, deer habitat was analyzed using productive 

old-growth (POG) and utilizing the ADF&G Quick Cruise habitat 

plots in connection with local knowledge and field validation of deer 

habitat conditions. 

SCS VI-20

Provide a more complete evaluation of access issues for 

subsistence uses, non-rural users and a growing guided sport 

hunting industry. 

Response: 

Currently there are no outfitter/guides permitted for the Kake road 

system. The DEIS discloses the effects of access to subsistence uses 

including potential changes in competition (Chapter 3). Subsistence 

hearing meetings were held in both Kake and Petersburg, Alaska 

during March 2009. While testimony in Kake included concerns about 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 69 Appendix D
maintaining current roads for subsistence and recreation access, no one 

testified that there is too much or too little motorized access available 

to users. The District wide Access Travel Management Plan will look 

at access across the entire Kake road system as well as across the 

District. This NEPA document will include intensive public 

involvement to better understand what roads are being used for 

subsistence and recreation activities, what roads are less important to 

these activities and what other access needs communities may have. 

See above response to “Traditional and Customary use areas; Use of 

Admiralty.” 

SCS VI-23

Provide a detailed discussion of competition from predators for 

deer and how this affects subsistence deer harvest. 

Response: 

Competition between predators and deer was analyzed at the Forest 

Plan level. Deer populations have rebounded from the winter kills of 

the late 1970s and early 1980s. Kuiu Island and Kupreanof Island 

have different prey patterns and differing predator relationships. Black 

bears are much more prevalent on Kuiu than on Kupreanof Island. 

Because of the winter kills subsistence patterns changed from Kuiu to 

Admiralty Island. While the population of deer has not returned to the 

pre-die off levels they have rebounded substantially. Subsistence 

hunters have not returned to Kuiu because of the hunting limit (2 buck 

deer) opposed to the hunting limit on Admiralty (5 deer), in addition to 

the length of the season (four months on Kuiu, six months on 

Admiralty). 

SCS VI-19

POG analysis does not fully evaluate the effects to all subsistence 

resources. Commenter requests a reevaluation of the finding. 

Response: 

The evaluation of subsistence wildlife species within the project area is 

found in Chapter 3 of the DEIS (p.3-87 through 3-93). This evaluation 

refers to the habitat analysis found in the Wildlife section of Chapter 3. 

This section discusses wildlife species, such as black bear, wolf, deer 

and marten. The effects of timber harvest on wildlife habitat were 

analyzed by comparing changes in Productive Old Growth (POG) 

using the Size Density Model (SDM). 

Page 3-89 of the DEIS determines that no significant effect of salmon, 

other finfish or invertebrate habitat capability is expected from 

implementation of any alternative. Reference to the analysis in the 

70 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
essential fish habitat evaluation for this determination has been added. 

A discussion specific to fisheries and invertebrate subsistence uses, 

including access, has been added to the subsistence section. 

A discussion of vegetative subsistence uses has also been added in the 

FEIS to the Subsistence section in Chapter 3. 

State ANILCA-3

Reference where in the DEIS information pertinent to ANILCA 

regulations is located. 

Response: 

Page numbers have been included to reference the subsistence analysis 

leading to subsistence conclusions contained in other sections of the 

FEIS. For example, the wildlife habitat analysis of POG can be found 

in the Wildlife section. 

SCS VI-24

Concerns were expressed that concentrated cumulative harvest 

was affecting subsistence use areas of the Kake and Petersburg in 

respect to other Southeast communities. 

Response: 

 Currently across the Tongass National Forest, several timber sales are 

being planned or implemented affecting various Southeast Alaska 

communities such as Thorne Bay, Craig, Hoonah, Ketchikan and 

Wrangell. Land Use Designations and their proximity to Southeast 

communities were allocated and analyzed in the Forest Plan. 

DR-1

Commenter is concerned that the OGRs for VCU 4360 and 4350 

do not provide suitable winter habitat for deer and moose. 

Response: 

During the 2008 Forest Plan development, the Forest worked with 

ADF&G and USFWS to complete a more comprehensive review and 

mapping effort concerning small old-growth reserves for the 2003 

Forest Plan Supplement. Appendix D of the Forest Plan explains that 

these interagency designs were further reviewed by Ranger District 

staff and final refinement made by the Forest Supervisor. Appendix D 

explains that “this refinement process was conducted in order to 

consider multiple-use objectives in addition to pure biological ones” 

(FEIS Vol. II p. D-28). All small OGRs were adjusted to meet the 

criteria found in Appendix K of the 1997 Forest Plan. Small OGRs 

should include about 16% of a VCU land base, of which 50% should 

Old Growth 

Reserves 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 71 Appendix D
be productive old-growth (volume class 4, 5, 6, and 7). As a result of 

the 2008 Forest Plan process, OGR locations were generally finalized 

for most small OGRs, including those within the Central Kupreanof 

Project Area. 

 

DR-2

Commenter is concerned that road building will provide new 

corridors for predators to travel. 

Response: 

As explained in DR-1, small OGRs were adjusted during the Forest 

Plan Amendment. The OGR spanning VCUs 438 and 436 is within a 

Timber Production LUD. Originally the small OGR was located 

further south. The movement to this higher value habitat was a 

conscious decision. It is recognized that timber harvest and road 

building in the surrounding Timber Production LUD, according to the 

Forest Plan LSTA and evident in this specific project planning, can 

and will occur right up to the borders of the small OGRs. There are no 

buffers. It is recognized that increased road building may provide 

additional access for hunters, trappers and predators. 

State WC-1, SCS VI-16

Provide a higher quality LUD map with information regarding 

OGRs in relation to proposed units, and disclose whether the 

Project Area OGRs were the ones designed by the interagency 

biologist team. 

Response: 

Roads will be added to the LUD map, Figure 1-2 in the FEIS. During 

the 2008 Forest Plan development, the Forest worked with ADFG and 

USFWS to complete a more comprehensive review and mapping effort 

on small old-growth reserves. Appendix D of the Forest Plan explains 

that these interagency designs were further reviewed by Ranger 

District staff and final refinement made by the Forest Supervisor. 

Appendix D explains that “this refinement process was conducted in 

order to consider multiple-use objectives in addition to pure biological 

ones” (FEIS Vol. II p. D-28). As a result of this process, OGR 

locations were generally finalized for most small OGRs, including 

those within the Central Kupreanof project area. 

72 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
State WC-5, GP V-17. OVK-3, SCS VI-17, SCS VI-18

Explain the effects of habitat fragmentation, naturally occurring 

and man made, as related to OGRs and connectivity within the 

project area. 

Response: 

The DEIS discloses that landscape connectivity was analyzed for this 

project and the FP S& G (Forest Plan p. 4-91) was applied. The DEIS 

explains that landscape connectivity is maintained in the project area 

through the existence of non-development LUD, OGRs and beach 

fringe areas. Small OGRs were adjusted during the 2008 Forest Plan. 

According to the conservation strategy these adjustments provide for 

landscape connectivity (Forest Plan FEIS Appendix D). In designing 

the proposed action, additional consideration to connectivity was given 

by looking at the results of the deer quick cruise plots taken in the 

project area. Units with higher total quick cruise plot scores were 

dropped or prescribed for partial harvest methods to allow for better 

connectivity. The Forest Plan standard and guidelines do not require 

specific analysis methods in looking at connectivity. The analysis 

conducted complies with the Forest Plan standards and guidelines. 

The issue of connecting Prince of Wales Island with Kupreanof Island 

is not well understood as there is a large body of water between these 

two islands. Regardless this concept is beyond the scope of this 

project and should be addressed (if needed) at the Forest Plan level. 

GP V-2, GP V-6, GP V-7, SCS VI-2, SCS VI-3, SCS VI-5a

Commenter’s feel that the wildlife analysis in the DEIS was not 

sufficient and do not agree with POG as a sufficient analysis tool. 

Response: 

Coarse canopy was evaluated during the initial stage of wildlife 

inventory and analysis. It was clear that the amount of coarse canopy 

depicted within the harvest units was limited and that the majority of 

coarse canopy in the project area was protected by the old-growth 

reserve system. High volume strata when depicted within the project 

area looked a lot like the coarse canopy. Because of the limited 

amount of this habitat type, the effects on coarse canopy and/or high 

volume strata would not provide a measurable difference between 

alternatives nor provide the decision maker with a meaningful 

comparison of alternatives/effects on wildlife. 

 Deer quick cruise plots were recorded in the majority of the unit pool 

which scores habitat from 0 to 100. Results were analyzed and the 

habitats with the highest total score were evaluated to make sure 

connectivity exists. Connectivity was evaluated in the project area 

Productive Old 

Growth (POG) 

Analysis 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 73 Appendix D
using POG and connectivity will be maintained. See IRI crew survey 

results in project record. 

Looking at the reduction of POG provides a way to measure effects to 

wildlife as well as to display the amount of habitat that is no longer 

available to a suite of wildlife species. This approach provides a clear 

comparison of alternatives. A brief discussion of the relevant species’ 

habitat preferences and requirements is also included in the FEIS. 

It is recognized that the use of POG as the unit of measure for wildlife 

habitat is a broad tool and does not address specific seasonal habitat 

use of wildlife species. However, while there have been attempts to 

define the limiting winter habitat of various species, field studies are 

showing use occurring in all volume classes. Depending on winter 

severities, while volume class 6 and 7 provide snow cover, these 

stands offer little foraging opportunities. There may be many winters 

that volume class 5 stands, which provide some snow cover as well as 

large amounts of food, play a more important role in winter survival 

than the coarse canopy stands. There is still much to discover and 

understand about the relationship between wildlife species and their 

habitat use. In this particular project area, as discussed above, using 

productive old-growth makes sense to compare the effects of 

alternatives when the main effect to habitat in the project area is the 

reduction of a generalized productive old-growth base. 

Effects were analyzed at various scales including the biogeographic 

province, multiple WAAs, and at the project level. Wildlife 

recommendations were addressed in the silvicultural prescriptions. 

These recommendations will be identified in the unit cards in the 

FEIS. 

This project is consistent with Forest Plan direction involving 

landscape connectivity found on page 4-91. 

State ANILCA-1

Commenter recommends allowing short-term limited access to 

temporary roads associated with the Project Area. 

Response: 

Temporary roads are built and authorized for use by the timber 

purchaser for the sole purpose of accessing timber. Temporary roads 

are at no time open to the public and are decommissioned after timber 

harvest. We have clarified and corrected information on the potential 

miles of increased access. However, the proposed new NFS and 

reconstructed roads would be closed with five to ten years after the 

completion of timber harvest. 

Roads 

74 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
State ANILCA-2

If closing roads associated with the project will restrict the 

public’s subsistence access to those roads a formal closure process 

(ANILCA 811) would need to be followed. 

Response: 

The DEIS was clear in the intention that new and reconstructed NFS 

roads would be closed within five to ten years after timber harvest. 

This document is intended to give formal notification that while roads 

may be open to public use in the interim, ultimately the objectives for 

these roads are closure. ANILCA hearings were held in March (in both 

Kake and Petersburg). If an action alternative is selected and before 

physical closure of any road, the Forest Service will post public 

notices of specific road closures and dates per the Central Kupreanof 

Final EIS and Record of Decision. See Transportation section for an 

analysis of road construction activities. Roads are also discussed in 

the RAP, which will be forward for analysis in the District wide 

Access and Travel Management document. 

We recognize people from Kake are going to Admiralty Island for 

subsistence uses. The Central Kupreanof DEIS and FEIS analyze the 

impacts of subsistence use for only the Kuiu/Kupreanof subsistence 

analysis area. 

GP V-8

Address the impacts of road building and delayed road closures on 

wildlife. 

Response: 

Motorized access will increase during the sale and for up to ten years 

after timber harvest activities. The DEIS recognizes increased road 

building may provide additional access for hunters and trappers (3-72). 

The DEIS states this effect for marten, deer and wolves as well as 

access to all subsistence resources. Refer to discussion in Chapter 2 

detailing the relationship between the ATM and this FEIS. 

SCS V-1 

Provide a discussion of road densities below and above 800 feet. 

Response:

A table and discussion was added to the FEIS disclosing road densities 

for the project level, Kupreanof Island and the Mitkof/Kupreanof 

biogeographic province. The majority of the Central Kupreanof 

project is located at low elevations. Person (et al. 1996, 2001) stated 

that wolves spend the majority of their time below 1200 feet in 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 75 Appendix D
elevation. Wolf populations do not generally suffer when road 

densities are held below 0.7 to 1.0 miles per square mile (Person 1996, 

2001, 2008; USDA 2008) as measured at the biogeographic province 

level. The Mitkof/Kupreanof Biogeographic Province has at most a 

road density of up to 0.44 miles per square mile, depending on which 

action alternative is selected. This road density was calculated for the 

entire biogeographic province for all elevations. The miles of road 

above 1200 feet would not count toward this road density and 

therefore this analysis would be more conservative approach. 

The DEIS discloses in Chapter 3 the direct, indirect and cumulative 

effects on wildlife for this project using the measurement index of 

percent change in productive old-growth. Road densities and 

landscape connectivity were considered. Forest Plan standard and 

guidelines were specifically applied to the project area and proposed 

activities. Chapter 3 discusses the methods of analysis used for this 

project and the rationale for that method (discussion expanded in 

FEIS), including defining analysis boundaries and species were 

evaluated for further detailed analysis. Over two years of site-specific 

field resource inventory data was collected for this project and used to 

complete the project specific analysis. 

This document does tier to the Forest Plan. The Forest Plan sets the 

stage for how we address issues. Scientific resources and literatures 

were used and cited in this analysis. Please refer to the literature cited 

in the Wildlife section of the DEIS and in the literature cited section of 

the Wildlife Resource Report. 

See also Wolf/Road Densities in this section. 

DR-6, DR-7

Commenter would like wildlife retention areas to be incorporated 

into this Project. 

Response: 

Retention was provided by Forest Plan Sag’s, OGRs (small OGRs in 

each VCU), silviculture prescriptions in various units (see Unit Cards 

in Appendix B of the DEIS, as well as Alternative Maps in Chapter 2), 

and travel corridors. Proposed units were evaluated by conducting 

Alaska Department of Fish and Game (ADF&G) “Quick Cruise” plots 

with in the project area which evaluated the quality of available 

vegetative habitat within the project. In consideration of additional 

landscape connectivity within the project area and deer habitat, units 

with the highest scores were either dropped from the proposed action 

or prescribed with partial harvest. 

Specifically for the proposed action, Units 271, 272, and 314 were 

Wildlife 

Retention 

76 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
dropped for connectivity and a portion of 273 was dropped as well. 

Unit 315 was prescribed for 50 percent retention. 

DR-8

Commenter would like to know the number of acres of Class 6 and 

7 old-growth that are reserved for deer and moose. 

Response: 

We looked at course canopy during the initial stage of wildlife 

inventory and analysis. We did not provide this map in the DEIS 

because after initial evaluation, it was clear that the amount of coarse 

canopy within the harvest units was limited and that the majority of 

coarse canopy in the project area was mainly protected by the OldGrowth Reserve system. High volume strata looks a lot like coarse 

canopy with the inclusion of volume class 5 and steep slopes >55%. 

There was not much high volume strata being affected by proposed 

harvest and road building to make a meaningful comparison of effects 

between alternatives. In consultation with the State, we have included 

in the project record, a map of coarse canopy as well as high, medium, 

and low volume strata in the project record. 

DR-11

Analyze the effects of road building and timber harvest on the 

wildlife populations within the Project Area. 

Response: 

Open and total road densities for the project area are provided on page 

3-72 of the DEIS. It is recognized that increased road building may 

provide additional access for hunters/trappers and therefore with easier 

access, may create additional pressure in new areas. Cumulative total 

road densities for the project area, Kupreanof Island, and for 

Kupreanof/Mitkof Biogeographic Province by alternative have been 

included in the FEIS (see also response to “Wolves/Road Densities” in 

this Appendix). The Subsistence section in Chapter 3 disclosed the 

effects of the project on access to wildlife resources and potential 

changes in competition. 

Wildlife Effects 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 77 Appendix D
GP V-5, SCS VI-1 

Conduct an analysis on the full range of MIS species to be 

impacted by this project. 

Response: 

The DEIS explains the methods of analysis for this project in Chapter 

3 beginning on page 3-66. The appropriate method and level of 

analysis needed to determine potential effects are influenced by a 

number of variables, including presence of species or habitat, the 

scope and nature of the activities associated with the alternatives and 

risk that are known or expected to occur within the project. Table 3-19 

displays the screening process for those species that need further 

detailed analysis. Pages 3-68 to 3-69 discusses further the analysis that 

can be found in the Biological Evaluation (to be published in 

Appendix E of this FEIS) as well as those species that are protected by 

the Forest Plan (conservation strategy, matrix of non-development 

lands, and standards and guidelines). 

USDI-3, State WC-2, State WC-3, GP V-17

Revise maps for the FEIS to show coarse canopy, volume strata, 

and where OGRs are in relation to harvest units. 

Response: 

When initially looking at coarse canopy during the initial stage of 

wildlife inventory and analysis it was clear that the amount of coarse 

canopy within the harvest units was limited and that the majority of 

coarse canopy in the project area was protected by the old-growth 

reserve system. We also looked at high volume strata, which looks a 

lot like coarse canopy with the inclusion of volume class 5 and steep 

slopes >55%. Again when depicted on a map, there was not much high 

volume strata being affected by proposed harvest and road building to 

make a meaningful comparison of effects between alternatives. 

Volume strata (POG) is depicted in the DEIS in Figures 3-2 as well as 

Figures 2-1, 2-2, 2-3, and 2-4. POG as depicted would be affected by 

proposed activities and offers a meaningful comparison between the 

effects of alternatives. 

According to Hanley and Freiberg (2009), all SDM categories are not 

equal. They found that grouping the seven SD classes into three 

supra-classes made sense statistically for the winter seasons. They 

placed SD4H in the small tree category because it produces the highest 

amount of deer forage during winter months (if it is available). The 

second category they called medium tree, which is composed of SD4S, 

SD4N, SD5H, SD5S and SD5N. Finally the large tree group, which 

comprised SD67, produced the lowest amount of winter forage for 

Volume 

Strata/Coarse 

Canopy 

78 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
deer. These three supra-classes make up POG and this analysis shows 

that the best winter habitat is comprised of small and medium tree 

categories and the lumping of all POG into suitable habitat is 

consistent with the best science available to predict alternative effects 

on deer winter habitat. While looking at the currently available studies 

on deer in Southeast Alaska, one thing becomes evident; the categories 

that make the up medium tree class provides good deer winter habitat 

and grouping the POG together creates a conservative approach to deer 

habitat during the winter (Schoen and Kirchhoff 1990, Doer et al. 

2005, Farmer et al. 2006 and Schoen and Kirchhoff 2007 found in the 

Nature Conservancy Publication 2007). This analysis tiers to the 

Forest Plan Standards and Guidelines that require the consideration of 

Sitka black-tailed deer habitat needs as part of project analysis. As 

such, the reduction of POG habitat was used to analyze effects of all 

action alternatives. 

After consultation with the State there is now included in the project 

record for the FEIS, a map of coarse canopy as well as high, medium 

and low volume strata. This additional review of coarse canopy and 

high volume strata again supports our decision to analyze productive 

old-growth (POG) as a tool to evaluate action alternatives. 

GP V-16, OVK-3, SCS VI-12, SCS VI-13

The FEIS needs to expand the discussion dedicated to endemics 

and small mammals. 

Response: 

The DEIS in Chapter 3 discusses endemics, listing species known to 

occur in the project area and citing numerous scientific studies. A 

qualitative analysis follows in the DEIS, disclosing effects to small 

mammals from the removal of productive old-growth. The discussion 

also includes how the Forest Plan’s conservation strategy and matrix 

lands, specifically on Kupreanof Island, provides protection for 

endemics. In accordance with the Forest Plan Standards and 

Guidelines (Forest Plan 4-97 XIX), existing information was adequate 

and used to assess project-level effects both qualitatively and with the 

POG analysis. 

GP V-9

Explain what the term “vegetation treatments” as used in the 

DEIS, refers to. 

Response: 

The DEIS refers to the Project Common to all Action Alternatives 

when talking about potential vegetation treatments. This is the 

precommercial thinning or pruning designed with the wildlife biologist 

General 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 79 Appendix D
to achieve habitat enhancement for second growth management that 

could be part of stewardship contracting opportunities in the project 

area. 

GP V-15

Explain why there were no surveys, or analysis completed for the 

Marbled murrelet in association with this project, and conversely 

why Kittlitz’s murrelet was included in the DEIS. 

Response: 

Forest Plan standards and guidelines for the marbled murrelet require 

that “if nests are found during project implementation maintain a 600-

foot (circular) radius of undisturbed forest habitat surrounding 

identified murrelet nests, where available. Minimize disturbance 

activities within this buffer during the nesting season (May 1 to 

August 15). Maintain the buffer zone and monitor the site for nesting 

activity for not less than two nesting seasons after nest discovery. A 

buffer will be maintained if the nest site is active during the 

monitoring period. Buffer protection may be removed if the site 

remains inactive for two consecutive nesting seasons. It is recognized 

that nesting habitat relationships are poorly understood as well as the 

life history requirements and distribution.

The Kittlitz’s Murrelet is considered for the protection and 

maintenance of known Kittlitz’s Murrelet nesting habitats, as directed 

by Forest Plan standard and Guidelines for Sensitive Species (p. 4-

100). 

AFA-2

Commenter feels that the protections provided to wildlife are 

excessive. 

Response: 

This refers to the implementation of the Forest Plan, the conservation 

strategy, and the standards and guidelines. Decisions to consider deer 

habitat, landscape connectivity, road density considerations, legacy 

habitat, nest buffers, and old growth reserves were made in the Forest 

Plan Record of Decision (2008). This project is in compliance with the 

2008 Forest Plan. 

 

80 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Alaska Forest Association 

 

 111 Stedman Street

 Ketchikan, AK 99901 

 Phone: 907-225-6114 

 Fax: 907-225-5920 

 

February 2, 2008 

Chris Savage 

Petersburg District Ranger 

Attn: Central Kupreanof Timber Harvest 

USDA Forest Service 

PO Box 1328 

Petersburg, AK 99983 

Kupreanof comments 

1. A rough appraisal of your proposed action alternative (#2) indicates a purchaser would lose $86 per mbf if the sale 

were purchased at base rates. This loss could be reduced to $74 per mbf if all of the helicopter volume were 

dropped. The proposed 3 mmbf is too little volume to justify mobilizing a helicopter operation anyway. 

2. Alternative #4 appraises only $48 per mbf below breakeven, so it seems to make more sense to work from 

alternative #4. Still, a lot of change will be needed to make this a viable timber sale. 

3. The wildlife habitat remarks we made for the Logjam DEIS comments are applicable for this project as well: 

a. Increased logging in the area will increase the amount of browse and allow deer populations to increase. 

The deer can survive even harsh winters because of all the many stream buffers and other reserves where 

the snows will be less deep than in the open. The increased browse extends into these buffers and reserves 

and thus further improves the deer winter habitat. Further, the young-growth stands on the hillsides 

provide deer winter habitat after about 30 years. There are many such stands in the area. 

b. The wildlife in the area do not need “travel corridors”; they normally utilize the roads for travel, even 

when the “corridors” are available. 

c. Subsistence hunters will benefit from the improved deer habitat and the improved access provided by the 

roads – even after the roads are closed. 

d. The closed canopy concerns about deer are often greatly exaggerated. Most 30 to 40-year old younggrowth stands show significant deer use, even in the winter. Often the deer will winter in older timber 

above the young-growth stands. This is particularly the case in east, south and west facing slopes. There is 

often less browse in the older young-growth (more than 40-years old), but that is more than offset by the 

increased browse on steep hillsides and along the harvest boundaries where the sunlight can reach to the 

forest floor. Once the young-growth timber reaches maturity (about 100-years), it should be harvested 

again and the cycle of improved deer habitat will repeat. If logging is not allowed to continue, then the 

deer habitat will gradually decline to the pre-harvest levels and that would be sad. 

e. The deer habitat model doesn’t seem to work. I think the Forest Service should contract with an unbiased 

third-party to develop a reliable, accurate deer habitat model. 

f. Wolf and marten populations can best be maintained through the State hunting and trapping rules, not 

through limiting the amount of access roads. 

g. The Legacy habitat guidelines are unnecessary. A better conservation strategy would be to set aside some 

untouched areas and fully manage the rest of the forest. The Legacy guidelines also result in much higher 

logging costs, much slower regrowth and the trees left standing in the harvest areas create additional 

hazards for our workers. People’s safety is much more important than this questionable habitat strategy. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 81 Appendix D
h. Birds know how to build nests. It is not necessary to leave trees and buffers to protect the nests, because if 

a nest is lost, the birds will construct a new one! 

i. Squirrel populations are not threatened by the minimal amount of logging that has been allowed on the 

Tongass. Remember, we have harvested only about 8% of the commercial timberland and 4% of the total 

timberland on the Tongass in the last 100 years. 

j. Grouse populations appear to have increased in the 30-years I have been working in the Tongass. The 

increased hunting pressure mentioned in the DEIS can be managed through the State hunting regulations. 

k. The Old-Growth Reserves, travel corridors and beach fringes are unnecessary in a forest where 92% of the 

original old-growth forest remains untouched and much of it is in congressionally protected status. Several 

agency biologists admit privately that all of these wildlife habitat protections are unnecessary, but the 

biologists don’t want to “give-up” the additional protections and, since they are paid by the government, 

they don’t really care about the economic consequences of the protectionist excesses that are borne 

primarily by the people working for private industry. 

4. The modest decline in industry employment indicated on page 3-11 ignores the enormous decline that the industry 

has endured since 1990 when the volume of timber under contract began to plummet. The decline in employment is 

due to a lack of economic timber supply, nothing else. 

5. We are not worried about impacts on the inventoried roadless areas in the project area because there are very large 

congressionally designated roadless and wilderness areas a short distance north, south, east and west of the project 

area. 

6. Page A-15 includes a statement that “The goal for Pool 3, volume under contract, is to maintain timber volume at 

approximately three times the amount of annual projected harvest. This allows the purchasers to have a continuous 

supply of timber volume available for harvest so they can plan their operations and be flexible to allow for weather 

conditions and market fluctuations” The goal should be to provide a three-year supply of timber under contract that 

would allow the industry to achieve its goal of becoming full-integrated, sustainable and competitive again. Our 

goal requires a lot more than 66.4 mmbf of timber annually. If the Forest Service establishes a low goal and 

performs at or below that level, then their goal becomes a self-fulfilling prophesy. 

7. In your conclusion on page A-20 & 21, please also acknowledge that the Secretary of Agriculture also established a 

goal of restoring a fully-integrated manufacturing industry on the Tongass. 

8. The Forest Service must take care to carefully balance the impacts of their decisions on various multiple-use goals 

including recreation, environmental protection and providing a timber supply. This requirement is particularly true 

in Southeast Alaska where the agency has monopoly control over the timber supply. Providing an adequate supply 

of economic timber cannot be ignored simply because there may be an adverse impact on another goal. 

9. The Forest Service 2008 land management plan indicates that there are 26,437 acres of commercial old-growth 

timber in VCUs 4260, 4271, 4290, 4360 & 4380 (wherein resides the Kupreanof sale area). Further, the agency has 

provided an economic analysis (the TETRA TECH analysis) of the timber base in the land management plan. That 

analysis indicates that there are only 8,455 acres of positive value (economic timber) acres within these VCUs. 

With this many positive value acres, it should be possible to design an economically positive (profitable) timber 

sale with as much as 200 million board feet of volume. 

10. We have provided critiques of both the Annual Market Demand and the longer term demand analysis that the 

Forest Service relies upon in Appendix A. Those critiques demonstrate significant logic and assumption errors in 

both of the demand procedures the Forest Service is using. We can provide the critiques again if you have lost 

them. In summary, the critiques support our contention that the Forest Service is grossly understating the demand 

for Tongass timber. 

We have not had time to analyze every cutting unit in the DEIS, but we will provide more detailed information as we 

develop it. Meanwhile, here are our initial detailed comments. 

1. Units 222, 223 and 224 should be dropped due to the high cost of constructing roads into these units. 

2. Units 241, 243, 246 and 248 should be enlarged. 

3. In units 261 and 262 we recommend you drop the helicopter volume and expand the cable logging. 

4. We recommend you enlarge unit 265. 

82 

5. We recommend you drop the helicopter portion of unit 266 and expand the cable portion. ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
6. We recommend you drop units 267, 268 and 269, along with road #45895 and make up the volume along the 

45803 road. 

7. We recommend you enlarge units 270 and 272. 

8. We recommend you add a unit between units 274 and 275. 

9. We recommend you drop units 274-277 because of the poor volume recovery per mile of road. 

10. We recommend you drop units 279-281 because of the poor volume recovery per mile of road. 

We are willing to sit down with your team and discuss ways to improve the economics of this timber sale – just let us 

know where and when. 

Thank you for the opportunity to comment. 

Sincerely, 

Owen Graham 

Executive Director 

Alaska Forest Association 

111 Stedman Suite 200 

Ketchikan, AK 99901 

Phone 907-225-6114 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 83 Appendix D
Purpose and Need

Among the purposes cited for the Central Kupreanof Timber Harvest, this planning effort 

is purported to, "Manage the timber...in an economically efficient manner." ; and, "... 

seek to provide a timber supply sufficient to meet the annual market demand for 

Tongass National Forest timber and the market demand for the planning cycle."

There is every reason to doubt the validity of these claims of purpose given the backlog 

of recently offered timber sales which remain unsold and on the shelves. According to 

timber industry representatives, such sales are repeatedly described as "uneconomic". 

In the past, USFS timber planners have claimed proportionality rules are to blame. 

Whether or not proportionality rules are a valid excuse as to why the USFS plans 

"uneconomic" timber sales, if only those sales (or portions thereof which target high 

volume old-growth stands) dominate that which does get sold, an end-run and loopholeenabling process will have been once again, achieved by this agency.

The timber planning and sale offering process as practiced is subverting those 

proportionality rules. 

The USFS is adept at inverting the economic logic which, in any other industry, would 

spell that industry's economic demise. All the while, the inverted logic of piecemeal 

deconstruction of the rarest, and highest value areas essential to ecosystem integrity on 

the Tongass continues. This has an undeniable and inescapable history of socioeconomic policy failure in the larger sense of national forest mismanagement and 

ultimately impoverishes the same rural residents which the extremely short term 

benefits resulting from "development" is purportedly going to benefit.

Given the fact that over a billion dollars of timber subsidies on the Tongass have been 

dedicated to this supposed "industry" which currently represents less than 1% of the 

regional economy underscores the fact that this agency and its planning efforts on the 

Tongass has accomplished the exact opposite of what constitutes an "economically 

efficient manner" of timber-at-all-costs planning.

With the present and near future state of the global, national, and regional economies 

imperiled by business as usual practices; commodities markets in shambles; and the 

outlook of severe recession, if not depression in the current planning cycle, such 

standard USFS "Purpose and Need" rhetoric belies these market realities. 

The notion that this timber sale will, "Provide for a diversity of opportunities for resource 

uses that contribute to the local and regional economies..." remains unsupported by any 

facts. If anything, the available facts demonstrate the opposite conclusion.

The most recent evaluation of the state of Alaska's economic policies (Alaska Economic 

Performance Report 2007, released, Sept.08) point out the state also has spent far 

more than it has received in revenues generated by the timber industry sector. Given 

84 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
the amount of unsold timber remaining on the shelves, there is simply no basis for the 

claim that this timber sale will provide for "a diversity of opportunities" which don't 

already exist on the Tongass.

There has been no commensurate basis for the claim, "There was local interest in 

timber sale opportunities" (Appendix A.3), especially to the extent that justifies a set of 

proposed actions which in aggregate represent of 87 mmbf., close to 31 miles of 

additional logging roads and over 4500 more acres of clearcuts in proximity to areas 

already heavily impacted by native corporate logging. The project area in its 

undeveloped state already possesses a naturally fragmented landscape highly 

vulnerable to connectivity issues resulting from timber harvest and road building.

Significant Issues Overlooked

As one of the few commenting members of the public who has a historic and ongoing 

awareness of commercial crab fishing activities and the crab resource in Hamilton Bay, 

I'd like to pass on the following observations.

Absent in the DEIS discussion on Significant Issues is the very significant issue of 

cumulative, historical and near-future impacts to the estuary and marine habitat of 

Hamilton Bay, which has been heavily impacted by past timber harvest and LTF 

activities. These activities do not have impacts limited to the confines of the LTF 

boundaries. 

These impacts extend far beyond the confines of the LTF boundaries as designated, 

and thus require far more consideration than a cursory mentioning in the DEIS. Issues 

of habitat degradation associated with Hamilton Bay LTF have been raised in the past 

and it is surprising these concerns were not being carried forward into this DEIS.

There are many benthic and sub-tidal areas of Hamilton Bay demonstrating anoxic 

conditions of degraded mud substrates typical of bottoms receiving pulses of organic 

debris deposition. This has resulted in observable and dramatic population declines of 

dungeness crab accompanied by a high incidence of diseased crab typical of exposure 

to anoxic mud. Such evidence includes crab with ulcerating lesions, weak, lethargic 

skipmolt crab often encrusted with barnacles and/or heavy algal or other epibiont 

growth; heavily discolored shell abdomens; obviously affected egg clusters; and 

chemically-burnt, missing, or necrotic dactyls resulting from walking across mud 

bottoms with low pH and a mud which reeks of the smell of rotten eggs.

Dive surveys which ascertain "recovery" of benthic and subtidal habitat within LTF 

boundaries on the basis of measurements of bark depth alone, as the primary indicator 

of substrate habitability, are absurdly simplistic given the degree to which crab are being 

affected by physical contact with bottoms exhibiting no evidence of bark. Without an 

understanding of dissolved oxygen or pH as a function of habitability of substrate the 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 85 Appendix D
commercially valuable dungeness crab exist in, bark depth measurements reveal very 

little.

The other assumption around the effects of LTF-associated organic deposition is that 

somehow, in an area known for >20 ft. tidal exchanges occurring within a 6 hour time 

period, to say nothing of freshwater flow inputs, that there would be no tidal current 

effect on the further distribution of toxic substrates generated by LTF activity and timber 

harvest. This, nevertheless, is the case and demonstrates a failure in the environmental 

analysis of the effects of this timber sale.

In the absence of sufficient evidence demonstrating there are no significant impacts 

associated with in-water storage and transportation of log bundles, it is incumbent upon 

this agency to restrict LTF activities to barges only, should any timber harvest activity 

occur as a result of this planning effort. 

Impacts resulting from seasonal ingress/egress of harvested timber within Hamilton Bay 

during the 4 month commercial season of dungeness crab fishing have also been 

overlooked. Log rafts are particularly problematic to the existing commercial fishing 

activities resulting in expensive gear replacement and lost fishing opportunities.

Incorporating a biological assessment of the marine habitat of Hamilton Bay within the 

effects of this timber sale is the only way to understand whether deleterious impacts 

have occurred up to this point. Failure to establish baseline ecological indicators of 

habitat health, species distribution, abundance and diversity are representative of a 

flawed EIS assessment of impacts associated with timber harvest. 

Effects of Project on Recreation, and Tourism

The vastly more important tourism component of the regional economy is being 

threatened as this agency makes further incursions into inventoried roadless areas in 

proximity to popular tourist destinations such as Rocky Pass, the Big John Bay trail and 

Cabin.

The expense of long distances traveled to exotic locations such as the Tongass' coastal 

temperate rainforest becomes harder to justify when the same devastated landscapes 

of the lower 48 become virtually identical to what those tourists encounter on many 

landscapes of the Tongass.

Localized, ecologically destructive impacts resulting from this project fall upon 

Kupreanof Island residents and tourism dependent businesses by undermining the 

island's desirability as a tourist destination.

I have serious concerns for the validity of a final decision whether to harvest timber 

based upon the information that is disclosed in this environmental impact statement 

which, in its draft form, falls far short of the obligations of the Supervisor to fully review 

the full scale of impacts of the Central Kupreanof Timber Sale.

86 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Pre-commercial Thinning Waste Streams

There has been very little, if any, science conducted on the ecological implications of 

diverting woody biomass waste streams away from clearcut sites on the Tongass. Such 

a diversion represents a significant development on the Tongass National Forest which 

in itself requires a NEPA review. 

Soils are dependent upon those same materials for nutrient recycling and the same 

woody biomass has been shown to be important in maintaining small mammal 

populations in forest understory elsewhere.

Thank you for this opportunity to comment.

David Beebe

P.O. Box 148

Petersburg

AK 99833

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 87 Appendix D
United States Department of the Interior 

OFFICE OF THE SECRETARY 

Office of Environmental Policy and Compliance 

1689 C Street, Room 119 

Anchorage, Alaska 99501-5126

9043.1 January 29, 2009 

ER08/1280 

PEP/ANC 

Mr. Chris Savage 

District Ranger 

Petersburg Ranger District 

P.O. Box 1328 

Petersburg, Alaska 99833 

Dear Mr. Savage: 

The U.S. Department of the Interior has reviewed the November 2008 Draft 

Environmental Impact Statement (EIS) for the Central Kupreanof Timber Harvest 

project. The Draft EIS evaluates three action alternatives which provide various 

combinations of resource outputs and spatial locations of harvest units on Kupreanof 

Island, Petersburg Ranger District. The project proposes to harvest 28.2 to 70.2 million 

board feet (MMBF) of timber from 1,327 to 3,647 acres, construct up to 25.1 miles of 

new National Forest System roads and 6.1 miles of temporary roads, and reconstruct up 

to 9.1 miles of existing system roads. The harvested timber would be hauled to the 

existing permitted log transfer facility at Hamilton Bay. 

We request that the following comments be taken into account in the Final EIS. These 

comments are submitted in accordance with the National Environmental Policy Act, Fish 

and Wildlife Coordination Act, and the Council on Environmental Quality guidance for 

providing technical expertise on water, biological, and geological resources. 

If you have questions concerning our comments, or if we may be of further assistance 

with regard to trust resource information, please contact Mr. Bill Hanson, Juneau Fish 

and Wildlife Field Office Supervisor, at 907-780-1170. 

Sincerely, 

Pamela Bergmann 

Regional Environmental Officer – Alaska 

Attachment 

Page 1 of 3 

88 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
ATTACHMENT 

GENERAL COMMENTS

Threatened and Endangered Species. We concur with the statement in the Draft EIS that 

no threatened or endangered species under our jurisdiction exist in the project area. 

Queen Charlotte Goshawk. Goshawks have a high probability of occurring in the project 

area, with potential for measurable effects to the population in the analysis area (Chapter 

3, page 69). Surveys detected unspecified “raptor” nests, which have been buffered as 

required by the current forest plan (Chapter 3, page 67). Current forest plan standards and 

guidelines (USDA Forest Service, 2008) require maintenance of an area of not less than 

100 acres of productive old growth forest generally centered over identified or probable 

goshawk nest trees. Research on Queen Charlotte goshawks in British Columbia has 

documented post-fledging areas of up to 230 hectares (568 acres) (McClaren et al. 2005). 

We recommend that 500 acres of old forest habitat be retained around all known nest 

stands and that this be specified in the Final EIS. 

Effective management of goshawk nesting habitat depends on the knowledge of nest 

locations. Many goshawk pairs do not nest every year, and often use alternate nest 

locations in subsequent years. To reduce the risk that nest stands in the project area that 

were inactive during the recent survey would be inadvertently impacted by logging, we 

recommend that additional goshawk nest surveys be conducted, with the results included 

in the Final EIS; and that the surveys be continued on an annual basis. 

SPECIFIC COMMENTS

Chapter 2, Pages 20-22, Figures 2-2, 2-3, and 2-4: The volume strata (high, medium, and 

low) used for determining forest structure (coarse canopy, etc.) in the project area appear 

to have been combined and displayed as “productive old-growth” in the maps for all 

action alternatives (Figures 2-2, 2-3, and 2-4). It is difficult to determine the exact 

location of the high, medium, and low volume strata relative to the proposed harvest 

units. Therefore, the volume strata need to be displayed as high, medium, and low in the 

Final EIS maps and unit cards to more accurately and completely display the effects. 

Chapter 3, Page 40: The Draft EIS states that the Little Hamilton Bay Log Transfer 

Facility (LTF) is a steel piling and concrete dock facility. It also states that the LTF 

would be used to barge or raft the logs to the mill. The Draft EIS (page 3-104) states 

that the waters adjacent to the Little Hamilton Bay LTF, including the log storage area, 

were placed on the Section 303(d) list of impaired waters in 1996 due to the deposition of 

bark and woody debris as a result of logging operations. These waters have since been 

removed from the Section 303(d) list in 2002/2003. A dive survey done in June 2002 

found that the bay was in compliance with water quality standards for residues. 

However, the storage of up to 70 MMBF of timber has the potential to again exceed the 

residues standard. Therefore, we believe it is important that logs be barged from this 

LTF, and note that barging was identified as an option in the Draft EIS. The use of a 

Page 2 of 3 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 89 Appendix D
Page 3 of 3 

barge would eliminate the deposition of additional bark and woody debris. We believe 

this issue needs to be addressed in the Final EIS. 

Chapter 3, Page 69: We believe that potential effects to bald eagles need to be analyzed 

in the Final EIS. Bald eagles, their eggs, and their nests are protected by the Bald and 

Golden Eagle Protection Act and by the Migratory Bird Treaty Act. Eagles can be 

sensitive to habitat alterations and disruptive activities near their nests, leading, in some 

cases, to nest abandonment, mortality of eggs or young, or destruction of a nest. To help 

land managers and others avoid causing such impacts, USFWS has developed guidelines 

for management of nest sites. The National Bald Eagle Management Guidelines may be 

downloaded at the following internet site: 

http://www.fws.gov/migratorybirds/issues/BaldEagle/NationalBaldEagleManagement

Guidelines.pdf

Chapter 3, page 101: The USFS has conducted road condition surveys to assess whether 

road crossing structures provide unimpeded passage for fish (Draft EIS Chapter 3, page 

101, USDA Forest Service, 2001). Based on the road condition information provided in 

Appendix B-Road Cards, we recommend installation of bridges rather than culverts to 

ensure unimpeded juvenile fish passage and minimize maintenance at the following 

locations: 

 Stream crossings on Roads 45808 and 45897 with gradients of 6-15% and 18%. 

 Stream crossings at mileposts 1.44, 1.58, and 1.98 of Road 45897, where channel 

incision depths would require substantial fill for the placement of culverts. 

 The 48 inch culvert proposed for the alluvial fan channel type at mile 2.83 of 

Road 45897, which may be susceptible to blockage by woody debris and bedload 

material. 

We further recommend that this information be included in the Final EIS. 

REFERENCES

McClaren, E. L., P. L. Kennedy, and D. D. Doyle. 2005. Northern goshawk (Accipiter 

gentilis laingi) post-fledging areas on Vancouver Island, British Columbia. 

Journal of Raptor Research 39:253-263. 

USDA Forest Service. 2001. Aquatic Habitat Management Handbook. U.S. Forest 

Service. Alaska Region: FSH 2090.21. 

USDA Forest Service. 2008. Tongass Land and Resource Management Plan Final EIS. 

R10-MB-603f. 

Woodbridge, B., and C. D. Hargis. 2006. Northern goshawk inventory and monitoring 

technical guide. USDA Forest Service, Washington Office, Gen. Tech. Rep WO-71. 84 

pp. 

90 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
February 02, 2009 

Reply to 

Attn Of: ETPA-088 Ref: 06-083-AFS 

Forrest Cole, Forest Supervisor 

Tongass National Forest 

Federal Building 

Ketchikan, AK 99901 

Dear Mr. Cole: 

 The U.S. Environmental Protection Agency (EPA) has reviewed the draft Environmental 

Impact Statement (DEIS) for the proposed Central Kupreanof Timber Sale on Kupreanof 

Island, Petersburg Ranger District, Tongass National Forest, in southeast Alaska 

(CEQ No. 20080513). Our review has been conducted in accordance with our responsibilities 

under the National Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act. 

 The DEIS analyzes four alternatives including the no action alternative (Alternative 1) and 

the proposed action (Alternative 2) based on timber harvest in the Central Kupreanof project area 

on Kupreanof Island. Alternative 2 proposes harvest of 46.8 million board feet (mmb) on 2,506 

acres, up to 7.3 miles of new roads and up to 3.9 miles of temporary roads, 4 additional Class I 

road crossings, and 434 acres of harvest within inventoried roadless areas (IRA). The 

silviculture treatments include 2,063 acres of clear cut and 2,427 acres of old growth harvest. 

The harvested timber would be transferred to the existing Little Hamilton log transfer facility 

(LTF). The decision on whether or not to harvest timber from this area, and if so, the manner in 

which it should be harvested, will be made by the Tongass Forest Supervisor in accordance with 

Forest Plan goals, objectives, and desired conditions. 

The EIS does a good job discussing the issues of concern, illustrating harvest units by 

providing unit card figures (Appendix B), and explaining the relationship to other applicable 

laws including tiering from the 2008 Forest Plan. We believe that the alternatives strive to 

respond to the significant issues associated with the project and we understand the need to 

balance forest economics with resource protection. Alternative 2 balances economics and 

resource protection and appears to have a moderate amount of potential environmental impacts. 

Alternative 3 has the greatest potential impacts and Alternative 4 has the least potential impacts. 

 Due to concerns about potential impacts to essential fish habitat and water quality from 

increased harvest activities, we have given a rating of EC-2 (Environmental Concerns - 

Insufficient Information) to this project. An explanation of the EPA rating system and detailed 

comments are attached to this letter. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 91 Appendix D
2

In general, we request that the Forest Service employ the following recommendations in the 

Final EIS and Record of Decision for the Central Kupreanof Timber Sale: 

 Minimize or avoid construction of new roads. 

 Reconsider alternate extraction methods and minimize ground-based extraction where 

feasible. 

 Consider methods other than even-aged treatment (clearcut), particularly in the 

Scenic Viewshed LUD and in sensitive watersheds. 

 Develop monitoring plans, including in-stream measures of water quality. 

 Protect biological diversity, especially that of critical habitat or unique vegetation. 

 Prohibit activities in areas where high hazard/high mass movement index soils are 

present, or in watersheds identified as most sensitive. 

Thank you for the opportunity to comment on this draft EIS. If you would like to discuss our 

comments, please contact Lynne McWhorter at (206) 553-0205 or by electronic mail at 

mcwhorter.lynne@epa.gov or me at (206) 553-1601. 

 Sincerely, 

 /s/ 

 Christine Reichgott, Manager 

 NEPA Review Unit 

92 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Attachment 1 

EPA Comments on Kupreanof Timber Sale, Tongass National Forest, DEIS 

Water Quality

 The EIS states that direct effects may include localized increase in annual water yield, 

increased peak flows, and altered timing of water delivery in streams from harvest activities. 

Harvest activities include clear cut of 266 acres on soils rated as high hazard for mass movement. 

Although, BMPs will be used to minimize adverse effects including stream buffers, these 

activities can introduce sediments to stream systems and alter thermal processes, consequently 

degrading water quality, and impacting fish and their habitat. We support the required stream 

buffers and minimizing road construction, clear cut prescriptions, and harvesting areas with high 

landslide potential. 

 Section 303(d) of the Clean Water Act (CWA) requires identification of those 

waterbodies which are not meeting or not likely to meet State water quality standards. The EIS 

states that Hamilton Bay was placed on the 303(d) list of impaired water bodies for debris from 

log transferring activities in 1996 and we are pleased to see that surveys resulted in the removal 

from the list in 2002/2003. The EIS discusses that barging logs would have less effect on marine 

species versus rafting logs, which can diminish habitat for managed marines species and their 

prey due to bark accumulation. It is not clear which transportation mechanism will be used for 

what quantity of logs. We support barging logs and avoiding impacts to marine species and 

recommend clarifying how much of the harvest timber will be transported by which mechanism 

in a separate section and including a figure illustrating the transportation route in marine waters. 

 Antidegradation provisions of the CWA apply to those water bodies where water quality 

standards are currently being met. This provision prohibits degrading the water quality unless an 

analysis shows that important economic and social development necessitates degrading water 

quality. The EIS should explain how the antidegradation provisions would be met for the 

proposed project. 

Essential Fish Habitat 

The project area includes federally managed species of pink, chum, coho, and sockeye as 

well as populations of Dolly Varden, cutthroat trout, and steelhead. Streams on the Tongass 

National Forest are divided into value classes from I to IV indicating levels of habitat use by fish 

populations. Class I indicates streams with high fishery habitat values and there are 369 miles of 

Class I streams in the project area. The EIS states that increased sediment delivery to streams 

during construction activities may affect individual fish by reducing oxygen levels to developing 

eggs in spawning gravels and/or trapping emerging fry in the gravel, but the effect is expected to 

be short-term (48 hours or less) and the use of seasonal timing restrictions will minimize impacts 

to fish. In addition to protecting high value habitat, another key component of protecting fish 

populations is culverts that allow for fish passage. The EIS states that there are 61 fish crossing 

characterized as red (high certainty of not providing juvenile fish passage at all desired stream 

flows). The risk of sediment delivery to streams is higher at road crossings and increases the 

potential for culverts to become plugged with sediment and debris. The proposal includes the 

addition of two culverts and replacement of two culverts in Class I streams and the removal of 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 93 Appendix D
2

one red culvert within 10 years of timber harvest. We support the Forest Service analysis and 

characterization of streams and planning efforts to protect aquatic resources. However, we 

believe that Alternative 4 more adequately protects aquatic resources by minimizing additional 

roads and increasing the removal or modification of more that one red culvert. 

Log Transfer Facility 

The EIS states that the LTF is still operating under a valid National Pollutant Discharge 

Elimination System permit (NPDES). On October 31, 2008, the Environmental Protection 

Agency (EPA) formally approved the state’s NPDES Program application. The state’s approved 

program will be called the Alaska Pollutant Discharge Elimination System (APDES) Program. 

We recommend that the final EIS include a discussion of this shift and whether or not this may 

affect the current NPDES permit. 

Habitat 

 The project area includes four old growth areas and the proposed project includes harvest 

of 2,427 acres of old growth habitat in three of the reserves. The EIS does a good job explaining 

the resource analysis area for wildlife through the use of biogeographic povinces (BP), which are 

geographic areas defined by the Alaska Department of Fish and Game to manage wildlife 

populations. This analysis tiers to the productive old growth (POG) forest habitat in the Forest 

Plan. The EIS states that there would be a reduction of approximately 4.2 percent POG in the 

project area and should not have adverse effects on wildlife. The EIS also includes a cumulative 

effect analysis of private land adjacent to Forest Service land and states that intensive harvest in 

the past occurred on these lands. We support the analysis and minimizing harvest of old growth 

stands that support wildlife populations. In particular we recommend maintaining legacy 

characteristics and not conducting even age stand cuts in POG areas. We also recommend that 

the EIS discuss any agreements that the Forest Service has with private land owners to promote 

stewardship or opportunities for agreements so that watershed function and habitat can be 

maintained across the landscape. 

Invasive Species

 Invasive species can aggressively spread into areas altered by road construction and harvest 

activities. Nationally, as well as in Alaska, the establishment of invasive nuisance species has 

rapidly become an issue of environmental and economic significance. EPA strongly supports 

weed control and management during and after harvest activities. The EIS should provide a 

discussion to comply with the Executive Order (EO 13112) on invasive species. The status of 

noxious weed projects in the project area should be described, and weed monitoring and control 

features should be identified. 

Monitoring

 As discussed above, the proposed project has the potential to impact water quality, fish, and 

habitat. Predicting the severity of these impacts and devising effective mitigation measures 

remains an imprecise science. Monitoring is a necessary and crucial element in identifying and 

understanding the consequences of actions. In this case, monitoring is needed to evaluate 

compliance with the Forest Plan and effectiveness of Best Management Practices. The EIS 

discusses monitoring and refers to the Forest Plan as well as the BMPs associated with the unit 

cards in Appendix B. However, we believe that the EIS does not include an appropriate level of 

detail about the proposed monitoring plan. Clear monitoring goals and objectives should be 

identified such as what questions are to be answered; what parameters are to monitored; where 

94 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
3

and when monitoring will take place; who will be responsible; how the information will be 

evaluated; what actions (contingencies, adaptive management, corrections to future actions) will 

be taken based on the information; and how the public can get information on mitigation 

effectiveness and monitoring results. We recommend that general components from the 

monitoring plan be included such as how monitoring is conducted and frequency. We also 

recommend that a discussion of the results of past monitoring efforts in the project area and how 

they affected management direction be explained in order to understand the accuracy of past 

predictions and success of monitoring efforts. . 

Climate change 

Currently, there are concerns that continued increases in greenhouse gas emissions 

resulting from human activities contribute to climate change. Effects of climate change may 

include changes in hydrology, sea level, weather patterns, precipitation rates, and chemical 

reaction rates. The EIS states that climate change is not essential for a reasonable choice among 

alternatives considered in this analysis. EPA believes that the cumulative effects analysis in the 

NEPA document should include changes to resources that can reasonably be anticipated due to 

climate change that may have bearing on aspects of the project (e.g. changes in hydrology that 

may affect siting of roads or sizing of culverts). Therefore, we recommend that the EIS consider 

how resources affected by climate change could potentially influence the proposed project and 

vice versa, especially within sensitive areas. 

Consultation with Tribal Governments

 The EIS states that the Forest Service consulted with the Organized Village of Kake 

(OVK) and the Wrangell Cooperative Association (WCA), the tribal groups that are culturally 

affiliated with the project area. We appreciate the inclusion of the discussion of government to 

government consultation and we support activities that minimize impacts to the area’s Native 

Alaskan communities. If continuing government-to-government dialog with potentially 

impacted Tribes reveals that the proposed project will have impacts on traditional resources of 

Alaska Native Tribes or their members, the final EIS should clearly specify which resources will 

be impacted and what mitigation measures will be included to minimize impacts. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 95 Appendix D
· Greenpeace · Cascadia Wildlands Project · Juneau Group of the Sierra Club ·

· Natural Resources Defense Council · Eric Lee · Becky Knight · Dave Beebe ·

February 2, 2009 

Chris Savage, Petersburg Dist. Ranger 

ATTN: Central Kupreanof Timber Harvest 

Box 1328 

Petersburg, Ak 99833 

Submitted to: comments-alaska-tongass-petersburg@fs.fed.us (Comments only) 

 ftp2.fs.fed.us/incoming/chugtong_R10/CK_Exhibs (Exhibits only) 

Subj: Comments on the Central Kupreanof Timber Sale DEIS

Dear Mr. Savage; 

These are jointly filed comments on the Central Kupreanof Timber Harvest DEIS, by 

Greenpeace, Cascadia Wildlands Project, Juneau Group of the Sierra Club, Natural 

Resources Defense Council, and three individual residents of Petersburg, Alaska: Eric Lee, 

Becky Knight, and Dave Beebe. All of the organizations have long-standing interests in 

management of the Tongass National Forest as well as the Kupreanof Island and nearby Kuiu 

Island areas in particular, as you already are aware. Becky Knight and Dave Beebe 

submitted comments on this DEIS previously, and join these comments because of 

additional topics that are covered. Please find our exhibits at the ftp address above, and add 

them to the planning record. 

We wish to begin by thanking you for using the SDM (Size-Density Model) dataset, as was 

done in the 2008 Forest Plan. This is the first Tongass project to use SDM to replace the VolStrata dataset which is unsuitable for wildlife analysis, even though several other projects 

have published NEPA documents or decisions after adoption of the Forest Plan. 

That said, SDM was not used to its best advantage in the Central Kupreanof wildlife and 

subsistence analyses, and we comment critically on those analyses. The are also deep flaws 

concerning the purpose and need for the project, the range of alternatives, and other aspects 

of the DEIS. We believe the DEIS falls far short of the requirements of NEPA and that 

substantial additional work is needed, including a Revised DEIS. 

Accordingly, we advocate adoption of Alternative 1, and request that work start over on the 

project if the Forest Service still wishes to pursue it. 

Contact Information: 

Larry Edwards Mark Rorick Eric Lee 

Greenpeace Juneau Group of the Sierra Club Box 858, Petersburg, Ak 99833 

Box 6484 1055 Mendenhall Pen. Road 907-518-0919 

Sitka, Ak 99835 Juneau, Ak 99801 oceanday2002@yahoo.com

747-7557 789-5472 

larry.edwards@greenpeace.org mprorick@alaska.net Becky Knight 

 Box 1331, Petersburg, Ak 99833 

Gabe Scott Niel Lawrence 772-9391 

Cascadia Wildland Proj. Natural Resources Defense Council bknight15@hotmail.com

Box 853 3723 Holiday Dr. 

Cordova, Ak 99574 Olympia, Wa 98501 Dave Beebe 

424-3835 360-534-9900 Box 148, Petersburg, Ak 99833 

gscott@cascwild.org nLawrence@nrdc.org 772-2270, fvjerryo@mac.com

96 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
2

Table of Contents

I. Throughout, This DEIS Fails the Requirements of NEPA in Its Glaringly Shallow 

Discussions of Important Issues, Incomplete Disclosure, and Other Faults..................... 3

II. The Project Is Contrary to the Forest Plan & TTRA, Because There Is No Foreseeable 

Market Demand for This Timber and No "Need" for the Project. ...................................... 3

III. Two of the Three Action Alternatives in the DEIS Exceed the Scope of the Project, 

Violating NEPA, and Therefore a Revised DEIS Is Necessary........................................... 4

IV. The Range of Alternatives Has Been Unreasonably Constrained, Preventing Reasonable 

Alternatives from Being Considered, in Violation of NEPA............................................... 4

V. Wildlife & Subsistence Issues, Generally. ..................................................................... 5

A. Wildlife Issues of Significance Have Been Swept Aside, Despite Clear 

Identification in Scoping Comments. .............................................................. 6

B. The DEIS Has Failed to Evaluate Project Consequences Over an Adequate 

Range of Management Indicator Species (MIS). ............................................... 7

C. The DEIS Is Overly Reliant on POG for Wildlife Analysis.................................. 7

D. The DEIS is Overly Reliant on the Biogeographic Scale for Wildlife Analysis..... 7

E. The DEIS Wildlife Section Is Inadequate in Other Ways, Too. .......................... 7

VI. The DEIS Is Contrary to the Forest Plan Because the Standard & Guideline for Providing 

Deer Habitat Capability Was Not Followed..................................................................... 8

VII. The DEIS is Contrary to NFMA Because It Fails to Adequately Evaluate Effects on Wolf 

Viability and Wide Distribution. .................................................................................... 8

A. Failure to Assure Adequate Deer Carrying Capacity to Support Wolves and Hunters.... 8

B. Failure to Adequately Analyze Wolf Mortality and Particularly Road Density. ............... 9

VIII. The DEIS is Contrary to ANILCA Because It Fails to Adequately Assess Effects on 

Habitat Carrying Capacity for Deer, a Proxy for Deer Abundance That Is Included in TLMP 

Standards & Guidelines...............................................................................................10

IX. Partial Cutting, Deer Habitat, and the Dropped Deer Alternative. ................................10

X. Deer Concerns & Other Wildlife Concerns Were Not Taken Into Account on the Unit 

Cards..........................................................................................................................11

XI. Other Wildlife Species.................................................................................................11

A. Small Mammals & Endemic Species..........................................................................12

B. Incorporation by Reference.......................................................................................12

XII. Fragmentation, Coarse Canopy Forest, Corridors, Connectivity & OGRs......................12

XIII. Fisheries & Hydrology .............................................................................................12

XIV. Roadless Areas........................................................................................................14

XV. Transportation & Roads ...........................................................................................15

XVI. A Detailed Public Investment Analysis Was Noted in Scoping As Required, and Was 

Requested But Not Provided in the DEIS. .....................................................................17

XVII. Significant Issue One: Timber Supply and Sale Economics .......................................17

XVIII. CONCLUSION........................................................................................................17

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 97 Appendix D
3

I. Throughout, This DEIS Fails the Requirements of NEPA in Its Glaringly 

Shallow Discussions of Important Issues, Incomplete Disclosure, and Other 

Faults. 

Early (2005) notes of a meeting of the Forest Service's interdisciplinary team (IDT) for this 

project indicate a clearly recognized need to "work very carefully with other state and federal 

agencies," including doing field trips with them.1 The planning record does not indicate that 

this level of cooperation was carried out by the IDT, and we believe that in general this lack 

has been detrimental to planning and analysis for the project. As one specific, when 

scheduling the fore-mentioned joint field trip proved initially to be difficult, it appears that 

the IDT simply gave up instead of pursuing other arrangements for this important field 

work.2 The joint field trip was not pursued with the diligence that careful work would entail. 

Also, evidence is very sparse in the planning record of consultation with other state and 

federal agencies, rather than showing careful work with them. Issues fairly raised by such 

agencies and the Organized Village of Kake were instead given short shrift in the DEIS and 

its supporting documents in the planning record. 

The DEIS itself is extremely shallow in its discussion of many important issues. The Wildlife 

section of Chapter 3 is only 21 pages. It avoids discussion of many species that likely would 

be affected by the project, and what analysis it does contain concerns only the percentage 

change in the amount of productive old-growth forest (POG). There are no standards and 

guidelines by which to judge the statistics of such analysis, and judging the impact of a 

project primarily on such percentages and on little else can only be expected to misinform a 

decision. Similarly, the Subsistence section of Chapter 3 is less than 7 pages long, and is 

devoid of data and meaningful analysis. And so forth, throughout this important chapter of 

the EIS. 

We can only conclude that the DEIS must be withdrawn and that if the Forest Service wishes 

to pursue the project further, it needs to start over. 

II. The Project Is Contrary to the Forest Plan & TTRA, Because There Is No 

Foreseeable Market Demand for This Timber and No "Need" for the Project. 

The purpose of the Central Kupreanof project, as disclosed by the district ranger in a radio 

story but not in the DEIS, is to put timber "on the shelf," not to meet a real need in the 

foreseeable future. 

"And I think I mean, you know, the economic conditions we're seeing right now, and especially 

the current timber market -- we just felt we'd like as much opportunity as possible to be sitting on 

the shelf, so that we have the greatest flexibility depending on what the market conditions look for 

in the near future." 3

The appraisals of the alternatives in the DEIS were based on shipment to the Silver Bay Mill 

in Wrangell. The mill has not produced more than minimal quantities of lumber in recent 

years, is presently not running, and sale of the mill has so far proven infeasible. Even if the 

mill were to restart the Forest Service substantial volumes of timber which are much closer 

 

1

 Project document 234, IDT notes of December 8, 2005. "We will work very carefully with other state 

and federal agencies. We should do field trips out there with partner agencies ..." 

2

 Project document 26, in combination with a lack in the record of documentation that a joint field 

trip was pursued further. 

3 Exhibit 1 and Exhibit 2. "Forest Service looks at logging south of Kake," KFSK Radio, Petersburg, 

12-Jan-09. The exhibits are a transcript and an audio recording, respectively. 

98 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
4

at hand to the this mill – part of the Backline and Doughnut projects on Wrangell Island, the 

Navy project on Etolin Island, and the Baht project on Zarembo Island. In addition, Alcan 

Forest Products has not logged the contract it holds on Zarembo Island, Skipping Cow, and 

that volume is conceivably available too. 

We believe that for the foreseeable future, clearly, this project is unnecessary to the quest for 

meeting market demand. We also believe the scale of the project is detrimental to the 

sustained yield of all renewable resources. For these reasons, pursuing the project is doubly 

in conflict with the Tongass Timber Reform Act (TTRA). 

III. Two of the Three Action Alternatives in the DEIS Exceed the Scope of the 

Project, Violating NEPA, and Therefore a Revised DEIS Is Necessary. 

The Purpose and Need for the project4 is broadly worded and can accommodate a much 

broader range of action alternatives than those which were analyzed in the DEIS. The 

Purpose and Need does not specify how much timber is needed from this project, nor does 

Appendix A of the DEIS demonstrate a need for the 28 to 70 mmbf from this project's action 

alternatives. Alternatives with far lower timber volumes than those – even just a microsale 

program for example – would satisfy the stated needs to manage for sawtimber and other 

wood products, to contribute toward the agency's duty to seek to meet market demand, and 

to provide a diversity of opportunities for resource uses. Viable alternatives that would do a 

far better job of meeting the Forest Service's mission and other obligations were excluded 

without valid cause from detailed consideration in the DEIS. 

The Forest Service's intended timber yield from this project has varied willy nilly, as if there 

in fact is no rationally defined purpose and need for the project. The notice for the second 

scoping for the project, in January 2008, proposed the "production of up to 40 mmbf." 

(Emph. added.) This was a reduction from an 80 mmbf maximum in the earlier scoping, in 

2006. Two of the three action alternatives in the DEIS exceed by significant amounts the 

maximum timber volume that was scoped last year. At 46.8 mmbf, the "Proposed 

Alternative" in the DEIS (Alternative 2) exceeds the scoped maximum by 18 percent, and at 

70 mmbf the "Preferred Alternative" (Alternative 3) exceeds that maximum by 75 percent. In 

addition, with unit acreages of 2,506 and 3,647 acres, respectively, Alternatives 2 and 3 

exceed the maximum acreage that was scoped for the project last year, 2,025 acres. NEPA 

requires that a DEIS "shall be prepared in accordance with the scope decided upon in the 

scoping process."5 The scope process for this project established a project scope that extends 

from the no-action alternative to the maximum timber volume and maximum acreage that 

were specified in the January 2008 scoping document. Accordingly, the Forest Service has 

violated NEPA by studying Alternatives 2 and 3 in detail and featuring them as reasonable 

alternatives in the DEIS. They must be ruled "unreasonable" and be dropped from further 

consideration. Moreover, because doing this leaves only Alternative 4, and because a DEIS 

with only one action alternative is inadequate, a Revise DEIS is necessary. 

IV. The Range of Alternatives Has Been Unreasonably Constrained, Preventing 

Reasonable Alternatives from Being Considered, in Violation of NEPA. 

 It is apparent from the planning record that the range of alternatives has been unreasonably 

constrained. Advice of the IDT Leader is contained in notes of a team meeting: 

 

4

 DEIS at 1-2. 

5

 40 CFR 1508.22(a). 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 99 Appendix D
5

"Tiffany emphasized a wide range of alternatives is very important, which does not mean a wide 

range of volume. ... be mindful of the volume to keep your alternative in the race." 6(Orig. emph.) 

Alternatives that produced lower volumes of timber were indeed dropped out of the "race," 

such as a completely roadless alternative that would have produced 18 mmbf.7 Others 

alternatives that would have low volume, to accommodate just local milling in Kake for 

example, didn't even get the tentative level of development which that alternative received. 

In early 2008 the district ranger directed that "the no-action alternative should be considered 

as a viable alternative and not just a baseline to compare action alternatives."8 We are 

pleased to see this stated explicitly, as it is consistent with NEPA, however it appears to not 

have been acted upon by the IDT. This option of no timber harvest and no road building is a 

viable, reasonable alternative which establishes the lower end of scope of the project. No 

alternative between that reasonable minimum and the scoped maximum can legitimately be 

ruled unreasonable simply because it would produce only a low volume of timber, because 

even the alternative that would produce zero is reasonable according to both the district 

ranger's directive and NEPA. Therefore, the range of alternatives in the DEIS has been 

unfairly constrained, and the DEIS in not consistent with NEPA. 

Further, in the same memo the district ranger directed the IDT to "continue to encourage the 

public and other agencies to make suggestions to modify alternatives or create their own 

alternatives." This encouragement to the public was never given by the IDT. For example, in 

the subsequent January 2008 scoping document,9 alternatives were not presented to the 

public, nor was the public encouraged to create its own. The framework of the scoping 

document was issues-focused and did not include an additional alternatives-focus. The 

public and other agencies were never invited, much less encouraged, to submit its own ideas 

for alternatives, and the implication of the scoping document was instead that the Forest 

Service would consider issues concerns in itself creating a range of alternatives. 

Nonetheless, in our scoping comments we did ask for multiple alternatives that would 

include no road construction, and multiple alternatives that would provide micro-sales to 

support the needs of Kake. No such reasonable alternatives were given any real 

consideration, yet unreasonable alternatives that out side the scope of the project got the 

emphasis and are even featured in the DEIS as the proposed and preferred alternatives. 

So, not only has the IDT directly constrained the range of alternatives in the DEIS unfairly 

and illegally, it has not followed line officer direction to pro-actively seek from the public 

other alternatives. 

Additionally, we incorporate by reference the Range of Alternatives section of the comments 

by Sitka Conservation Society and SEACC. 

V. Wildlife & Subsistence Issues, Generally. 

The wildlife section of this DEIS is superficial and fails completely to meet the Forest 

Service's duty under NEPA to take the hard look at the consequences of its actions and to 

fairly compare alternatives. Citations to scientific literature, field reviews or other sources of 

information are largely absent. There is no real analysis of impacts to specific species, just 

scanty, over-simplified analysis and unreliable conclusions. The DEIS falls far short of the 

requirements of NEPA and of providing a reasonable basis for public comment. This is yet 

 

6

 Planning document 238 (11/9/06). 

7

 Planning documents 240 (11/28/06) and 253 & 364 (12/11/06).

8

 Planning document 189, January 8, 2008, signed by District Ranger Chris Savage. 

9

 Planning document 178, request letter to the public for scoping comments. 

100 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
6

another reason, in addition those discussed earlier and below, that the Forest Service must 

withdraw this DEIS and start over with its planning, if it wishes to continue to pursue this 

project. 

A. Wildlife Issues of Significance Have Been Swept Aside, Despite Clear Identification in 

Scoping Comments.

IDT meeting notes of November 9, 2006 show that the IDT recognized that the public had 

raised issues including "deer model," "subsistence," "wildlife outside of subsistence (road 

density, goshawks, connectivity)," and cedar high-grading.10 Another document from later 

that month discloses a decision to include as one of three significant issues the effect of 

building roads and harvesting timber on deer habitat, as it relates to subsistence. 

In January 2008 the district ranger wrote a memo to the IDT to document required changes 

and set some new direction. "Based on past comments and project comments" it identifies 

deer habitat as one of two "expected issues. Concerning subsistence, the memo says road 

management and access issues will be covered by the RAP/ATM; however, those are only two 

issues related to subsistence deer hunting, and the matter of deer habitat to support 

subsistence used is covered by the fore-mentioned expected issue.11 

In March 2008 there was a "close-out" of a review of the project by the Juneau Review Team 

(JRT).12 Deer habitat and its carrying capacity were dismissed as significant issues (we 

contend wrongly, as noted elsewhere herein), and notes of an IDT meeting held a week later 

show that the team dropped all wildlife issues from consideration.13 The planning record and 

DEIS do not contain a reasonable explanation of why this was done, and we believe there can 

be no reasonable explanation of dropping this class of issues from meaningful analysis.14 

A key project document (Issue Development and Alternative Review) from April 2008 

acknowledges that even if an issue is not identified as a significant issue, the intent of the 

process is that "all (such) other issues are meaningfully addressed in the analysis."15 The 

DEIS has failed to do this. In order to excuse this, the document relies on analysis done in 

the Forest Plan, but which is not adequately site-specific, and it not adequate for a projectlevel NEPA review. The document attempted this explanation: 

"... the team felt wildlife and subsistence was really too broad in scope and pinpointed the 

concern to the effects on deer habitat. Subsistence (carried forward in terms of deer habitat), 

while concerned about deer habitat, also pointed to concerns about access that the team 

believed the ATM process would address." 16

It makes no sense, however, expect deer habitat concerns (including those of subsistence)to 

be addressed through the access issues. Moreover, the Forest Plan S&G XIV.A.2 directs that 

analysis include use of the deer model in evaluating habitat carrying capacity, and that 

means considering more the simplistic POG analysis that was done in the DEIS. 

 

10

 Planning document 238, 11/9/06: IDT meeting notes of 11/9/06. 

11

 Planning document 189 (1/8/08): "Letter of Direction for Central Kupreanof Timber Sale EIS 

(Update)," Chris Savage, District Ranger. 

12 Planning document 155, March 20, 2008. "Central Kupreanof JRT Checkpoint 2 Review Close-out" 

13

 Planning document 153, March 27, 2008. IDT meeting notes. 

14

 The analysis of wildlife issues in the DEIS is superficial, not meaningful. 

15

 Planning document 403, 4/18/08. "Central Kupreanof Timber Sales Issue Development and 

Alternative Review." 

16

 Id. at 10. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 101 Appendix D
7

The Central Kupreanof DEIS is unique on the Tongass among EIS documents to date in 

having performed a de minimis analysis of wildlife, especially so for a project of this size. 

This attempted "easy pass" for the project is inconsistent with NFMA and NEPA. For no 

species was the analysis adequate. 

B. The DEIS Has Failed to Evaluate Project Consequences Over an Adequate Range of 

Management Indicator Species (MIS).

The DEIS has not evaluated impacts of the project to the full range of MIS that can be 

expected to be in the project area. Analysis for all MIS in the area is important because 

represent numerous other species and ecological niches. Conspicuous in their absence from 

meaningful analysis in the DEIS are raptors, cavity nesting birds, small mammals, and 

endemic species. 

C. The DEIS Is Overly Reliant on POG for Wildlife Analysis.

Use of a POG model alone is clearly insufficient analysis under NEPA. While we agree that 

POG is an important measure (among others), simply running the numbers tells us little 

about, for example, habitat connectivity, localized impacts, impacts to particularly important 

places, or species-specific impacts. 

D. The DEIS is Overly Reliant on the Biogeographic Scale for Wildlife Analysis.

Over-reliance on the biogeographic province scale in wildlife and subsistence analysis (as 

done in the DEIS, and including even parts of Kuiu island) conceals the state of the current 

condition and effects of alternatives at the WAA and watershed scales. This results in a fatal 

inconsistency with NEPA over disclosure and the full and fair discussion of responsibly 

raised issues. An SDEIS is necessary to correct this deficiency. For example, wolf impacts 

are best understood at a wolf home-range scale (one or two WAAs, depending on their size. 

E. The DEIS Wildlife Section Is Inadequate in Other Ways, Too.

It is incredible that the DEIS does not include any discussion of the goshawk. 

The DEIS' consideration of wildlife is so inadequate, that a decision-maker would be left with 

the impression that the overall impact of the proposed timber sale on wildlife is positive. In 

the Direct and Indirect Effects subsection of the wildlife section, the first two sentences are: 

“Removal of stream crossings and closures of roads may benefit wildlife by limiting road densities 

and motorized human access. Vegetation treatments should benefit wildlife as it helps to restore 

side lighting to the forest floor, increasing the production of forbs and shrubs as well as well as 

helping to promote taller and denser stands of trees that can provide shelter (snow interception).” 

(DEIS at 81) 

In the first place, it is inaccurate and misleading to tout road closures as a beneficial impact 

of this timber sale, since those closures will occur under the ATM in any event. The impact 

of the action alternatives on those closures is to delay them by prolonging use of the roads, 

with of course the additive impact of building new roads. Please consider the impact of road 

building and delayed road closures on wildlife. 

It is unclear what “vegetation treatments” the DEIS is talking about, but assuming this refers 

to the proposed logging units, we are not aware of any scientific support for these 

conclusions. Cutting a pristine old-growth forest down does not “promote taller...stands of 

trees.” It certainly does make stands denser, after several decades, but that is not a beneficial 

impact for winter habitat due to the lack of undergrowth and forbs in densely packed stands. 

Please review the seminal paper on forest succession, Alaback (1982). And, “side lighting” 

does not need restoring in old-growth stands. The abundant muskegs and old-growth forest 

gaps are natural, adequate sources of light for forbs. What this sentence seems to be talking 

102 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
8

about is also known as the “edge effect,” which is commonly understood to be a negative 

impact for interior-dependent species, such as goshawks. There is no basis for citing it as a 

positive. 

VI. The DEIS Is Contrary to the Forest Plan Because the Standard & Guideline 

for Providing Deer Habitat Capability Was Not Followed. 

Notes of an early 2007 meeting of the IDT with the ADF&G Area Biologist say, 

"A reduction in deer density is a concern, because deer density is already low in Central 

Kupreanof. ... The effect of the Central Kupreanof timber sale on the already low deer 

populations is a concern because of illegal hunting pressure. ... Lowell's concerns: · road 

density – its effect on legal and illegal harvest of wildlife; · the reduction in deer carrying capacity 

due to (timber) harvest – how to make the sale economically viable without negatively affecting 

deer habitat." 17 

ADF&G is "concerned about (deer) as they pertain to wolf viability and (status) and 

subsistence hunting opportunity." These are concerns of great significance, but nonetheless 

the Forest Service decided to do a substandard analysis of the effects of this large project on 

deer in area where populations are already acknowledge to be low. 

In March 2008 a document closing out a project review by the Juneau Review Team (JRT) 

announced 

"it was decided that the real issue is not deer habitat, but tied more to Access to deer. ... It was 

agreed that Deer Habitat would not be a significant issue (considered but eliminated) and that the 

ID team would carry forward Access as a significant issue." 18

Neither the DEIS nor the planning record reflects any determination of deer carrying capacity 

by use of the deer model, as directed in Forest Plan S&G XIV.A.2. Given that the planning 

record clearly indicates that both modeled habitat capability and deer populations 

themselves are low in the project area, not ascertaining and disclosing the modeled carrying 

capacity of deer habitat is a significant deficiency in the planning work and the DEIS. Among 

timber projects of significant intended timber yield on the Tongass, the Central Kupreanof 

project is unique in not considering modeled carrying capacity, further underscoring the 

deficiency. 

VII. The DEIS is Contrary to NFMA Because It Fails to Adequately Evaluate 

Effects on Wolf Viability and Wide Distribution. 

A. Failure to Assure Adequate Deer Carrying Capacity to Support Wolves 

and Hunters. 

A Forest Plan standard and guideline (XIV.A.2) requires providing sufficient deer habitat 

capability to sustain wolf populations and provide for human deer harvest. It requires use of 

the deer model toward providing a carrying capacity of 18 deer per square mile, which is the 

generally accepted minimum, as established by best available science, for where deer are the 

primary prey of wolves. Local knowledge needs to be considered as well, under the S&G, but 

determination of carrying capacity through application of the model is a firm requirement 

and is also the only means presently available for obtaining a numeric estimate of carrying 

capacity. 

 

17

 Planning document 113 ( 1/16/07), meeting of IDT with ADF&G Area Biologist Rich Lowell. 

18

 Planning document 155 (3/20/08), "Central Kupreanof JRT Checkpoint 2 Review Close-Out." 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 103 Appendix D
9

In the DEIS, brief mention is made of that science has determined a need to provide this 

habitat capability of at least 18 deer per square mile; 19 however, the DEIS makes no mention 

of standard and guideline XIV.A.2 and it fails to follow the requirement to use the deer model 

to estimate carrying capacity. Not using the model violates: (1) the Forest Plan which directs 

that the model be used; (2) NFMA, which the Forest Plan was implementing in making that 

directive; and (3) NEPA, which requires application of the best available science, a full and 

fair discussion of all responsibly raised issues, and a hard look at impacts. Under the 

standard and guideline local knowledge must be used in concert with the modeled carrying 

capacity, not as a substitute for it. 

Moreover, carrying capacity estimates from the deer model that underlie the 2008 Forest 

Plan indicate that two of the three WAAs (wildlife analysis area) that are directly affected by 

the Central Kupreanof project have carrying capacities which, at 17 deer/sq-mile are below 

the minimum of 18.20 The third WAA21 has a carrying capacity of 19, but in aggregate the 

three WAAs score just below the minimum of 18. 

According to the science,22 prey availability on the scale of a wolf pack home range is one 

important measure, and that scale is about 100 square miles. The three directly affected 

WAAs range in size from 110 to 168 square miles, so considering them individually and in 

aggregate, as above, is appropriate. Is is also worth noting that two other WAAs23 that are 

immediately adjacent have low deer carrying capacities of 15 and 13 deer/sq-mile because, 

respectively, of past logging and natural habitat fragmentation. 

Substantial questions are unresolved about the effect of this project on prey availability and 

game availability. The DEIS is fatally deficient in not having used modeled carrying capacity 

in the analysis. This can only be corrected with a Revised DEIS. 

Concerning what was presented in the DEIS, the assessment of percent change in POG is a 

meaningless exercise for which there are no standards and which can easily lead to 

dangerous conclusions. Also, the DEIS did not present data to back up judgments that were 

made regarding deer habitat, and that does not satisfy the requirements of NEPA. 

B. Failure to Adequately Analyze Wolf Mortality and Particularly Road 

Density. 

Wolf mortality concerns that involve road density on Kupreanof Island and its biogeographc 

province have been brought to the attention of the Forest Service several times by the Alaska 

Department of Fish & Game.24 We believe this should have triggered initiation and 

development of a Wolf Habitat Management Program (WHMP) for the area, as required by 

Forest Plan S&G XIV.A.1. The DEIS is deficient because it did not include a real analysis of 

road density (also a factor in that S&G) and because analysis underlying the DEIS should 

have been done in concert with the WHMP. 

In addition, the Forest Service is required by its Forest Plan standard and guideline XIV.A to 

implement a different, Forest-wide program, along with the US Fish & Wildlife Service, "to 

assist in maintaining long-term sustainable wolf populations. This S&G has existed for over 

a decade, but has yet to be implemented to our knowledge. We believe the program is 

 

19

 DEIS at 3-71, citing Person et al. (1997). 

20

 WAAs 5030 and 5033. 

21

 WAA 5031. 

22

 Person et al. (1997), planning document 326.. 

23

 WAAs 5132 and 5135. 

24

 Planning document 113 and letters from Rich Lowell in 2004 and 2006, also in the record. 

104 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
10

necessary to the sustainability of wolf populations on the Tongass, and that not having it 

may in part be a cause for the failures regarding wolves in this DEIS. 

We submit for the planning record and for further consideration the recent paper concerning 

wolf mortality on the Tongass, Person & Russell (2008).25

Deficiency of the DEIS in regards to roads requires a Revised DEIS for correction and further 

public comment. 

VIII. The DEIS is Contrary to ANILCA Because It Fails to Adequately Assess 

Effects on Habitat Carrying Capacity for Deer, a Proxy for Deer Abundance 

That Is Included in TLMP Standards & Guidelines. 

The IDT recognized early-on that the subsistence issue consists of "two components: access 

and the opportunity to harvest subsistence resources."26 The deer model was used at that 

stage for a quartile analysis, but apparently not to determine deer carrying capacity and to 

apply the related S&G. The quartile analysis found that availability of quality winter habitat 

is so low that the top quartile of habitat is everything above an HSI of 0.29 (habitat suitability 

index) on a scale of 1.3. 27 The planning record document we reviewed says these results 

were validated by using Quick Cruise plot data; however, how this was done was not 

disclosed, and another later document shows that the creator of the Quick Cruise method 

contends that Quick Cruise is not suited to that purpose.28 Although the IDT attempted to 

drop higher quality deer habitat from the unit pool, the habitat quality is low enough that 

even lower quality habitat may have importance that was not recognized. We believe there is 

little if any deer habitat capability to spare in this project area. 

Incongruously, the Forest Service acknowledged in its "2008 Issue Sorting Table" for the 

project that the Alaska Department of Fish & Game raised concerns over deer habitat with 

respect to subsistence, yet the Forest Service concluded, without addressing the comment or 

further consultation and with scanty reasoning, that deer habitat is a non-significant issue, 

considered but eliminated.29 ADF&G is characterized in the table as saying: 

"Deer, subsistence: The project area is rated by ADF&G's Tongass Fish and Wildlife Resource 

Assessment as being of the highest sensitivity to disturbances in the 'Sensitivity to Disturbances 

of Subsistence Use Areas Map'; particularly concerned and believe of significance is the effect to 

deer habitat." 30

Accordingly, we believe there is a significant void in the subsistence analysis in this DEIS (as 

indicated here and in earlier sections concerning deer) and that clearance of the project 

under ANILCA is not supported by the analysis. A complete reconsideration of subsistence 

issues is needed, and a Revised DEIS. 

IX. Partial Cutting, Deer Habitat, and the Dropped Deer Alternative. 

Planning record documents indicate that the IDT developed a deer habitat alternative, which 

was dropped because it was deemed similar to the timber alternative, which had a 30% 

 

25

 Exhibit 4, Person & Russell (2008). "Correlates of Mortality in an Exploited Wolf Population," 

JOURNAL OF WILDLIFE MANAGEMENT 72(7):1540–1549; 2008) DOI: 10.2193/2007-520

26

 Planning document 363, November 27, 2006, "Subsistence Alternative." 

27

 Planning document 113 (1/16/07). Meeting of IDT with ADF&G Area Biologist Rich Lowell. 

28

 Planning document 135, IDT pers. comm. with Matt Kirchhoff of ADF&G. 

29

 Planning document 331 (9/1/08) at 3. 

30

 Id., at bottom of the 3rd page of the attached table. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 105 Appendix D
11

greater timber yield. How such disparate alternatives could be considered similar was not 

disclosed, and we do not believe doing this was justified. 

Further, we do not believe the deer alternative was reasonably constructed. First, the 

current carrying capacity of the area for deer was not estimated, contrary to Forest Plan S&G 

XIV.A.2. Also, the alternative included "partial harvest," apparently assuming that partial 

harvest has low impact on deer winter habitat – an assumption we challenge, given the 

prescriptions the Forest Service has been promoting. "The group looked at the relative 

highest deer habitat within the proposed units and removed these highest habitat units from 

harvest. The team then took the second highest units and applied partial harvest 

methods."31 A thorough review of best available science shows, however, that the partial 

harvest prescription contemplated will result in what are effectively small clearcuts that 

initially diminish and ultimately remove winter deer habitat.32,

33

We contend that the partial cut prescriptions considered do not protect deer winter habitat, 

contrary to the IDT's assumption. 

X. Deer Concerns & Other Wildlife Concerns Were Not Taken Into Account on 

the Unit Cards. 

In comparing the units cards to planning record document 272 ("Draft Deer Habitat 

Alternative, Winter 2008") we found that identified concerns for deer habitat in particular 

units were not reflected on the unit cards. The cards say "no concern." In particular for 

those units identified in the document as having connectivity or corridor concerns, on the 

unit cards the corridors are substantially restricted anyway, generally to less than a 300 foot 

width. While such width may allow mobility, it is still too narrow because predation 

mortality is promoted, and future blowdown may degrade the function of such narrow 

corridors. 

With but one exception34 all unit cards are labeled "no concern" for wildlife. We do not 

believe that many of the units do not raise wildlife concerns, and this leads us to question 

the adequacy of the field work, or its reporting, or the analysis that was done for the project. 

The unit cards are generally bereft of the information that is commonly reported on Tongass 

timber project unit cards and upon which we rely in our evaluation of projects and their 

alternatives. The unit cards are not of adequate quality to allow us a satisfactory opportunity 

to review the DEIS. This is yet another reason that a Revised DEIS is needed. 

XI. Other Wildlife Species. 

Surveys should have been completed and analysis completed for the marbled murrelet, a 

species which is not even mentioned in the DEIS. Incongruously, Kitzlitz's murrelet appears 

twice in the DEIS, but there is no habitat for this species in the project area. 

 

31

 Planning document 403 (4/18/08) at 12, and document 331 (9/1/08) at 2. 

32

 Exhibit 3, Ott & Juday (2002), "Canopy gap characteristics and their implications for management 

in the temperate rainforests of southeast Alaska."

33

 We caution: the Forest Service has relied on Deal (2007) and his earlier works as a basis for relying 

on partial cuts where there are deer concerns; however, these works must be interpreted with an 

understanding of the science they rely upon. In that regard, Hanley (2006) explicitly did not consider 

the effect of deep snow, which is a primary factor that contributes to the availability of deer for 

subsistence and wolves. Therefore, Deal (2007) is not as relevant as it may at first seem. 

34

 A hawk nest in Unit 232. 

106 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
12

A. Small Mammals & Endemic Species 

The cursory discussion of small and endemic species known to occur in the project area 

(DEIS 3-74 to 75) is wholly inadequate. Among the obvious indicators of concern for species 

omitted from or glossed over in the DEIS are: 

Long-tailed vole (Microtus longicaudus, previously M. coronarius) – listed as a species of 

ecological concern in West, E.W. 1991. Status Reports on selected Alaska mammals of 

ecological concern. Alaska Natural Heritage Program. Anchorage. 

Northern bog lemming (Synaptomys borealis) – “distribution ... remains poorly understood ... 

limited number of specimens.” MacDonald, S.O. and J. Cook. 2007. Mammals and 

Amphibians of Southeast Alaska. University of New Mexico. Albuquerque. 

Northern American porcupine (Erethizon dorsatum) – “Specimens are few, suggesting further 

effort is needed to clarify the distribution and status of this species in the region.” 

Macdonald and Cook (2007). 

Wolverine (Gulo gulo) – International Union for the Conservation of Nature (IUCN) listed as 

vulnerable; special concern by the Committee on the Status of Endangered Wildlife in 

Canada (COSEWIC). Wolverines in Southeast Alaska are genetically distinctive, suggesting 

limited exchange between inland populations and those in the region. Tomasik, E. and J. 

Cook. 2005. Mitochondrial phylogoegraphy and conservation genetics of wolverine (Gulo gulo) 

in northwester North America. Unpublished thesis. Idaho State University. Pocatello. 

Western toad (Bufo Boreas) – IUCN listed as near threatened; COSEWIC species of special 

concern. “There is growing concern that Alaska populations are experiencing [rapid decline]. 

Long term residents from Haines to Ketchikan have noted sharp declines.” Macdonald and 

Cook (2007). 

B. Incorporation by Reference. 

We incorporate by reference the comments by Sitka Conservation Society and SEACC on 

black bears, marten, goshawks, and endemics and small mammals. 

XII. Fragmentation, Coarse Canopy Forest, Corridors, Connectivity & OGRs. 

In our scoping comments we raised the issues of effects to habitat fragmentation, coarse 

canopy and interior forest conditions, wildlife corridors, landscape connectivity, and oldgrowth reserves. Each of these is a critical issue for this project because of the extraordinary 

degree of natural habitat fragmentation on much of Kupreanof Island and the additional 

contribution of past logging activity (within the project area, in other adjacent WAAs, and in 

the biogeographic province more broadly) to fragmentation and habitat loss in general. 

The DEIS has failed in it duty to provide analyses that are of any substance for these topics, 

let alone providing the hard look that is demanded by the situation just described and the 

scale of this project. We incorporate by reference additional material in section VI.H of Sitka 

Conservation Society & SEACC's comments, on these topics. 

Again, a Revised DEIS is needed if the project is to proceed. 

XIII. Fisheries & Hydrology 

Please consider impacts of the proposed action on both increased peak flows as a result of 

roads and clearcuts, and decreased low flows as a result of cuts, roads, and dense-stand 

regeneration. Old forests and wetlands serve a buffering function in both directions, that 

should be considered in the EIS. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 107 Appendix D
13

We are concerned with impacts of proposed roads, and maintenance problems springing from 

the proposed action, on watersheds. The large number of red culverts and other fish passage 

problems, chronic sediment sources, landslides and mass soil movement, and increased 

traffic are all concerns. The proposed action would result in large percentages of watersheds 

being cut, and in large numbers of new stream crossings. 

The Cederholm et al. (1980) “threshold” of 2.5% road coverage of a watershed is being 

misused. First, problems of fish passage occur wherever they occur, regardless of road 

density. Please consider and disclose where these problems occur. Second, there is nothing 

magical about the number 2.5%. A poorly maintained road along a stream can fill 

overwintering pools with sediment just as surely at a low road density, as at a high one. 

Third, the Cederholm study had more to do with peak flow events, such as rain-on-snow 

events that are critical in Washington and Oregon, but less so here in Southeast Alaska. 

What is the implication of the stream crossing density column in Table 3-24? It’s an 

interesting number but we’re at a loss to determine what it is supposed to mean. 

It is absolutely unacceptable that there be 61 red culverts on this road system. It is even 

more unacceptable to spend the money that should go to fixing those on building new roads 

and maintaining those needed to get the cut out. The impact of the proposed action on 

delaying the needed repairs should be considered as an important impact of the proposed 

action. 

Please consider the impact of introducing fine sediment into stream channels that are 

important to overwintering and spawning habitat for salmon. In certain channel types, 

sediment can fill overwintering pools, and cover spawning gravels. Even were the actual 

release of sediment is temporary, the impacts certainly are long-term. 

Please explain why it is you think sediment delivery from the proposed action, building then 

storing roads, would not degrade water quality enough to “fully maintain the water body’s 

designated beneficial uses.” Fish habitat is certainly a beneficial use, and it is likely to be 

impaired. 

We are uneasy with the reliance on speculative road storage to mitigate road impacts to fish. 

As we comment above, it is not reasonable to expect that to actually happen. 

The analysis of impacts to hydrologic function is improperly dismissed by saying impacts are 

hard to measure at the watershed scale. (DEIS, p.105) So what? When habitat is degraded in 

a stream reach, that has an impact. If those impacts are hard to measure at a watershed 

scale, then that is just an argument for analyzing those impacts at some different scale. 

Alternative 3 proposes temporary road crossings on one Class I and three Class II streams. 

However, earlier information indicated that temporary roads were never used where special 

resource concerns like this exist. 

Please consider the impact of the storage strategy, versus just maintaining the proposed 

roads, on stream crossings. Assuming pulled crossings will have to be rebuilt, is that a 

greater or a lesser impact on fish? 

All in all the consideration of fisheries issues in the DEIS does not measure up to the 

immensity of the proposal. You are talking about building 139 new stream crossings, and 

keeping untold hundreds more open for years or even decades, and impacts are only 

considered in the vaguest possible way. Please conduct a more in-depth analysis for the 

FEIS. 

108 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
14

XIV. Roadless Areas. 

Though much of the Central Kupreanof project would be operated in previously roaded 

portions of the island, two of the three action alternatives also enter Inventoried Roadless 

areas (IRAs) for logging and road construction. These areas play a uniquely special role on 

the Tongass. As the Forest Service itself has determined in the Roadless Area Conservation 

Rule (RACR) process, the “Tongass is unique because the majority of subsistence and game 

species are integrally linked to the habitat qualities provided by unroaded areas.” RACR 

FEIS at 3-374. 

IRA lands that would be damaged by logging and/or road construction in Alternatives 2 and 

3 include areas identified by the Alaska Department of Fish and Game (ADF&G) as being of 

special sensitivity for subsistence use by several communities, most notably Wrangell, 

Petersburg, and especially Kake. ADF&G rated the large majority of the project area as being 

at “Highest Value” for Community Use. And roadless area logging in Alternatives 2 and 3 

would be in the headwaters of salmon streams that run through pristine lands to the east 

and northwest of the project area. 

The proposed logging and road construction in IRAs would violate the RACR. We understand 

that in 2003 the Forest Service decided to exempt the Tongass temporarily from the RACR. 

However, for reasons explained below, we believe that the temporary exemption was itself 

illegal and therefore ineffective. Because the exemption was ineffective, the Tongass National 

Forest, like all others, must follow the RACR in planning and conducting timber sales and 

road construction. 

The temporary exemption was illegal, in part, because the Forest Service never explained its 

about-face from 2001. In 2001, the agency carefully considered whether to include the 

Tongass in the RACR, and decided to do so for sound and well-explained reasons. It 

recognized that the unparalleled status of the Tongass, as our largest and most wild national 

forest and as a naturally fragmented archipelago, made protection of the remaining roadless 

areas here especially important. The decision adopting the RACR specifically cited “the 

unique and sensitive character of the Tongass National Forest, the abundance of roadless 

areas where road construction and reconstruction are limited, and the high degree of 

ecological health.” Federal Register, vol. 66, p. 3254 (Jan. 12, 2001). 

Any further roadless area entry beyond what was grandfathered under the RACR “would risk 

the loss of important roadless area values.” Id. Because local decisions about local IRA 

abundance could not be expected to factor in adequately the national interest in preserving 

this unique resource and in reducing the proliferation of an unmanageable, extremely 

expensive road system, the Forest Service decided to end the practice on the Tongass. These 

were strong, valid reasons for protecting all remaining Tongass IRAs. Until and unless the 

agency explains why they no longer apply or are persuasive, we do not believe it is legal 

simply to abandon those protections. 

Exemption of the Tongass from the RACR also was illegal because the Forest Service failed to 

provide a public NEPA process for its decision. This was ironic, given how the Bush 

Administration criticized the RACR process as inadequate, despite thousands of pages of 

environmental impact statements and many hundreds of public meetings. Relying on the old 

RACR FEIS was not justified for several reasons. First, the employment picture had changed 

dramatically. The RACR FEIS assumed that 900 direct jobs were at stake, based on logging 

levels that never materialized. In fact, the 2008 FEIS for the TLMP amendment shows that 

current logging levels can be sustained from the roaded timber base. That means no jobs are 

at stake, currently, from application of the RACR to the Tongass. Second, the RACR FEIS 

looked only at impacts to IRAs under the old roadless area inventory. Hundreds of 

thousands of additional acres were identified in the 2003 supplement to TLMP, however, 

meaning much more roadless acreage was at stake, actually or potentially, in the exemption 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 109 Appendix D
15

decision than understood in 2001. And finally, the management baseline for the RACR FEIS 

was the 1999 TLMP, which was more protective than the one in effect when the temporary 

exemption was adopted (and the one now in effect). Therefore foreseeable potential impacts 

from a rollback to the 1997 TLMP – which is very close to the 2008 amended plan – were 

greater than those reviewed in the RACR FEIS. 

Finally, the Forest Service never provided any rationale for a temporary exemption. The 

exemption decision cited the need to provide certainty for the region. But it was a temporary 

exemption. By its nature, a temporary decision cannot provide long range predictability. 

And exempting the Tongass from the RACR certainly does not in any way reduce the 

controversy and conflict over roadless area entry. As noted above, the exemption did not 

protect jobs that did not exist. It did not help connect communities by facilitating powerline 

and public roads, at least not in the timeframe of a temporary exemption. Not one example 

of a potential powerline or community-connecting road that would run afoul of the RACR was 

cited in the exemption decision. And despite the decision’s assertion that TLMP adequately 

protected roadless areas, the RACR protected another 2.4 million acres of them that TLMP 

left exposed. As discussed above, the Forest Service earlier recognized the national, even 

global, significance of these areas, unique in the national forest system. The exemption 

decision never explained why they were no longer important. 

Because exemption from the Tongass from the RACR was illegal, the Forest Service cannot 

rely on the exemption in planning timber sales and logging. None of the logging and roadbuilding exemptions within the RACR apply to Alternatives 2 and 4 of the Central Kupreanof 

project. To pursue these alternatives would therefore be illegal. They should be dropped 

from consideration or modified to comply with the RACR. 

XV. Transportation & Roads 

There are many good things to say about this EIS’s treatment of transportation. We are 

especially pleased you consider road management/access as a significant, alternative-driving 

issue. Thank you also for your consideration of both open and closed roads, and for 

recognizing and considering the maintenance costs associated with road management. These 

are major steps forward after years of brushing these issues under the rug. This is an issue 

on which there is a lot of common ground, and where there is a lot of good work for the 

Forest Service to do. 

It also is encouraging that the relevant Roads Analysis is done in time to inform this decision. 

We urge the Forest Service to base the actual decision on that information, in particular as it 

relates to maintenance shortfalls and the need to cut road density. Not having reviewed that 

document yet, we have no idea what it says. Please include the essential information from 

that analysis in the EIS, so that the public and decision-makers have access to it. The desire 

for shorter EIS documents is understandable, but all the important information should be 

put together in that single document, as per NEPA. 

Less encouraging is the fact that the relevant ATM plan has not been done. Please complete 

that process prior to issuing the FEIS are making any decision. Otherwise the decision would 

unfairly bias the ATM decision. The overlap also raises NEPA complications. Road 

management under this sale is a connected action with the overall ATM plan, and the 

impacts should be considered in a single NEPA document. 

We are concerned with road densities, especially given impacts to watersheds, wolves and 

marten. A great many of these roads should be decommissioned and some should be 

obliterated. At the very least, we strongly oppose any road construction in roadless areas. Up 

to 13 miles of new road in a Roadless Area, as proposed, is outrageous. 

110 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
16

Ironically, proposed roads would not even be multiple use, but rather single-use timber 

roads. Using scarce public roads funds for such narrow benefit is a poor use of resources, 

and it is questionable whether timber-only roads are an appropriate use of those limited 

funds. 

Lack of maintenance is a continuing concern, as the DEIS discloses. They say the first stage 

to recovery is admitting that you have a problem. We look forward to the next stage, which is 

taking action to alleviate the problem. Several actions should be taken with regard to 

maintenance shortfalls: 

· Please fix all roads that will be used in relation to this sale, before any timber haul 

takes place. We see no reason why the Forest Service should be permitted to use 

unmaintained forest roads in timber operations, without following BMPs or having a 

404 permit. 

· Please complete the ATM planning process, to enable fair evaluation of cumulative 

impacts. 

· Do not commit limited funds to building new roads, when that money is urgently 

needed to do maintenance on roads that are already there. 

· Do not build any new roads, particularly in roadless areas. 

This DEIS is the best I’ve ever seen at analyzing road costs. Thank you for citing to specific 

numbers, and the frank disclosure of costs. (DEIS, p.3-45). We were interested to learn that 

only 35 miles of road can be maintained each year on a 114-mile road system. There is a 

substantial maintenance backlog and this must be addressed 

It is not correct that road maintenance and this timber sale are entirely separate activities. 

(DEIS, p.3-43) The sale includes transportation management decisions that would impact on 

maintenance. For example, the DEIS says “having more maintenance funds available and 

less miles open to maintain the open roads to their operating standards and reduce deferred 

maintenance cost.” (DEIS, p.3-47) The opposite is also true. This sale will have adverse 

impacts on road maintenance, including by: 

· Increasing the number or road miles to be maintained35 

· Increasing the number of road miles that will need to be decommissioned and stored; 

· Spending available funds on timber sale-related maintenance and road construction. 

We are concerned with the quality of the RCS information on roads. The DEIS (p.3-42) seems 

to imply that only some of the project area roads have been surveyed. As you know, 

monitoring remote roads is one of the first maintenance tasks to be cut when budgets aren’t 

adequate. Nonetheless, this monitoring work is extremely important to an informed decision 

both for this timber sale, and the ATM. Please conduct on-the-ground surveys of all roads 

connected with this sale, and consider that information in the FEIS. If that information is not 

available, please explain why it is not. 

The DEIS says, “all road construction would follow the applicable BMPs and meet or exceed 

Forest Plan standards and guidelines.” (DEIS, p.3-43) However, it is evident that 

maintenance and perhaps even some reconstruction does not follow BMPs for TLMP S&Gs, in 

particular for fish passage, chronic sediment, and invasive species. Because these BMPs are 

not being followed on many roads in the timber sale system, it would seem that a Corps of 

Engineers 404 wetlands permit is necessary to use them for this timber sale. 

 

35

=$720K being (difference of 98 & 62 under Alt. 3, in added maintenance costs (assuming ten 

additional years, meaning 36*2.; difference of 98 & 62, $2K/yr maintenance; 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 111 Appendix D
17

Thank you for explaining that some roads would remain open an additional five to ten years 

post-sale. (DEIS, p.3-43) It’s important to remember that a timber sale is a fairly long-term 

event, with “temporary” facilities that last for years and even decades. 

Because all the action alternative appraise so strongly in the red, and the Forest Service is 

prohibited from advertising negative sales, this sale raises an additional concern with regard 

to delaying implementation of road storage and decommissioning. What is likely to happen if 

it is “NEPA-cleared” is that this sale will sit on the shelf for years and years, in the vague 

hope for a turnaround in the timber industry. That will mean that decommissioning/storage 

work on these roads will not be done, in order to keep those roads available for this sale. 

Thus, we will get the worst of both worlds. The timber industry won’t get any more timber to 

cut than they have already, and at the same time we won’t get the benefit of road closures 

made possible by lack of an active industry. Please consider this likely consequence of 

issuing a ROD in the FEIS. 

This problem of a very long “temporary” condition is compounded by the maintenance 

shortfall. We are concerned that storage and decommissioning prescriptions for roads are 

unfunded mandates. It is easy to say you intend for certain roads to be stored ten or fifteen 

years from now, but, is that a reasonable expectation? Given past experience and the 

available numbers we don’t think that it is. 

It is unacceptable to use red culverts for timber haul. The DEIS says that, for NFS Road 

6327, red crossings would be pulled “at the time of storage.” (DEIS, p.3-47) These red 

culverts are violations of the Clean Water Act, and your designation of it as a travel route is 

unacceptable here. 

The 45803 and 45808 roads are especially bad, encroaching on roadless areas, crossing 

headwaters and degrading habitat. These roads should be high priorities to drop. 

We question the layout of the “project area,” in particular as it relates to analysis of road 

density. Since the project area includes large parts of roadless areas that are far from 

proposed roads and units, considering only road density in terms of the project area may give 

an inaccurate impression that they are low, when in fact the impacted watersheds and WAAs 

have high road densities. Please show road density for WAAs and VCUs. 

XVI. A Detailed Public Investment Analysis Was Noted in Scoping As Required, 

and Was Requested But Not Provided in the DEIS. 

Enough said, and another reason a Revised DEIS is necessary. 

XVII. Significant Issue One: Timber Supply and Sale Economics 

We incorporate by reference Section III ("Significant Issue One: Timber Supply and Sale 

Economics") of the comments by Sitka Conservation Society and SEACC. 

XVIII. CONCLUSION 

For all of the above reasons we ask that either the DEIS be withdrawn, with a later Revised 

DEIS to be produced, or that the No-action Alternative be selected. We believe timber sales of 

appropriate scale for the local production of wood products in Kake can be accommodated 

through a micro-sale program (via categorical exclusions or an EA), and that larger projects 

in the area should be foregone; however, we defer to the Organized Village of Kake concerning 

what may be appropriate for consideration. 

112 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Central Kupreanof Timber Harvest FEIS Appendix D ▪ 113 Appendix D
114 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Central Kupreanof Timber Harvest FEIS Appendix D ▪ 115 Appendix D
"Mike Jackson" 

<MAJackson@KakeFirstNatio

n.org>

01/30/2009 03:38 PM

Please respond to

<MAJackson@KakeFirstNation

.org>

Default custom expiration date 

of 04/30/2009

To <comments-alaska-tongass-petersburg@fs.fed.us>

cc "Gary Williams" <GEWilliams@KakeFirstNation.org>, 

<larry.edwards@wdc.greenpeace.org>, "'Buck Lindekugel'" 

<Buck@seacc.org>, "Chris S. Savage USFS PSG" bcc

Subject Central Kupreanof Timber Harvest Comments by the 

Organized Village of Kake

History: This message has been forwarded.

Chris Savage, Petersburg District Ranger, USDA Forest Service

The Organized Village of Kake (OVK) would like to comment on the Central Kupreanof Timber Harvest, 

Draft Environmental Impact Statement (DEIS). OVK has general concerns about this DEIS, as being the 

Village that will be directly impacted by this proposed timber sale, they are as follows:

1. The wildlife section is only 21 pages, with the environmental consequences 

subjection is only 8 pages

2. The Subsistence section is less than 7 pages long – OVK being one of many 

villages that rely on Customary & Traditional Gathering as a way of Life

3. The Deer & Martin models were not used, deer being one of the most important 

Customary & Traditional Gathering 

4. OVK residents have noticed that the Wolf population is very active on Kupreanof 

& Kuiu Islands. The Wolf standard and guideline (concerning mortality, road density, 

generally providing a carrying capacity of 18 deer/square mile) was not applied.

5. The subjects of Connectivity, Marten, Goshawk, and endemic species sections are 

too brief, nothing on Goshawk beyond a listing in a table; Kake residents have spotted 

Goshawk activity within the Kake & proposed timber sale areas.

6. OVK knows from experience that any US Forest Service timber Sales that have 

been made around the Kake area has hired barely a hand full of workers. The logging 

companies bring in their own workers on barges & contribute very little economic 

development/benefit to our community. OVK understands that there are no guarantees 

that the Forest Service can give to ensure that the local unemployed members will be 

hired. 

7. One (1) out of seven (7) OVK Council members supports this timber sale, primarily 

because of no local hiring of workers in the past.

8. Over the past decade OVK has noticed that the Black Bear sport hunters have been 

increasing their take of Black Bear at a steady rate, we know from Customary & 

Traditional Knowledge, from thousands of years co-habituating with the Black Bear that 

if one species of wildlife is hunted too much that it will have a unraveling effect on our 

habitat. The cumulative logging of watersheds add to siltation of our salmon streams, 

negatively impacting salmon spawn survivorship, thus impacting the salmon catch by 

OVK members, by fisherman, etc...and the Black Bear. The Black Bear is one large 

contributor of natural fertilizer to the existing prime watersheds/old growth trees that we 

are blessed with. The cumulative effect of the loss of habitat for our Subsistence use & 

the loss of Black Bear to all the watersheds will have a vary negative effect on the OVK 

members & the habitat that we continue to live in. 

OVK looks forward to the US Forest Service coming to Kake to continue the dialog with the Tribe about 

the Central Kupreanof Timber Sale and other subjects that you like to address. 

Mike A. Jackson

Organized Village of Kake 

Realty/Trust/Natural Resource/Trans. Planner/Tribal Court Officer

PO Box 316

Kake, Alaska 99830

116 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Phone #: (907) 785-6471

Fax #: (907) 785-4902

Email: MAJackson@KakeFirstNation.org

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 117 Appendix D
1 

Chris Savate, District Ranger 

Tiffany Benna- Team Leader 

Central Kupreanof February 1, 2009 

Petersburg Ranger District 

Tongass National Forest 

PO Box 1328 

Petersburg, AK 99833 

comments-alaska-tongass-petersburg@fs.fed.us 

Dear Ms. Benna: 

The following are comments submitted on behalf of the Sitka Conservation Society (SCS) and 

the Southeast Alaska Conservation Council (SEACC) regarding the Central Kupreanof Timber 

Sale. SCS has a long history of involvement in the land management planning process on 

the Tongass National Forest. Our membership includes hundreds of Alaskans who use the 

Tongass National Forest and are concerned about management of its natural resources and 

roadless areas. Our members within the Tongass include commercial fishermen, Alaska 

Natives, tourism and recreation business owners, hunters and guides and citizens who use 

areas throughout the Tongass for recreation, scientific research and subsistence. 

SEACC is a coalition of 15 volunteer citizen organizations in 12 communities across 

Southeast Alaska. Our individual members include commercial and sport fishermen, Alaska 

Natives, tourism and recreation business owners, small-scale high-value added wood product 

manufacturers, hunters and guides, and Southeast Alaskans from all walks of life. SEACC is 

dedicated to preserving the integrity of Southeast Alaska’s unsurpassed natural environment 

while providing for the balanced sustainable use of our region’s resources. 

The alternatives indicate a timber take between 28 and 70 MMBF from Central Kupreanof 

Island. Much of the project area has been heavily fragmented from past logging and road 

construction. This project significantly increases logging in this area and would add as much 

as 34 more miles of open road for at least ten years, greatly increasing the road density and 

threatening numerous fish and wildlife species. Because of this significant damage from past 

logging and road construction, the extraordinary salmon productivity of project area 

watersheds, the importance of this area to Kake residents for subsistence and other 

activities, and the absence of a need for a project of this scale, we request that you withdraw 

this DEIS and that no further planning occur on this project. 

Some of our problems with this DEIS flow from the newly amended TLMP. This DEIS and its 

planning documents rely on, tier to and reference the TLMP. We had hoped that the Forest 

Service would have taken the opportunity to revise the TLMP to reflect the significant 

changes in demand for timber, fish and wildlife, subsistence, tourism and recreation on the 

Tongass in a way that would help rather than hinder the ongoing transition in Southeast 

Alaska since the end of the pulp mill era. 

Instead, the amended TLMP retained a “timber first” direction that failed to appropriately 

analyze and balance multiple uses of forest resources. The development of this large-scale 

project at an enormous public cost is an unfortunate but predictable outcome of the flawed 

TLMP amendment process. SCS and other groups appealed the TLMP to the Chief of the 

118 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
2 

Forest Service and requested specific and major changes. These comments rely on, tier to 

and incorporate by reference those appeals.1

We would have preferred to review several alternatives with volumes scaled to the small mills 

in this biogeographic province rather than review a DEIS that couples lip service to small sale 

options with a large sale component that is both uneconomical and ecologically 

unacceptable. Under the circumstances, this DEIS leaves little choice but to support 

Alternative 1, the no-action alternative. We request that you cancel planning on this project 

or prepare a substantially revised DEIS with fundamentally downsized alternatives that 

adequately reviews environmental impacts.2

I. Preliminary Concerns 

 A. The Scoping Notice Failed to Describe the Scope of the Proposed Action In 

Violation of NEPA 

In your responses to comments, please detail the history of scoping on this sale. A scoping 

notice must describe the proposed action and possible alternatives.3 NEPA further requires 

that “[d]raft environmental impact statements shall be prepared in accordance with the scope 

decided upon in the scoping process.”4

The January 2008 scoping notice informed us of the intent to log up to 40 million board feet. 

The DEIS explains that “the proposed action has been adjusted to respond to on the ground 

conditions and resource concerns while remaining within the scope of the original proposed 

action.”5 The January 2008 notice provided no indication that the Forest Service intended to 

develop a proposed action alternative that would take up to 46.8 MMBF from this project 

area and develop a second of three alternatives that would take over 70.2 MMBF of timber 

from this project area. 

The DEIS also states that a second public involvement letter was sent out stating that the 

project could take 80 MMBF following the development of an initial unit pool that would have 

taken 40 MMBF.6 It does not specify when that second letter was sent. Our review of the 

planning record and of our files for this project show that the Forest Service has looked at 

and communicated to the public different volume options for this sale several times prior to 

the January 2008 scoping notice. The problem is that we do not have and did not find any 

indication in the planning record that there has been a subsequent notice after January 

2008 that informed the public of this most recent change of plans. Other commenters with 

 

1 Specifically, we incorporate Appeals No. 08-13-00-0027 (Southeast Alaska Conservation Council); -

0028 (The Wilderness Society); -0029 (Sitka Conservation Society et al.): -0019 (Trout Unlimited 

Alaska); -0023 (Alaska Wilderness League); -0025 (Natural Resources Defense council); -0026 

(Audubon Alaska). All of these filings, with their attachments, have been provided to Region 10 in the 

course of the 2008 TLMP amendment appeal proceedings and are readily available to the Forest 

Service on the Tongass website. We can also furnish these materials if needed. Most of the 

documents cited herein are contained in the project or TLMP planning record and we will supply 

several documents as attachments in a separate e-mail. 

2 40 C.F.R. § 1502.9 (providing that “[i]f a draft statement is so inadequate as to preclude meaningful 

analysis, the agency shall prepare and circulate a revised draft of the appropriate portion”). 

3 40 C.F.R. § 1508.22(a). 

4 40 C.F.R. § 1502.9. 

5 DEIS at 1-3. 

6 DEIS at 2-2. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 119 Appendix D
3 

specific concerns about the scale of this project as scoped also assumed that this would be a 

40 MMBF project with 18 miles of roads.7

The failure to prepare this DEIS in accordance with the scope decided upon during the most 

recent scoping process violates NEPA. The most recent public notice clearly set a maximum 

volume that is now exceeded in two of the three action alternatives. We request that you 

withdraw the DEIS and issue a new scoping notice so that the public is fully aware of the 

plans for this project in the first instance.8

 B. The Purpose And Need Statement Is Inadequate 

In our scoping comments, we asked that the purpose and need and the alternatives be scaled 

to the needs of any sawmills that are on the western Kupreanof road system, and that the 

project be designed to be attractive primarily to them at more or less the current level of 

production. The scale of this project appears to be designed primarily for shelf volume for 

large sales rather than for local and diverse opportunities for resource uses. Please revise 

the purpose and need statement to address the needs of sawmills on the Kupreanof road 

system and the restoration and maintenance needs in the area and redevelop alternatives 

accordingly. 

 C. The Streamlined DEIS 

We have noticed over the past year an increasing tendency to reduce the amount of 

information provided in an EIS. Although the Forest Service’s effort to improve the efficiency 

of the NEPA planning process are commendable, the result has been a DEIS that is 

inadequate given the significant impacts of large-scale timber harvest. This DEIS is not the 

“detailed statement” that NEPA requires federal agencies to produce so that environmental 

impacts receive consideration “to the fullest extent possible.”9 

NEPA compliant environmental analysis must take a “hard look” at the environmental 

consequences of a proposed action.”10 The information provided needs to be of high quality 

and include all pertinent information that is or should be part of the decisionmaking 

process.11 Conclusory statements need to have some basis in scientific or objective data.12 

This DEIS supplies numerous unsupported conclusory statements about subjects that range 

from job generation to cedar regeneration. The DEIS measure impacts to fish and wildlife in 

an encyclopedic manner through reference to cumulative harvests and remaining POG 

without any site-specific analysis of project impacts. 

Even the unit and road cards suffer from streamlining. The public reviewing those 

documents is led to believe that none of the cutting units implicate concerns with wildlife, 

recreation, sensitive plants, and a host of other resources. Yet there are materials in the 

 

7 Cariello, J. 2008. State of Alaska DNR/OHMP Comments; Mecum, R. 2008. NOAA Scoping 

Comments for the Central Kupreanof Timber Harvest. 

8 This result would also redress several other concerns we raised about the January 2008 scoping 

notice – the time period between mailing and the requested comment submission date was very short, 

there was no purpose and need statement to indicate why the project was planned at this time, no 

proposed harvest techniques were discussed and impacts to the inventoried roadless areas were only 

vaguely discussed 

9 42 U.S.C. § 4332(2)(C). 

10 Citizens Against Toxic Sprays v. Bergland, 428 F.Supp. 908 (D.Or. 1977). 11 40 C.F.R. § 1500.1(b); Trout Unlimited v. Morton, 509 F.2d 1276, 1282 (9th Cir. 19740. 

12 Citizens Against Toxic Sprays v. Bergland, 428 F.Supp. 908 (D.Or. 1977). 

120 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
4 

planning record indicating connectivity concerns for some units and the Recreation section 

identifies specific units that will impact recreational uses. We find it surprising that cutting 

units containing 70 MMBF of timber could be harvested without any unit-specific wildlife 

concerns. In your responses to comments, please address whether the level of information 

provided in the unit cards is complete, and whether the individual units were surveyed for 

wildlife use. 

We also continue to be concerned that the public must then request copies of the project 

planning record to find material that should be in the DEIS and that is necessary to 

understand the nature and impacts of the project. We spent an inordinate amount of time 

reviewing the planning record for information on goshawks that should have been in the 

DEIS and ultimately realized that the information was not included there either. One of 

NEPA’s purposes is to ensure that “environmental information is available to public officials 

and citizens.”13 The Forest Service is supposed to facilitate and encourage public 

involvement rather than discourage public involvement by obscuring material that best 

facilitates meaningful comment. Requesting and reviewing a project file of thousands of 

pages and hundreds of documents spanning years in order to meaningfully comment on a 

DEIS is not reasonable and does not further NEPA’s goal of public participation. 

For the reasons above and below, we request that the DEIS be withdrawn and redone. There 

are too many omissions of important details that are essential to a reasoned decision. An 

unreasonable decision to proceed with this project was the result. 

II. Range of Alternatives: 

The alternatives are the heart of a NEPA document and one of the Forest Service’s most 

important obligations under NEPA.14 Because of the environmental damage and the 

significant taxpayer loss associated with road construction, our scoping comments requested 

that the Forest Service consider multiple action alternatives that eliminated new road 

construction as well as incursions into or impacts to roadless areas. We also requested 

alternatives consisting of economically efficient micro-sales scaled to the needs of local mills. 

The DEIS proposes three action alternatives. Alternative 2 addresses timber economics and 

deer habitat and would take up to 46.8 MMBF of timber with 2,031 clearcut acres and 467 

acres where some form of partial retention prescription would apply.15 This alternative 

includes 14.1 miles of road construction or reconstruction.16 Alternative 3 addresses timber 

economics by maximizing volume and would take up to 70.2 MMBF from 3,127 clearcut 

acres and 520 uneven-aged management acres.17 This alternative involves 41.3 miles of 

road construction or reconstruction.18 Alternative 4 minimizes road construction and takes 

28.2 MMBF from 1,327 clearcut acres.19

We reiterate our requests for multiple alternatives that both minimize ecological impacts and 

maximize economic efficiency per unit of impact: road-based micro-sales. The Forest Service 

needed to “[r]igorously explore and objectively evaluate all reasonable alternatives, and for 

alternatives which were eliminated from detailed study, briefly discuss the reasons for their 

 

13 40 C.F.R. § 1500.1(b). 

14 40 C.F.R. § 1502.14; NRDC v. U.S. Forest Serv., 421 F.3d 797, 813 (9th Cir. 2005). 

15 DEIS at 2-3. 

16 DEIS at 2-3. 

17 DEIS at 2-3. 

18 DEIS at 2-3. 

19 DEIS at 2-4. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 121 Appendix D
5 

having been eliminated.”20 “The existence of a viable but unexamined alternative renders an 

environmental impact statement inadequate.”21 The failure to consider a low volume 

alternative that minimized impacts to other important resource area values warrants 

production of a supplemental EIS. 

 A. The DEIS Improperly Excludes Other Reasonable Alternatives 

The IDT selected three significant issues used to formulate and design alternatives: (1) 

Timber Supply and Economics; (2) Inventoried Roadless Areas and (3) Road 

Management/Access.22 In our scoping comments, we raised several other issues that should 

have merited more serious concern in the alternative development process. In particular, we 

indicated that the project area contains several watersheds that are highly ranked for salmon 

productivity and we asked the Forest Service to consider some combination of impacts to 

fish, wildlife and subsistence uses of these resources as a significant issue. 

The scoping notice declined to consider subsistence as a preliminary issue because it was 

addressed in the Road Analysis Process/Access Travel Management Plan. But the scale of 

this project poses additional risks to subsistence resources beyond impacts resulting from 

road construction. Further, not all wildlife resources are synonymous with subsistence 

resources and we requested that the DEIS consider overall impacts to fish and wildlife as an 

alternative driving issue. 

The DEIS did note that numerous concerns were raised about subsistence, access and 

deer.23 But the only reasons given for eliminating the alternative was that additional units 

were added to the unit pool.24 This explanation was confusing – does it mean that the Forest 

Service eliminated an alternative driven by wildlife, subsistence and access concerns because 

of the need for increased volume? We request clarification as the other two alternatives 

maximize timber volume and if the explanation is accurate, the entire range of alternatives 

has either to do with maximizing timber volume in general or maximizing timber volume and 

economics. The DEIS should disclose the opinion of several IDT members that a low volume 

alternative was preferable as it provided the best economics and pointed to the futility of high 

volume alternatives because the agency would have to “bear the burden of road building 

costs and impact more resources when the timber quality is marginal.”25

Further alternatives around deer habitat were rejected on the ground that the proposed 

action incorporated deer habitat in the design.26 We are extremely disappointed that the 

Forest Service did not consider a combined subsistence/deer habitat alternative. ADF & G 

expressly raised concerns about project impacts to deer habitat.27 Nearby Kuiu Island is a 

predator pit with low deer numbers, Admiralty Island deer harvest requires vessels capable of 

transiting large stretches of open water during winter weather and Kupreanof Island does not 

have enough habitat to support large numbers of deer. Because of the importance of deer as 

a subsistence resource, the Forest Service should be managing this area to restore and 

protect deer habitat rather than planning for large-scale future removals of deer habitat and 

increasing deer removals through increased road density. 

 

20 40 C.F.R. § 1502.14(a). 

21 Westlands Water Dist. V. U.S. Dep’t of Interior, 376 F.3d 853, 868 (9th Cir. 2004). 

22 DEIS at 1-17. 

23 DEIS at 2-10. 

24 DEIS at 2-10. 

25 Planning Record Document # 255. 

26 DEIS at 2-10 

27 Planning Record Document # 331. 

122 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
6 

Please revise this DEIS to include alternatives that address subsistence and deer habitat as 

an alternative driving issue. 

 B. The Range of Alternatives Tiers to an Illegal and Arbitrary Forest Plan 

The purpose and need statement for this project relies on guidance from the 2008 TLMP 

amendment. As a result, the range of alternatives was unreasonably restricted by the 

objective of meeting an overinflated market demand scenario pursuant to the 2008 TLMP 

amendment. These issues have been fully addressed by the administrative appeals filed by 

SCS and others and we will reiterate these problems in our discussion of Appendix A. We 

simply point out here that this particular project is an unfortunate result of the deficient 

Forest Plan analysis and flawed multiple-use balancing. All of the action alternatives include 

large-scale clearcuts and two of the three action alternatives authorize extensive road 

construction. 

 C. The Forest Service Improperly Excluded a Small or Micro-Sales Alternative 

In our scoping comments, we specifically requested that the project be scaled to the needs of 

local mills and that action alternatives offer only micro-sales. In light of the economic and 

ecological context, the development of a small and/or microsales alternative was essential to 

fulfilling NEPA’s mandate to facilitate “informed decisionmaking and informed public 

participation.”28 A small or micro-sale alternative would have done by far the best job of 

“sharply defining the issues and providing a clear basis for choice among options.”29 The 

DEIS notes that “a number” of small mill owners have “expressed an interest in purchasing 

small sales from the project area.” 

 1. The Small Sales Alternative Would Best Meet the Economic Goals of the 

Purpose and Need for this Sale 

NEPA requires the Forest Service to discuss the reasons for eliminating alternatives from 

detailed study.30 There was no discussion in the DEIS that explains the rejection of our 

suggested micro-sales alternative. Such an alternative would even be the most consistent 

with the unreasonably narrow purpose and need for this project – to “[m]anage the timber 

resource ... in an economically efficient manner” and to “[p]rovide for a diversity of 

opportunities for resource uses that contribute to the local and regional economies of 

Southeast Alaska.”31

Small sales may be the most feasible method of providing local employment and economically 

efficient projects: 

Small timber operators have the ability to sell smaller amounts of forest products in the local area, 

have less capital outlays, lower overhead, and have been able to develop niche markets for their 

products. The small and very small family owned businesses that currently constitute the 

Southeast Alaska woods products industry are adjusting to take advantage of these more 

 

28 Westlands Water Dist. V. U.S. Dep’t of Interior, 376 F.3d 853, 872 (9th Cir. 2004). 

29 40 C.F.R. § 

30 40 C.F.R. § 1502.14(a). 

31 DEIS at 1-2. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 123 Appendix D
7 

specialized markets. This is likely a normal phenomenon that is part of the transition occurring in 

the Southeast Alaska timber industry.32

This DEIS confirms that “[l]ocal processing avoids the cost of barging the timber to a larger 

mill, thus reducing logging costs and increasing the indicated bid amount for the volume 

harvested though small sales.”i33 Statistics corroborate the economic efficiency of smaller 

sales. On nearby Prince of Wales Island, the micro-sales generated an average bid value of 

$90.36 per MBF over a five-year period from 2003 to 2007 and the small sales program 

generated an average bid value of $64.75 per MBF.34 During the same time period the larger 

sales program generated a bid value of just $11.44 per MBF for a much larger volume.35 

These figures indicate that the most economically efficient timber is that timber taken from 

the road system in smaller volumes. Further, the small sale program is more effective at 

achieving local utilization of high value species. As indicated by the supporting 

documentation for the limited interstate shipment policy, the large sale program requires 

high levels of out-of-state processing in order for the sale to be economical.36

We have not conducted a detailed review of the Petersburg Ranger District sales program but 

have skimmed through information pertaining to bid data and sales cancellations.37 As 

discussed in more detail in subsequent sections, the Forest Service should have taken a 

harder look at the recent history of its large sale program in this DEIS and such an effort 

would have better informed the development of alternatives. But in general, it appears that 

small sales from this ranger district have also generated a much higher bid value per MBF 

and that numerous large sales are in default, been cancelled or received no bids.38 

In sum, we fail to see how preparing a large sale component solely for the purpose of shelf 

volume meets the purpose of managing the timber resource for economically efficient 

sawtimber production. If planning on this project continues pursuant to the current Purpose 

and Need statement, please include multiple small sales alternatives in a revised DEIS. 

 2. A Micro or Small Sale Alternative Best Meets Forest Plan Guidance 

The two largest sales from the Petersburg Ranger District over the past five years, Lindenberg 

and Finger Point, received just one bid.39 But the Forest Plan directs the Forest Serivce to 

“plan offerings to encourage competitive bidding in a range of total sale volume and species 

that provides opportunities for purchasers.”40 

In our view, the Forest Service should have reviewed bid data for sales from the district prior 

to eliminating a small or micro-sales alternative. It is clear from recent Thorne Bay Ranger 

 

32 Couverden Timber Sales ROD at R-9. 

33 DEIS at 3-17. 

34 Mehrkens, J. 2007. Tongass Timber Bid Analysis. Excel spreadsheets on file with SCS and also 

attached as Exhibit 2 to the SEACC appeal of the Tongass Land and Management Plan Amendment 

available at http://tongass-fpadjust.net/FPA_Appeals.htm. 

35 Id. 

36 Housley, R., K Vaughan & S. Alexander. 2007. Forest Service Region 10 Timber Market Analysis of 

the Effects of Export and Interstate Commerce on Timber Sale Value and Volume. Regional 

Economist, USDA Forest Service, Alaska Region. February 20, 2007. 

37 Mehrkens, J. 2007. 

38 Id. 

39 Id. 

40 2008 TLMP at 4-74. 

124 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
8 

District bid data (2005 – 2007) that small sales generated multiple bids while larger sales 

from the same district over a five-year period (2001-2005) received but a single bid from the 

same mill.41 Notably, the competitively bid sales generated more than five times the value 

per MBF.42

 3. There Are No Buyer For Large Sales and the Forest Service is Foreclosing 

Opportunities for Small Mills by Excluding Small Sales Alternatives 

As we explained at the outset of our comments, the large sale component of all the 

alternatives leaves us little choice but to support the no-action alternative. This is 

unfortunate because we would support road-based small sales from this project area that 

would facilitate employment in Kake and Petersburg. This support would minimize the delay 

associated with extended NEPA documentation and administrative appeals. 

In the revised DEIS that explains why our proposed small sale alternatives were not 

considered, please discuss potential buyers for the large sale component. Three mills have 

bought recent sales from the Petersburg Ranger Districts in recent years. One, Silver Bay 

Logging, cancelled several sales and ended up going bankrupt trying to harvest these sales. 

Another, Alcan, has not harvested timber from any Tongass sales in recent years unless 

there was prior approval for export of the entire sale volume. The third, Viking Lumber, has 

cancelled several sales in the project area and may be seeking to cancel the remaining 

volume of its only current sale in the Petersburg Ranger District – Lindenberg – despite 

barely having enough volume to remain in operation. 

Conversely, the DEIS mentions specific requests for small and micro-sales from small mills 

in Kake. There is no mention of any interest in large sales from this project area. This lack 

of interest is not surprising in light of the recent cancellations and large sales from this 

ranger district that have received no bids. We make three points here: (1) environmental 

organizations have repeatedly advocated and recently have negotiated for small timber 

programs that supply local mills; (2) small local mills requested small sales and (3) large 

sales from this project area have not helped larger mills. In light of these three points, please 

explain in some detail why the Forest Service has refused to uncouple small sales from large 

sales in developing alternatives. The only explanation we can see is that the agency wants to 

continue to blame environmentalists for its inability to supply timber to local users rather 

than conduct a sincere evaluation of the combined realities of poor economics, poor demand 

and the agency’s own export policies that promote foreign processing of the most valuable 

trees. 

 4. Conclusion 

The DEIS did not respond to our request for multiple action alternatives consisting solely of 

small and micro-sales and consequently did not explain why this option was eliminated from 

study in violation of NEPA. We have provided numerous reasons why our proffered 

alternative best meets the economic timber component of the purpose and need, Forest Plan 

guidance and ecological concerns. Such an option furthers NEPA’s goal of sharply defining 

the issues. To correct the deficiency of this DEIS, please include multiple small sales 

alternatives in a revised DEIS or explain why these alternatives were excluded in light of 

recent sales cancellations, the improved economic efficiency of small sales and the 

opportunities for competitive bidding. 

 

41 Mehrkens 2007. 

42 Id. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 125 Appendix D
9 

III. Significant Issue One: Timber Supply and Sale Economics 

In our scoping comments, we noted a number of concerns pertaining to the economics of 

timber sales on the Tongass. Our first concern pertains to the market demand rationale for 

considering harvest in this project area. We request a re-evaluation of this analysis before 

you proceed with this project. Our reasons for this are discussed in our discussion of 

Appendix A at the end of these comments. 

We also point out that this DEIS underestimates the costs associated with this project and 

overestimates the benefits. This DEIS measure timber sale economics in terms of six factors: 

(1) total volume measured in MMBF; (2) logging costs per MBF; (3) indicated bid value; (4) 

employment in direct number of jobs; (5) direct income based on projected employment; and 

(6) logging systems by harvest method.43

These measurements do not adequately reflect a true cost/benefit analysis of this project. In 

our administrative appeals and in comments on other timber projects, we have repeatedly 

asked the Forest Service to take a hard look at the employment and economic impacts of 

timber projects, to incorporate the true costs of road construction and other subsidies and to 

discuss detrimental impacts to other resource users. Our specific concerns follow. 

 A. The DEIS Overstates the Ability of the Forest Service to Affect Local Timber 

Industry Economics 

In our scoping comments, we requested an accurate assessment of the number of jobs and 

the amount of revenue the project will generate in the region. We further asked the Forest 

Service to identify the amount of unprocessed lumber hemlock, spruce and cedar from this 

sale that is pre-authorized for transshipment or export and the amount of cedar that is likely 

to be exported based on past sales. The public has a legitimate interest in expecting that 

high-value timber will be available for value-added local processing and the DEIS failed to 

take a hard look at this important issue. 

 1. The DEIS Needs to Disclose the Likelihood of Out-of-State Shipment or 

Export 

We remind the Forest Service that “[f]or an EIS to serve [its] functions, it is essential that the 

EIS not be based on misleading economic assumptions.”44 At a minimum, assumptions 

must at least be explained.45 The DEIS suggests that a purchaser “may elect to process all 

the sawlogs locally or to ship up to 50 percent of the total sawlog volume and 100 percent of 

the utility volume to markets outside Alaska in the lower 48 states.”46 

We are unaware of any large sale purchased from this or any other ranger district where all 

of the timber received domestic processing. In fact, in 2007 the Forest Service issued permits 

to export or transship 16.3 MMBF of timber during a year where operators cut only slightly 

more than that – 18.7 MMBF. We recognize that there is a time lag between sale, cut, permit 

approval and actual export but it seems clear that purchasers of large sales typically ship out 

at least a third of sawlog volume without any local processing. For example, more than one-

 

43 DEIS at 3-10. 

44 Hughes River Watershed Conservancy v. Glickman, 81 F.3d 437, 446 (4th Cir. 1996). 

45 Van Abbema v. Fornell, 807 F.2d 633, 639-42 (7th Cir. 1986). 

46 DEIS at 3-19. 

126 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
10 

fourth of the volume from the 2004 Finger Point project had been approved for export by the 

end of 2007. Please compare export permit approvals with sales data from Petersburg 

Ranger District sales and evaluate whether the assumption that a sale purchaser may 

domestic process all sawlogs is valid. If there are no instances of 100% domestic processing 

for projects of this scale, please revise and redo this EIS to correct any misleading 

statements. 

We also request clarification about the status of the 2007 limited interstate shipment policy. 

The DEIS fails to discuss the 2008 addendum to this policy that authorized foreign export of 

spruce and hemlock sawlogs. Please discuss whether the circumstances that led to the 

development of that addendum are still present and evaluate whether or not there may need 

to be an extension of that foreign export addendum in order to make this sale economic. 

Regardless of whether there will be 50% interstate shipment or 50% foreign export, the 

requested information is critical so that the public and the decision maker have an 

opportunity to evaluate the extent to which this project will meet the stated purpose and 

need. The DEIS needs to fully analyze the economics of this sale in terms of the amount 

timber likely to be processed out of state. 

There should also be a comparison of the respective values of sawlog species generally 

harvested for export versus those that may receive domestic processing. Although the 

amount of cedar sold between 2001 and 2005 was less than 20% of the volume of spruce and 

hemlock sold during the same period, the stumpage values were similar - $3.3 million for the 

spruce and hemlock and $2.8 million for the cedar.47 The proposed action would take 5.7 

MMBF of yellow cedar. Using 2008 figures from the most recent sale advertisement, the bid 

value for the amount of yellow cedar for this sale by far outstrips the bid value for hemlock 

even though there is five times as much hemlock.48 

In sum, please indicate the respective values of this sale by species so that the public can 

review whether planning for this project is for the primary purpose of seeking cedar for 

export rather than promoting economically efficient sales for local processors. 

 2. Because of the Inadequate Analysis of Exports and Interstate Shipments, the 

Table on Mill Jobs is Misleading 

In scoping comments, we asked that the DEIS clearly account for the probable percentage of 

workers who will be seasonal out of state workers based on information from previous years. 

Residents of Kake have indicated that timber operators bring in their own workers so that 

there is little contribution to the local economy through these projects. Please provide 

detailed statistics about past employment generated by large timber sales. We further asked 

for an accurate assessment of job generation based on a realistic analysis of exports and 

interstate shipments of raw logs out of the region. This information was important so that 

the decisionmaker and the public could evaluate whether the stated purpose and need for 

the project will be fulfilled. 

The DEIS did not respond to these requests in any way. Instead, it proposed a range of jobs 

that reflects “the variety of options the timber purchaser has under the limited interstate 

 

47 USDA Forest Service Region 10, Timber Cut and Sold on National Forests, 2001-2005, available at 

http://www.fs.fed.us/r10/ro/policy-reports/for_mgmt/index.shtml. 

48 Kolund, L. 2008. Traitor’s cove Sale Bid Notice. USDA Forest Service, Ketchikan Ranger District, 

Ketchikan Alaska: September 18, 2008. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 127 Appendix D
11 

shipment policy.”49 The upper end of the range assume complete domestic processing of all 

sale volume and the DEIS says that the number of jobs is likely to fall between the high and 

low end of that range.50 As discussed in the preceding subsection, we are unaware of any 

basis for the assumption that a sale purchaser “may elect” to process all the sawlogs in the 

region. 

Consequently, Table 3-7’s assertion that action alternative could generate as much as 221 

jobs worth $8.3 million or 332 jobs worth $12.5 million is highly misleading. This table 

mischaracterizes the total annualized jobs and income by suggesting an upper range without 

providing any basis for the assumption that all the timber sold would ever be processed 

locally in Southeast Alaska. 

 3. The DEIS Needs to Evaluate the Long-Term Economic Impacts of Liquidating 

High-Value Trees for Export Now 

One of our concerns with regard to cedar exports is that trees which have the highest 

potential for adding value to the local small industry are being cut now and will not be 

available to these small mills over the planning cycle. The CEQ regulations require the 

Forest Service to discuss “the relationship between short-term uses of man’s environment 

and the maintenance and enhancement of long-term productivity.”51 Please explain how the 

near-term targeting of POG, which contains the relatively rare but much higher value cedar 

species, affects the long-term viability of the Tongass timber program. 

 4. Conclusion 

The failure to take a hard look at export policy and its consequences warrants production of 

a revised EIS. Please include accurate information about job generation and job generation 

specifically in Kake and Petersburg. Please review Petersburg Ranger District sales data and 

compare bid values for large and small sales and discuss recent cancellations of large sales. 

 B. The Timber Financial Efficiency Analysis Needs to Discuss All Costs 

In scoping comments, we requested a detailed public investment analysis that disclosed the 

full public costs associated with administering this project, including “pre-roading funded by 

taxpayers but not recovered in timber sales receipts.52 We requested that the analysis take 

into account the fact that a substantial portion of timber sales offered in recent years have 

received no bids or been cancelled so that taxpayers incur the expenses of preparing the 

sales with no offsetting timber receipts. 

In planning a timber project, the Forest Service needs to compare the public money it will 

spend administering a project with the prospective returns to the agency. That analysis 

“compares estimated Forest Service expenditures with estimated financial revenues” and 

allows the decision maker and the public to gain some understanding of “the future financial 

position of the program if the project is implemented.”53 Part of the purpose of this analysis 

 

49 DEIS at 3-19. 

50 DEIS at 3-19. 

51 40 C.F.R. § 1502.16. 

52 Specifically, we expected comprehensive and accurate estimates of sale administrations costs, 

actual expenditures rather than estimates, associated costs such as the project’s share of Region 10 

timber program overhead and foreseeable post sale costs as well as information on the methodology 

uses whenever costs were estimated. 

53 Forest Service Handbook § 2400.18_30. 

128 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
12 

is to fulfill NEPA’s requirement to “balance a project’s economic benefits against its adverse 

effects.”54 Without a corresponding an accurate display of costs and harms, informed 

decisionmaking is not possible, the public is mislead and NEPA’s hard look requirement is 

not met.55

This DEIS fails to provide a table that accurately displays and tallies administrative, 

engineering and road costs so that the public can compare the public money spent on this 

project with income generated. Table 3-6 does indicate that each alternative will generate a 

loss of between $1.6 and $5.1 million but does not specify the specific sources of those losses 

so the public cannot evaluate whether there has been a full accounting of administrative 

costs and costs associated with public works roads. Our more specific concerns follow. 

 1. Pre-Roading Contracts 

The DEIS says that “in some years, public works funds are available to pay for all, or a 

portion of, road construction or reconstruction costs in a timber sale for roads that will be 

used in the long-term administration of the national forest.”56 As a result, the display of 

stumpage to mill costs fails to incorporate road construction and reconstruction costs and 

misleads the public as to the true costs associated with this project. 

Nearly every large timber sale has been and will be dependent on pre-roading contracts. In 

our administrative appeal of the 2008 TLMP amendment, we provided examples of preroaded sales based on actual contracts issued and solicitations for bids on road construction 

contracts. There was well over $1 million spent of pre-roading for the Lindenberg and Finger 

point sales – an amount that tripled the value received from sales revenues.57 Most timber 

sales involved considerably higher pre-roading costs that led to costs exceeding sales 

revenues by over $2 million per project for three projects.58

This DEIS fails to account for these costs and does not explain what public works purpose 

these road fulfill other than access to timber units. In light of the large scale of road 

construction proposed for this project, the Forest Service needs to include the cost of public 

works contracts in order to fully evaluate the financial efficiency of this sale. The DEIS 

indicates that road construction is “primarily ... a function of the demand for access to 

timber resources” and “future construction is anticipated to be largely determined by the 

need to access timber resources.”59 If there is road construction funded through other 

Congressional appropriations for some other National Forest purpose in the project area, it 

should be explicitly discussed in the DEIS. 

We request that a supplemental table be provided that fully accounts for the cost of taxpayer 

subsidized road construction in the project area regardless of the stated purpose of the road. 

 2. Cost Monitoring 

This DEIS omits any discussion of the costs of administering this project and we request that 

the revised DEIS include a table that indicates the Net Present Value of the project after 

 

54 Hughes River Watershed Conservancy v. Glickman, 81 F.3d 437, 446 (4th Cir. 1996). 

55 Id. 

56 DEIS at 3-17. 

57 SCS et al. TLMP administrative appeal 

58 Specifically, the Midway, Sunmore Change and Buckdance Madder projects. 

59 DEIS at 3-37. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 129 Appendix D
13 

incorporating administrative and public works road contracting costs. The only cost factored 

into the timber efficiency analysis in this DEIS is the stumpage to mill cost to the purchaser. 

As a result, the public and the decisionmaker have no information to review about the cost of 

NEPA analysis, the costs of sale preparation and administration and the cost of engineering 

support. According to one recent DEIS, these costs can amount to approximately $5 million 

for a 52 MMBF sale.60 Thus, in a sale that had a positive indicated bid value, there was still 

a negative Net Present Value of -$3.7 million. 

Further, we request that the Forest Service update its stumpage to mill cost calculations for 

the DEIS. We have repeated requested that the Forest Service update its measurements of 

logging and road costs. The information in this DEIS appears to be clearly outdated given 

that the closest appraisal point is a mill that is no longer in operation.61 

 3. Conclusion 

The financial efficiency analysis failed to discuss a number of significant costs – particularly 

administrative costs and “public works” road construction costs. Without this information, 

the entire section is misleading. We request that the Forest Service prepare a revised DEIS 

that provides updated logging costs, includes administrative costs and includes all public 

works road construction costs that are related to timber access. 

 C. The DEIS Must Provide a More Thorough Analysis of Ecosystem Services 

In scoping comments, we requested the inclusion of all non-timber-related economics of the 

area in the economics analysis section of the EIS including: recreation, tourism, hunting, 

fishing and subsistence. The financial efficiency analysis ignores these costs on the ground 

they are regional or on the ground that non-market benefits and opportunity costs are not 

easily quantifiable.62 Costs to fisheries and recreation are shifted to those corresponding 

sections where we are told that the project will not impact those resources. 

Obviously, the value of these factors will differ depending upon which alternative the Forest 

Service selects, but quantifying them as “zero” in the “No-action Alternative” does not portray 

these factors accurately to the public. A fully informed analysis of the economics of this 

timber sale should incorporate external costs. Courts have pointed out that “[t]here can be 

no ‘hard look’ at costs and benefits unless all costs are disclosed.”63 This DEIS fails to meet 

that standard because it focuses its economic analyses and forecasts solely on the wood 

products industry and ignores important economic contributions from other industries as 

well as the services and benefits that ecosystems provide. The cost of producing a good or 

service is not simply a factor of priced inputs such as logging costs. If environmental and 

other resource user costs are not factored into the economic analysis, the true value of 

resources being used to produce the timber is not accurately represented. 

Forest Service scientists and the experts they work with are well aware of this dynamic and it 

needs to be incorporated into planning and project level analysis: 

... management of the Tongass for carbon sequestration may be of equivalent economic value to 

timber harvesting. Valuation of potential carbon sequestration in the Tongass from ceasing 

 

60 See Logjam DEIS at 3-131. 

61 DEIS at 3-14. 

62 DEIS at 3-16; 3-19. 

63 Sierra Club v. Sigler, 695 F.2d 957, 975-76 (5th Cir. 1983). 

130 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
14 

all harvesting may be amplified by indirect benefits of eliminating harvesting, such as 

maintenance of the southeast Alaska fisheries and tourism industries and reduced 

expenses for the Tongass timber program.

64

In previous timber project comments and in our administrative appeal of the 2008 TLMP 

amendment, we repeatedly emphasized that these values needed to be incorporated in the 

financial efficiency analysis. But this DEIS did not mention the more easily quantifiable 

values and it ignored real costs to other values by omitting non-quantifiable costs. Without 

taking readily available data and putting a number to these values or measuring losses in 

some way, the DEIS failed to fulfill its core NEPA obligation of informing the public and the 

decisionmaker. We request a revised DEIS that includes a cost/benefit analysis that 

incorporates ecosystem values and puts a number to subsistence resources, recreational 

values and fishery values so that the public can be fully aware of the economic value of nontimber forest resources and judge for themselves whether the value generated by timber 

warrants risking other resource values. 

 1. Legal Directives Requiring Eco-System Benefit Analysis 

This request is supported by applicable legal directives. NEPA requires the identification and 

development of methods and procedures “which will insure that presently unquantified 

environmental amenities and values may be given appropriate consideration in decisionmaking along with economic and technical considerations.”65 To implement this guidance, 

CEQ regulations require that a cost-benefit analysis “discuss the relationship between that 

analysis and any analyses of unquantified environmental impacts, values and amenities.”66 

The Forest Service need not necessarily monetize these considerations but must include 

them where relevant and important to a decision.67

Similarly, NFMA and its implementing regulations also require appropriate consideration of 

non-market goods and services when evaluating alternatives. Planning regulations require 

forest plans to “describe and analyze ... the range and estimated long-term value of market 

and non-market goods, uses, services and amenities that can be provided by [by national 

forests] consistent with the requirements of ecological sustainability.68 The regulations 

provide further guidance by defining “net public benefits” as “the overall long-term value to 

the nation of all outputs and positive effects (benefits) less all inputs and negative effects 

(costs) whether they can be quantitatively valued or not.” 

This DEIS entirely ignored these directives.69 In our administrative appeal of the 2008 TLMP 

amendment we provided numerous means of quantifying non-commodity and other values 

that have been applied by resource economists and federal agency economists. These 

options include the travel cost and contingent use methods of valuing recreation and the 

IMPLAN input/output model used by the Forest Service to estimate the effects of agency 

actions on income and employment.70 

 

64 Leighty, W., S. Hamburg & J. Caouette. 2006. Effects of Management on Carbon Sequestration in 

Forest Biomass in Southeast Alaska. Ecosystems (2006) 9:1051-1065. 

65 42 U.S.C. § 4332(B). 

66 40 C.F.R. § 1502.23. 

67 40 C.F.R. § 1502.23. 

68 36 C.F.R. § 219.21. 

69 DEIS at 3-16. 

70 Loomis, J.B. & R. Richardson. 2000. Economic Values of Protecting Roadless Areas in the United 

States. Fort Collins, Colorado, Department of Agricultural and Resource Economics, Colorado State 

University. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 131 Appendix D
15 

Other values such as fisheries and subsistence resources are easily quantified by calculating 

value per fish by fishery ex-vessel values and guided angler willingness to pay formulas or by 

calculating the value of subsistence resources by comparing prices of substitute protein 

products. In the following two sections we list the economic benefits provided by forest 

resources occurring within the project area that must be evaluated in order to reach a fully 

informed decision. 

 2. Specific and Measurable Economic Sectors: Effects on other Natural 

Resource-related Employment 

The DEIS needs to acknowledge the economic impacts to sectors other than the timber 

economy. Jobs, personal income (wages or proprietor income) and mixed economy incomes 

(subsistence) realized in surrounding communities directly flow from continued preservation 

of natural environments. Given that non-timber sectors provide significantly higher levels of 

economic activity in surrounding communities, it was important for the DEIS to fully analyze 

these economic sectors in order to provide the information necessary to arriving at a fully 

informed decision. 

 a. Fisheries 

There is ample indication in the project file to indicate that there are ecosystems services 

worthy of discussion at the project level. The DEIS entirely defers project level analysis of 

impacts to fisheries on the ground that the fishery economy is regional in nature.71 Because 

the fishery analysis ultimately arrives at the flawed conclusion that as much as 30 miles of 

road construction and 70 MMBF of timber extraction poses no risk to fishery resources, the 

DEIS entirely declines to inform the public of the annually renewable value of project area 

fishery resources. 

ADF & G specifically raised project-level impacts to fisheries in their scoping comments and 

pointed out that “[i]t is apparent that FS staff has not fully considered the relative values of 

productive watersheds within the Central Kupreanof Project area relative to communities 

here in Central SE Alaska.”72 The agency explained that project area watersheds contribute 

to subsistence, recreational and commercial fisheries and requested that the Forest Service 

review published information used to evaluate potential habitat impacts from proposed 

developments that identifies harvest, catch and productivity data used to identify high value 

community use areas.73 ADF & G technical bulletins expressly identify project area 

watersheds: 

The Department’s information clearly shows that in SE AK, both Hamilton Creek (VCU #s 4250, 

4260) and Castle River (VUC #s 4350, 4360) were/are considered as Primary Salmon Producers 

as well as Primary Sport Fish Producers. These two important systems were also ranked as 

having moderate-high, and highest sensitivity, respectively, for disturbance of Subsistence use 

areas for communities in SE AK. In the same analysis, Tunehean and Irish creeks (VCU #s 4280 

and 4290) and Big John Creek (VCU #4271) ranked as Secondary Salmon Producer. Taken 

together, we believe that this information clearly indicates that most of the potentially affected 

watersheds (5 of 7) have been identifies as productive and valued for the sustained benefits seen 

 

71 DEIS at 3-19. 

72 Cariello, J. 2008. ADF & G Sport Fish Division Scoping Comments. 

73 Cariello, J. 2008. ADF & G Sport Fish Division Scoping Comments (referencing Tongass Fish and 

Wildlife Resource Assessment, 1998, Alaska Deapartment of Fish and Game Technical Bulletin No. 98-

4. 

132 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
16 

in subsistence, commercial and recreational fisheries. Sustained full habitat functioning in these 

watershed is important to our local communities, particularly Petersburg and Kake, and as such, 

we propose that timber sale alternatives and logging prescriptions reflect this.74

In 2007, commercial salmon fisheries in Southeast Alaska were worth $98 million in terms of 

ex-vessel value, meaning that this figure does not include processing jobs, transportation 

jobs and other ripple effects.75 Given the maintenance backlog, the increased road 

construction and the concentration of cutting units around streams, we think this project 

will have real and immediate impacts on the productivity of Primary Salmon Producer 

streams in the project area. The DEIS needs to discuss the contributions of project area 

watersheds to the region’s key economic sectors in order to fully inform the decisionmaker 

and the public about the costs and benefits of this project. 

 b. Recreation Employment 

The DEIS needs to take a harder look at how timber harvesting activities impact the tourism 

industry. The DEIS notes that timber harvest activities would be readily apparent in the 

vicinity of key project area recreation places but concludes that these impacts are temporary 

and ultimately would have “little effect.”76 But this statement ignored the fact that the 

quality of the experience is important to ensuring that visitors return year after year. 

The DEIS needs to quantify the value of recreation to local communities in order to ensure a 

full consideration of project area resource values. Recreation employment can be measured 

in terms of annualized jobs using the same methods to calculate timber annualized jobs. A 

significant portion of visitor expenditures becomes direct income to business owners and 

workers in recreation-related industries (e.g. gas stations, grocery stores, outfitters). Visitors 

spend income in the local area to replensish inventories or to purchase consumer services. 

Theses indirect and induced effects generate income throughout the community. 

In 2004, over 100 businesses, including 17 Alaska businesses, addressed Congress 

pertaining to the outdoor recreation industry’s concerns about logging roadless areas: 

While the timber industry in Southeast Alaska continues a sharp decline ... the recreation and 

visitor industry continues to grow. Using Forest Service data, a 1997 comparison between the 

value of logging Tongass old-growth forest and recreation and tourism use of these lands showed 

that tourism was nine times more valuable than logging. By 2000, recreation and tourism on the 

Tongass contributed 30 time the value of clearcutting the forest. These are particularly interesting 

facts when considering that the failing Tongass timber program cost taxpayers $35 million in 

subsidies that same year. The estimated number of summer visitors to Southeast Alaska slightly 

more than doubled between 1993 and 2001, increasing from 502,800 in 1993 to 1,010,352 in 

2001. Clearly, trees left standing for recreation and tourism contribute substantially more than 

logging to Southeast Alaska’s long-term economy.77

Because the quality of the visitor experience can influence the number of return customers 

that is critical to the health of the tourism industry and local guide-outfitters, we strongly 

disagree that the DEIS can authorize timber extraction and road-building activities adjacent 

 

74 Cariello, J. 2008. ADF & G Sport Fish Division Scoping Comments. 

75 ADF & G. 2007. 2007 Alaska Commercial Salmon Harvests and Exvessel Values. Available at 

www.cf.adfg.state.ak.us. 

76 DEIS at 3-176-177. 

77 Outdoor Industry Support Effort to Safeguard Tongass National Forest for Sake of Customers and 

U.S. Taxpayers. (Septmeber 29, 2004. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 133 Appendix D
17 

to identified recreation sites on Central Kupreanof that avoid detrimental impacts to visitor 

industries. The DEIS needs to include an analysis of the recreational business generated 

through use of the project area in its economic analysis so that the public and decisionmaker 

can evaluate the extent to which this project will impact the dominant economic uses of this 

area. 

 c. The Subsistence Economy 

The value of wild foods on the Tongass has been quantified – wild food harvest provide 115% 

of the protein requirements for Southeast Alaska residents and the total value of wild food 

harvests to Southeast Alaska’s 73,000 plus residents in 1999 was $15,193,527 at $3 per 

pound and $25,322,545 at $5 per pound.78 The DEIS provides specific numbers of 

subsistence harvest from project area WAAs. This is adequate information to calculate the 

value of local subsistence resources by Kupreanof WAAs in terms of deer harvests but the 

DEIS declines to interpret the economic significance of these resources.79 Again, this 

information should have been provided in the financial efficiency analysis. 

 d. Conclusion 

In our view, many values such as individual sport or commercially caught fish or pounds of 

protein harvested for subsistence purposes are easily quantified and have been quantified in 

numerous studies. If the Forest Service can calculate annualized jobs based on MBF 

harvested it can certainly figure out the value of salmon and deer produced from area 

watersheds and recreational jobs per acre of intact forest. We request that an effort be made 

to provide these figures and to consider other ecosystem values that are not as easily 

quantified. 

 3. Carbon Storage 

Carbon sequestration is an emerging topic but there is sufficient information from studies in 

the Pacific Northwest and from Tongass-specific studies to warrant consideration of carbon 

storage values in a project level EIS. Carbon credits have already been exchanged for 

between $10 and $20 per ton around the world and carbon credits could be worth between 

$300 and $600 per acre.80 As indicated in one of the most recent Tongass-specific studies, 

The economic value of carbon sequestration associated with the cessation of harvesting in the 

Tongass may be significant relative to the value of the timber harvested. Our best estimates of the 

net annual economic value of carbon sequestration resulting from the cessation of all harvesting on 

the Tongass ($3 million to $7 million/y) are of similar magnitude to the annual revenue from timber 

sales in the Tongass ($6.5 milllion/y)(USDA Forest Service 2001).81

The timber financial efficiency analysis is entirely unsatisfactory for omitting this information 

that is well known to the Forest Service and an ongoing research focus of Forest Service 

scientists. We recognize that there is ongoing research into Tongass-specific sequestration 

capacity but still request that the DEIS mention that carbon sequestration values are 

 

78 Wolfe, R. 2000. Subsistence in Alaska: A Year 2000 Update. ADF & G Div. of Subsistence: March, 

2000. 

79 DEIS at 3-87-88. 

80 Walls. 1999. 

81 Leighty, W., S. Hamburg & J. Caouette. 2006. Effects of Management on Carbon Sequestration in 

Forest Biomass in Southeast Alaska. Ecosystems (2006) 9:1051-1065. 

134 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
18 

significant in relation to timber sales values and quantify the value of sequestration per acre 

based on the most recent available science. 

 D. Conclusion 

The analysis of timber economics is entirely deficient in numerous ways – it fails to account 

for export policy, fails to account for the inefficiency of the large sale program and fails to 

account for impacts to other valuable forest resources. As noted in the DEIS, timber 

harvests from public lands provides but a small fraction of regional employment. The notion 

that this project could somehow fulfill the purpose and need of providing regional resource 

development opportunities is wholly undermined by the Forest Service’s own recent sales 

data and export policy liberalization – even at increasing levels of export authorizations 

numerous recent sales have solicited no bids or solicited bids and been returned. 

The lack of quality analysis, misleading information and failure to incorporate other 

economic sectors into the analysis violates NEPA. In addressing the implications of income 

and employment trends, resource economists have pointed out that timber projects such as 

this are entirely misguided: “the ability of forest policy to impact the regional economy via the 

timber sector will be small.”82 Therefore, 

Although timber from the Tongass continues to play a role and efforts to assist the wood products 

industry restructure should continue, timber is not likely to be the most important contributor to 

future socioeconomic well-being in the area. Based on regional, national and international 

economic and demographic trends, the roles the Tongass plays as a provider of tourism and 

recreation opportunities and as the custodian of many of the unique natural amenities and 

ecosystem values that both attract tourists and enhance the quality of life for existing and potential 

residents, is likely to be of more importance to the economic vitality of the region. 83

In a revised DEIS, please prepare an economic analysis that accurately depicts job 

generation, public costs and costs to other natural resource uses. As indicated above, there 

are numerous ways to quantify ecosystem services and requirements to discuss those values 

when they are not quantifiable. Without a hard look at these figures and values, an informed 

decision about the economic efficiency of this project is simply not possible. Clearcut logging 

has dramatically reduced numerous fish and wildlife populations throughout the coastal 

temperate rainforest biome. It is wholly unreasonable for the Forest Service to ignore these 

impacts by employing deceptive but bogus measurements of effects to these resources as an 

excuse to avoid analyzing them. 

IV. Significant Issue Two: Impacts to Roadless Areas 

Thank you for responding to our request to consider impacts to inventoried roadless areas as 

a significant issue for this project. It is especially critical that Inventoried Roadless Areas on 

central Kupreanof Island be maintained in an undeveloped state because of the significant 

past harvest and road construction that has occurred on this portion of the island and on 

nearby islands including Kuiu. Alternative 3 in particular proposes substantial road 

construction and timber harvest, mostly from the South Kupreanof IRA. 

 

82 Crone, L. 2005. Southeat Alaska economics: A resource-abundant region competing in a global 

marketplace. Landscape and Urban Planning 72: 215-233. 

83 Id. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 135 Appendix D
19 

From an economic perspective, the uniqueness of these areas creates economic value by 

supporting the aforementioned fishery, recreation and subsistence economies. From an 

ecological perspective, inventoried roadless areas provide benefits to fish, wildlife and 

vegetation that are unavailable in developed areas. Further, given the strong scientific 

support for protecting Tongass roadless areas, including that of the TLMP Peer Review Team 

(Powell et al., October 1996 and September 1997), and the strong public sentiment that these 

areas should be protected, we see no valid reason for moving forward with any project that 

directly or indirectly degrades roadless areas and associated resources. 

 A. The DEIS Should Analyze Economic Costs and Benefits Specific to the 

Roadless Areas 

In scoping comments, we pointed out that there are increased taxpayer deficits associated 

with road construction and timber take in roadless areas. We requested that the Forest 

Service consider the economic viability of proposed roadless cutting units and ensure that 

alternatives emphasize logging in areas where road construction is not necessary. 

Timber harvest from roadless areas greatly increases costs. The DEIS clearly demonstrates 

that the bid value per alternative consistently decreases as the amount of impacted roadless 

acreage increases. Alternative 4 avoids roadless timber harvest and road construction and 

has a negative bid value of - $65.96 per MBF. Alternative 2 takes timber from 341 acres in 

the South Kupreanof IRA, mostly through helicopter logging with one mile of road and has a 

negative bid value of -$74.93 per MBF. Alternative 3 would have a tremendous impact on 

the South Kupreanof IRA with 1,184 acres of timber harvest and 15 miles of road and is by 

far the least economical sale with a negative value of -$86.55. 

Conversely, in 2000, two economists studied the economic values associated with leaving 

roadless areas intact. The found that the average value of a recreation visitor day in a 

roadless area is nearly $42.00 per day and that roadless recreational expenditures flowed to 

other economic sectors and supported economic development outside the roadless areas.84

If you proceed with this project with continued planning for logging in the roadless units, 

please include information in a table or format that allows the public and the reviewing 

agency the opportunity to compare the economics of the sale in terms of roaded and roadless 

areas. The poorer economics associated with roadless cutting units indicate that making 

these units available will do little to satisfy even the narrow purpose and need for this project 

and further analysis would better inform the development of reasonable alternatives. We add 

that this analysis should consider the unique values associated with leaving roadless areas 

intact. 

 B. Roadless Areas Are Critical to Biodiversity and Species Viability and These 

Values Need to be Fully Analyzed Prior to the Inclusion of Roadless Units in 

Alternatives 

Tongass specialist reports on the draft roadless EIS have noted that “[t]he Tongass is unique 

[from other national forests] because the majority of subsistence and game species are 

integrally linked to the habitat qualities provided by unroaded areas.”85 Also: 

 

84 Loomis, J.B. & R. Richardson. 2000. 

85 Johnston, 2000. Biological Resources Effects. 

136 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
20 

Because relatively little is known about the current status, needs and response to management 

activities for some species on the Tongass, conservative management approaches that emphasize 

retention of roadless areas may provide a necessary “buffer to ensure higher likelihoods of 

maintaining biodiversity and species viability.86

Roads and road maintenance significantly disrupt these environments: 

Roads increase air and water pollution, promote the spread of invasive exotics, reduce watershed 

integrity, compromise fish and fish habitat, increase surface erosion and landslide potential, and 

are associated with declines in wildlife numbers.87

136 scientists had the following comments about roadless areas in their 1997 letter to 

President Clinton that best states our general concerns: 

A substantial amount of scientific information collected from both aquatic and terrestrial 

environments has demonstrated the importance of roadless areas in protecting the nation’s wildlife, 

fisheries and water resources. ...[T]hey act as de facto refuges for numerous sensitive plant and 

animal species, reservoirs of genetic material, and benchmarks for experimental restoration efforts 

in intensively managed landscapes. [...] The ecological risks associated with developing these 

areas are extremely high, and may jeopardize the flow of goods and services that the national 

forests currently provide to human society.88

Our review of the minimal information provided in the DEIS and planning record verifies 

some of these concerns. According to the unit cards, incursions into the roadless areas 

entail road construction on wetlands and timber harvest from forested wetlands in the South 

Kupreanof IRA and risks to sensitive plants in the North Kupreanof IRA. Some of the units 

in the South Kupreanof IRA were apparently deemed important to connectivity for wildlife as 

they were previously recommended for inclusion into the small OGR.89 

Unfortunately, neither the DEIS nor the planning record provides any further information 

about site-specific roadless values. Because of the significance of this issue, other Tongass 

ranger districts have provided information about specific wildlife uses of roadless areas to 

better inform decisions about roadless cutting units and we request that this DEIS do the 

same before any further planning on this project.90 We reviewed the 2003 roadless area 

evaluation FSEIS and identified just a few of the numerous values that should have been 

analyzed prior to making the decision to proceed with alternatives that impact the roadless 

areas: 

(1) the South Kupreanof roadless area “contains either the entire stream or the 

headwaters of approximately 20 ADF & G-numbered salmon producing streams”; 

(2) there are high opportunities for remote recreation; 

(3) nearly all of the project area MIS and northern goshawk inhabit the roadless area, 

including known goshawk nests; and 

 

86 Id. 

87 Dellasala, D. & J. Strittholt. 2006. Impact of Inventoried Roadless Areas and Unroaded Lands to 

Oregon’s Natural Hertiage. 

88 Loomis, J.B. & R. Richardson. 2000. 

89 Parsley, C. 2006. Central Kupreanof Susbsistence Draft. 

90 See e.g. Iyougtug Timber Sales FEIS. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 137 Appendix D
21 

(4) the cities of Kupreanof and Petersburg opposed extensive logging and road 

construction in roadless area watersheds.91

In sum, we request that the Forest Service review the fish and wildlife values and other 

ecological services provided by the roadless areas, survey roadless cutting units for these 

values and discuss the results in a revised DEIS prior to proceeding with planning any 

timber harvest in the roadless areas. 

 C. Concerns About the Legality of Roadless Entries 

We continue to have concerns about the continual loss of potential Wilderness areas on the 

Tongass and the impacts these losses will have on local economies as well as fish and 

wildlife. The South Kupreanof and Rocky Pass IRAs have high WARS ratings that may 

diminish through this and other future proposed actions. 

Also, we think that roadless areas should remain intact on the Tongass pending NEPA 

analysis of the temporary exemption of the Tongass from the Roadless Area Conservation 

Rule. The Forest Service has repeatedly relied on a combination of the November 2000 

supplemental information report and the absence of significant new circumstances to excuse 

the need for a supplemental EIS.92 But neither the 2000 RACR FEIS nor the 2003 SEIS ever 

analyzed the reallocation of 234,000 acres from natural LUDs to development LUDs. 

Further, the rationale for the temporary exemption was inadequate. The exemption is still 

being justified based on the 2000 FEIS’s anticipation of “substantial negative effects.”93 The 

Forest Service needs to reevaluate whether the reinstatement of the roadless rule would have 

negative effects given that the exemption has not ameliorated the loss of timber jobs in the 

region and has little chance of improving the timber economy in the foreseeable future. 

Due to the unsettled legal status of the temporary exemption of the Tongass from the RACR, 

we request that all roadless units be removed from further consideration. In the event that 

the Forest Service proceeds with these units, please evaluate whether “substantial negative 

effects” would result from leaving them intact. 

V. Significant Issue Three: Road Management and Access 

We incorporate by reference here the scoping comments of Greenpeace and the Cascadia 

Wildlands Project pertaining to the transportation system and road construction in the 

project area. In particular, we would re-emphasize the concerns about the maintenance 

backlog and lack of funding for restoration. Given the high value of fisheries and the low 

value of timber extraction, we find it particularly disturbing that the public funds road 

construction projects that degrade salmon habitat with no real assurance that mitigation 

measures will occur in a time frame that comports with short spawning cycles, if ever. 

We will summarize the issues that the DEIS must address further: 

 

91 USDA Forest Service. 2003. Final Supplemental Impact Statement, Roadless Area Evaluation for 

Wilderness Recommendations, Volume II: Appx. C part 1. 

92 December 20, 2003 FR at 75141. 

93 Brewster, P. 2008. Recommendation to Appeal Deciding Officer on the Iyouktug Timber Sale Appeal. 

USDA Alaska Region, Juneau, AK: Aug. 7, 2008. 

138 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
22 

(1) there needs to be a discussion of road density by different elevation categories – below 

and above 800 feet - in order to fully assess impacts to wildlife; 

(2) in light of the extensive road construction proposed for this project, tiering to the as 

yet undeveloped Peterburg ATM is inadequate and the DEIS should address our 

scoping request that if temporary roads are to be constructed, there needs to be full 

information regarding the duration of their use, their maintenance regime, and how 

they will be stored or decommissioned once they are no longer necessary; 

(3) NEPA’s requirement to analyze cumulative impacts requires the Forest Service to 

complete the ATM process before making a decision on roads for this project because 

road management under this sale is inextricably connected to the overall ATM plan 

and the impacts need to be considered in a single NEPA document; 

(4) lack of maintenance is a serious concern and the DEIS needs to analyze whether there 

will be sufficient funds to (a) maintain an increasing number of road miles; (b) 

decommission and store an increased number of road miles and (c) pay for culvert 

repairs and 

(5) in particular, drop roads 45803 and 45808 because of impacts to roadless areas, 

headwater crossings and other habitat impacts. 

VI. Wildlife: Impacts on Wildlife Habitat and Populations 

In general, the wildlife section is an example of why we object to the production of a 

“streamlined” DEIS. There was little information about potential impacts to wildlife – the 

DEIS considered only five MIS and entirely omitted the section on Threatened, Endangered 

and Sensitive species (TES). There was no project-level analysis discussed other than 

generalized statements about remaining productive old growth. The Wildlife Resource report 

appears to be a draft version of the text in the DEIS and does not provide any site-specific 

information about wildlife habitat use in the project area. 

 A. The DEIS Needs to Actually Analyze Wildlife Habitat Values 

The DEIS entirely failed to take a hard look at impacts to wildlife. The wildlife analysis for 

this project declined to use population models and instead simply measured effects based on 

a “quantitative approach which looks at the reduction of productive old-growth” without 

considering the value of specific types of old growth forests or analyzing the relative 

proportion of productive old-growth to the overall landscape. As a result, for each alternative 

the DEIS informs the public that habitat reductions are “considered insignificant and [are] 

not expected to affect wildlife populations.”94 The DEIS entirely fails to discuss the 

shortcomings of relying solely on POG reductions to measure impacts.95 The measurement of 

impacts to wildlife was utterly meaningless and we request that project level analysis of 

specific habitat types and needs be provided in a revised DEIS. 

 B. The DEIS Improperly Excluded Analysis of a Number of MIS Species 

The DEIS excludes analysis of a number of wildlife MIS species by tiering to the Forest 

Plan.96 This exclusion misconstrues the purpose of selecting MIS – to indicate the effect of 

amanagement activities on other species with similar habitat requirements.97 Application of 

 

94 DEIS at 3-85 

95 Inland Empire Public Lands Council v. Powell

96 DEIS at 3-69. 

97 36 C.F.R. § 219.19(a)(1)(1982); TLMP FEIS 3-351; Inland Empire Publ. Lands Council v. U.S. Forest 

Serv., 88 F.3d 754, 762 n. 11 (9th Cir. 1996). 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 139 Appendix D
23 

the MIS concept is project specific – the Forest Service should evaluate each project 

alternative in terms of the impact on both MIS species habitat and MIS populations.98 This 

DEIS evaluated 2 large ungulates, two large predators, one small predator and no birds, 

sensitive species or small mammals. Consequently, numerous species with a high 

probability of occurrence in the project area and the species they represent received no 

consideration whatsoever. We request that the revised DEIS analyze impacts to each MIS 

known to occur in the project area. 

 C. Black Bear 

The DEIS says that impacts to black bear “will be inconsequential as bear are generalists, 

using a variety of habitats and are not exclusively dependent on productive old-growth.”99 

This statement exemplifies our concern with using generalized statements that apply forestwide to substitute for project level analysis. In fact, “most high quality black bear habitat in 

Unit 3 is associated with low-elevation, old-growth forest with abundant and productive 

salmon streams.”100 The DEIS needs to evaluate harvest impacts in more detail in terms of 

human caused disturbances to bears, particularly those related to roads and habitat loss. 

 1. Habitat Loss 

ADF & G management reports contradict the unsupported assumption that project impacts 

to black bear will be minimal. In a 2005 report, the agency expressed concern “about the 

extensive habitat changes occurring throughout [GMU 3] due to logging.”101 The agency 

points out that the increased forage from early successional plant communities will soon be 

lost and that the succeeding second growth forest is of little value as bear habitat.102 There 

has already been a 33% loss of summer black bear habitat.103 The agency’s conclusion was 

unequivocal: “[t]he long-term effects of logging will be detrimental to black bears.”104

 2. Hunting Pressure 

The revised DEIS should analyze how road density impacts hunting effort and provide 

updated information about hunting effort. There is a reported increase in black bear hunting 

in nearly all areas of Southeast Alaska.105 The increased take “is compounded by the 

increasing density of roads that are being constructed concurrently with logging in the 

southern islands.”106 This concern also implicates our point about the ecological values that 

inhere in roadless areas because “construction of roads into roadless black bear habitat will 

increase human access, which will likely increase the direct mortality of bears through legal 

hunting kills in defense of life and property, illegal killing and road kills.”107

 

98 Idaho Sporting Congress v. Rittenhouse, 305 F.3d 957, 971-74 (9th Cir. 2002). 

99 DEIS at 3-70. 

100 Lowell, R.E. 2005. Unit 3 Black Bear Report. Pages 97 – 116 in C. Brown, editor. Black Bear 

Management Report of Survey and Inventory Activities. ADF & G Project 17. Juneau, AK. 2005 

101 Id. 

102 Id. 

103 Schoen, J. & D. Albert. Southeast Alaska Conservation Assessment at Ch. 4.17 

104 Lowell, R.E. 2005. 

105 Schoen, J. & D. Albert. Southeast Alaska Conservation Assessment at Ch. 6.3. 

106 Id. 

107 Id. 

140 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
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The DEIS should have discussed updated information about hunting effort. On average, 

black bear harvest in GMU 3 grew at an annual rate of 7% between 1990 and 2000.108 

Kupreanof Island provides a third of the harvest in this GMU.109 The Board of Game limited 

black bear harvest on Kuiu Island in 2000, creating an incentive to increase black bear 

harvests on Kupreanof.110 Residents of the Organized Village of Kake have observed a steady 

increase in black bear hunting and have asked the Forest Service to consider this increase 

and its effects – not only on black bear populations but also on the ecosystem services 

provided by black bear populations. Please address these concerns in the DEIS. 

 3. The DEIS Needs to Evaluate the Adequacy of Riparian Buffers for Black Bear 

Because of the threats associated with logging and road construction, the Forest Service 

needs to consider the recommendations of the recent studies on the importance of riparian 

buffers to bear populations.111 The TLMP does not delineate specific buffers for black bear 

but does direct that riparian buffers be increased from the standard buffer to 500 feet in 

important brown bear foraging areas. Black bear are more secretive than brown bear and 

should receive additional protection. The availability of spawning salmon as a food resource 

is a major influence on bear habitat quality and bears have the highest vulnerability to 

human activities in low elevation riparian areas during summer months.112

We request that the DEIS clarify whether class I streams will have only the minimum 100 

foot buffer or whether black bear foraging areas will receive additional protections pursuant 

to 2008 TLMP guidance and the recommendations of regional bear experts. We add that 

experts recommend implementation of the 500 foot buffer for bears on both sides of class I 

streams regardless of whether or not there have been project field observations of an absence 

of anadromous fish. 

 4. Conclusion 

In sum, the analysis of impacts to black bear was wholly inadequate and there have been 

ample concerns raised that were sufficient to trigger detailed analysis. Please fully discuss 

impacts to black bear in a revised DEIS and include site-specific information about riparian 

habitat use, updated hunting information, the cumulative effects of increased road density 

and illegal take and other topics listed above. 

 D. Marten 

The DEIS fails to provide any project-level analysis of impacts to marten. It simply cites 

TLMP Standards and Guidelines, Conservation Strategy, OGRs and buffers without 

discussing how or where these measures apply in the project area. 

This is the first wildlife analysis we have seen on the Tongass that fails to evaluate the 

specific habitat needs of marten and instead measures impacts solely on the basis of POG 

reductions.113 As a result, the DEIS provides a “one-size-fits-all” measurement of effects to 

 

108 Lowell, R.E. 2005 

109 Id. 

110 Id. 111 Flynn, R.W.; S.B. Lewis; R.B. LaVern & G.W. Pendleton (2007). “Brown bear use of riparian & 

beach zones of N.E. Chichagof Island: Implications for Streamside Management in Coastal Alaska.” 

Alaska Dept. of Fish & Game, Douglas, Alaska. 

112 Audubon/TNC Conservation Assessment (Albert & Schoen 2007) Ch. 6.3. 

113 DEIS at 3-69. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 141 Appendix D
25 

wildlife that fails to consider specific needs of wildlife species and informs the reader that for 

every action alternative, the “reduction in habitat due to the action alternative considered 

insignificant and is not expected to affect wildlife populations.”114 The DEIS analyzes these 

topics only at the large scales of the biogeographic province and multiple WAA levels without 

ever considering the loss of POG at the project level or by VCU. 

In a revised DEIS, please address the issues discussed below. 

 1. The DEIS Needs to Apply the Marten Model and Factor in Road Density 

But the DEIS also seems to recognize that low elevation habitats have higher value for 

marten, especially in winter and specifically high volume old growth habitats and riparian 

areas have the highest value.115 The interagency habitat capability model (Suring et al. 1992) 

calculates a Habitat Suitability Index (HIS) based on timber volume strata, elevation and 

typical snowfall. For these reasons, the marten model must be applied to consider impacts 

to high value marten habitat. Neither the DEIS nor the planning record includes any 

consideration of high value marten habitat in an unusual departure from the practice of 

most ranger districts of evaluating high value marten habitat in an EIS. 

Total road density in the project area is .35 miles per square mile.116 The DEIS does not 

indicate what project area road density will be when adding in road construction from this 

project and other projects. Alaska Department of Fish and Game area management 

biologists have expressed concerns about increasing road density in this project area and 

prices for pelts are dramatically increasing because of China’s entry into the market for 

marten pelts. Road density is a matter of critical importance for marten and the failure to 

address it in detail would raise population viability concerns. 

In the revised DEIS, please consider road density and incorporate it into the marten model so 

that the public can fully evaluate impacts to marten habitat. Apply the table appended to 

Suring et al. (July 1992), which adjusts model results for road density and ensure that total 

road density is incorporated rather than just open roads. 

 2. Other Factors Affecting Project Area Marten – Forest Structure Retention, 

Prey Densities and Trapping Refugia 

The 1997 TLMP mandated forest structure retention in this biogeographic province but the 

new Forest Plan excludes this area from the new forest legacy standard. The former TLMP 

required 30 percent canopy closure retention in gaps of over two acres in VCUs in high risk 

biogeographic provinces where over 33% of the productive old growth was harvested or will 

exceed that amount after a proposed project activity.117 For VCUs where less than 33% of 

the original POG was harvested, openings larger than two acres needed to retain 

approximately 10-20% of the stand structure.118

Because this DEIS measure POG reductions only at the biogeographic province level and at 

the level of multiple WAAs, we cannot speculate as to the extent of matrix land protections 

that no longer apply to this project area. We request that the revised DEIS include an 

 

114 DEIS at 3-85. 

115 DEIS at 3-71. 

116 Id. 

117 1997 TLMP at 4-119. 

118 1997 TLMP at 4-119. 

142 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
26 

analysis that compares the amount of forest retention for marten in this project area to the 

amount of retention required under the 2008 amended TLMP. 

We are concerned about the viability of marten populations on Kupreanof because of the 

weakened forest plan standards and the previously mentioned pelt market changes and road 

density. Please evaluate whether the new Forest Plan will adequately maintain marten 

population viability in the project area or whether additional protections will be necessary. 

The DEIS only briefly discusses the significance of patch sizes for marten habitat values and 

entirely omits any discussion of prey availability in the project area.119 Scientists at the 

recent Conservation Strategy Review Workshop made clear that this would be the most 

effective means of addressing marten refugia.120 This DEIS should adhere to the practice of 

Tongass ranger districts by providing a table that identifies the amount of patches of 

sufficient size to provide de facto trapping refugia for marten.121

In sum, we are highly disappointed in the analysis provided for marten and request a revised 

DEIS that uses the marten model, considers trapping refugia and otherwise fully evaluates 

impacts to this species. 

 E. Deer and Wolves 

Given continued effects from past declines in deer population in the 1970s, evidence of last 

winter and this that record-setting snow falls must be anticipated despite global warming, 

and the importance of deer for subsistence, we are particularly concerned about the project’s 

impacts to the Sitka-black tailed deer and wolves. The needs for subsistence resources and 

for wolf viability are closely intertwined, and if wolf viability is not protected, subsistence will 

not be protected either. It has been well documented that road access significantly 

contributes to wolf mortality. 

 1. Wolf Mortality and Road Density 

The construction of significant additional roads associated with the Central Kupreanof 

Project will increase road density. Studies have shown that roads can have a negative impact 

on wolf survival and long-term population viability. Rather than build new roads the Forest 

Service should address ways to close existing roads to reduce wolf mortality in the area. In 

considering road density, the Forest Service must use the total miles of all roads both open 

and closed, using both the mileage and land area below 1200 feet in accordance with the 

best available science.122 

The DEIS does not say much about road density other than to state present road density in 

the project area. There is no disclosure of post-project road density and no discussion of the 

cumulative effects of other road construction projects that are likely to occur. In 2004, ADF 

& G indicated that “the high likelihood of future timber harvest and road construction within 

small areas” implicated long term wolf mortality and viability concerns.123 ADF & G pointed 

out that road densities in some portions of this biogeographic province already exceed 

 

119 DEIS at 3-71. 

120 Tetra Tech 2006 at 12. 

121 Tetra Tech 2006 at 12. 

122 Person. 2006. 

123 Lowell, R. 2004. Letter to Patricia Grantham re Wolf Mortality and Road Density. ADF & G Div. of 

Wildlife Conservation, Petersburg, AK: March 23, 2004. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 143 Appendix D
27 

established guidelines for wolf mortality.124 ADF & G personnel reiterated these concerns 

during the interagency review process.125 Further, ADF & G pointed out that the 

Kake/Petersburg Inter-tie or roads associated with timber projects such as this one will 

trigger or approach recommended thresholds for wolf mortality.126

Under the Forest Plan, the identification of wolf mortality concerns triggers several duties. At 

a minimum, wolf sustainability concerns trigger the duty to further analyze project level 

impacts: “[l]ocal knowledge of habitat conditions, spatial locations of roads, and other factors 

need to be considered by the interagency analysis rather than solely relying on road 

densities.127 Further, the concerns raised by ADF & G implicate the need to develop a Wolf 

Habitat Management Plan pursuant to TLMP Standards and Guidelines. 

Person and Russell (2008) produced a recent study that needs to be considered in managing 

wolf populations. Please incorporate the findings of that study into a revised DEIS and 

address the following issues: 

(1) discuss the relationship between road density and resident wolf mortality rates; 

(2) discuss the relationship between non-resident wolf mortality and clearcuts; 

(3) discuss the survival rate for dispersing wolves; 

(4) discuss use of closed roads; 

(5) discuss wolf harvests, both legal and illegal and the factors motivating or contributing to 

illegal take and the effectiveness of harvest regulations; 

(6) discuss the relationship between road densities above the TLMP standard and local 

extirpations and 

(7) consider road densities at appropriate elevations.128

 2. Further Site-Specific Concerns: Wolf/Deer Modeling and Subsistence 

We incorporate by reference here the comments of Greenpeace et al. pertaining to the 

analysis of deer and its relationship to wolves and subsistence. As pointed out in those 

comments, the deer model should not be used to predict actual numbers of deer and this 

shortcoming in the model must be disclosed. The DEIS needs to adequately assess affects on 

deer habitat carrying capacity. Further, the measures used to address high value winter 

deer habitat are not adequate – partial harvest prescriptions ultimately create small clearcuts 

that eventually diminish winter deer habitat values. Finally, game management units in 

northern Southeast Alaska have experienced significant winter-related deer mortality in 

recent years. Climate change predictions for Southeast Alaska indicate a likelihood of 

extremes of warm and cold during future winters and greater precipitation. The Forest 

Service needs to analyze the cumulative effects of these events when considering winter deer 

habitat and concentration of hunting effort. Please consider erring on the side of safety in 

protecting winter deer habitat. 

 3. Conclusion 

 

124 Id. 

125 Planning Record Document # 113. 

126 Lowell, R. 2004. Letter to Patricia Grantham re Wolf Mortality and Road Density. ADF & G Div. of 

Wildlife Conservation, Petersburg, AK: March 23, 2004. 

127 TLMP at 4-95. 

128 Person, D. & Russell. 2008. Correlates of Mortality in an Exploited Population. This document is 

on file with the Thorne Bay Ranger District and included in the planning record for the Logjam Timber 

Sale DEIS. Copies can be provided if needed. 

144 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
28 

We think that there are numerous reasons why the DEIS needed to take a harder look at 

available deer habitat, road density and wolves. We here reiterate our request that some 

combination of subsistence/deer habitat/road density impacts on wildlife be considered a 

significant and alternative driving issue. Please respond with a revised DEIS that includes 

multiple alternatives to respond to these concerns. 

 F. Endemics and Small Mammals 

In scoping comments, we requested that you review Cook et al. (2006), Smith (2005), and 

Smith & Zollner (2005) and apply the understandings and advice of those papers in 

analyzing the effects of the project on small mammals and especially endemics. We explained 

that thorough surveys were needed to enable meaningful analysis and pointed out that both 

the 1997 and amended 2008 TLMP required surveys in this circumstance. 

The TLMP recognizes that loss of unique species on the Tongass is an issue of concern. 

Standards and Guidelines require the Forest Service to “maintain habitat to support viable 

populations and improve knowledge of habitat relationships of rare or endemic terrestrial 

mammals that may represent unique populations with restricted ranges.”129 Surveys are 

required when information necessary to assess project-level effects is lacking.130

But the DEIS simply excuses analysis on the ground that Kupreanof Island received a 

relatively low rating for endemism in comparison to other islands.131 The DEIS (and identical 

language in the Wildlife Resource Report) lists a number of endemic species but then says 

that Forest Plan standards and guidelines are met by the following analysis: 

Species that are associated with old growth would be affected because we are harvesting old 

growth. Old growth habitat is being removed causing a change at the stand level. This change will 

remove cover and possible habitat for small mammals they may be exposed to a greater degree to 

predation. The increased side light may provide an increase in vegetation that may benefit small 

mammals. This analysis is adequate for all old growth species based on site specific old growth 

and connectivity analysis and the Forest Plan analysis.132

Given that a large number of the endemic species identified by Macdonald and Cook inhabit 

Kupreanof Island, we do not think that general statements about old growth removal 

affecting small mammals in a general way meets Forest Plan guidance. This discussion 

provides no indication as to whether enough information exists to excuse further research 

into endemic habitat in the project area. Cook et al. have pointed out an absence of 

information about the lineages of ermine on Kupreanof and in our view this is enough to 

trigger Forest Plan survey requirements. 

Further, in our scoping comments we requested that the DEIS consider connectivity between 

Kupreanof Island and other areas for endemics as this issue was an element of the forestwide Conservation Strategy. We would point out that black bears from Kuiu have been 

observed on Kupreanof, goshawks have departed Prince of Wales for Kuiu, and the roadless 

FSEIS has indicated the northern flying squirrels from Prince of Wales have started to occupy 

project area roadless areas. The Forest Service is well aware that cumulative impacts of 

 

129 TLMP at 

130 TLMP at 

131 DEIS at 3-73. 

132 DEIS at 3-74. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 145 Appendix D
29 

logging on dispersal and isolation of these populations needs further examination and that 

adequate surveys have not been conducted on many portions of larger islands.133

In sum, please conduct surveys for endemics and discuss what existing information there is 

on endemism in the project area and what information is still needed to assess project level 

effects. Please also evaluate the role of Kupreanof Island as available habitat for endemic 

movement from other islands. 

 G. Goshawks 

The goshawk is a sensitive species, meaning that population viability is a concern on the 

Tongass. TLMP Standards and Guidelines mandate that “[s]pecial consideration should be 

given to the possible adverse impacts on habitat of sensitive, threatened and endangered 

species.”134 The goal of the sensitive species program is to ensure adequate numbers and 

distribution of species and avoid extirpation and/or federal listing.135 We expected that this 

DEIS would adhere to the usual practive of Tongass ranger districts by describing impacts to 

goshawks in greater detail because, as one recent DEIS explained, this species has additional 

management concerns.136 Residents of Kake have reported goshawk activity in the project 

area and the 2003 roadless FSEIS has indicated that goshawks use project area IRAs. 

But the DEIS entirely omits analysis of the goshawk despite acknowledging a high probability 

of occurrence in the project area and the potential for measurable effects.137 Instead, it refers 

the reader to a Biological Evaluation that was not included in our copy of the planning 

record.138

This raptor is the rarest and most old-growth dependent of all the North American goshawks, 

has been virtually extirpated from Washington and Oregon and is listed as a threatened 

species in Canada. The extinction risks are all due to extensive logging of old growth forests 

in those areas.139 In our scoping comments, we requested that the Forest Service complete 

and document at least two years of goshawk surveys in all proposed units and roads using 

the best available science, along with a habitat quality analysis takes into account all 

available information on differential utilization of various forest types and structures. Since 

the new Forest Plan has eroded protections for this raptor, we requested a detailed 

discussion of measures that will be taken to maintain goshawk population viability. 

The FWS recently concluded that the Queen Charlotte goshawk warrants protection as an 

endangered species in Canada but not in Alaska.140 The FWS determined that logging has 

eliminated roughly half of the species’ rangewide habitat and expects continued habitat 

declines.141 The FWS based its determination that Alaska populations did not merit listing 

based on two conclusions: 1) the 1997 forest plan provided adequate protections for the 

 

133 Haufler et al. 2005. Maintaining wildlife habitat in southeastern Alaska: implications of new 

knowledge for forest management and research. 

134 2008 TLMP at 4-89. 

135 2008 TLMP FEIS at 3-226. 

136 Iyouktug DEIS at 3-135 (September 2007); Baht DEIS at 3-147 (October 2006). 

137 DEIS at 3-67. 

138 DEIS at 3-69. 

139 U.S. FWS. 2007. Queen Charlotte Goshawk Status Review. Juneau, Alaska: U.S. Fish and Wildlife 

Service, Alaska Region. April 25, 2007. 

140 Greenwald, N. 2007. Queen Charlotte Goshawk Granted Protection as Endangered Species in 

Canada, But Not Alaska. Portland, OR: Center for Biological Diversity, November 8, 2007. 

141 Id. 

146 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
30 

goshawk and 2) the Canadian and Alaskan populations constituted two distinct population 

segments (DPS) so that the agency could consider each DPS separately in its listing 

decisions. 

The reviewing public should not have to request and review a planning record in order to 

ascertain whether or not the Forest Service is playing Russian roulette with the Endangered 

Species Act. 

Because of concerns pertaining to this species, we request that the Forest Service revise and 

redo this DEIS and provide a TES section that fully analyzes impacts to this raptor. Please 

discuss the results of surveys and provide maps of historic or occupied nest sites and stands 

and locations of other observations of goshawk habitat use. Please discuss how Forest Plan 

guidance, the TLMP Conservation Strategy and information from recent scientific studies will 

be considered and implemented to goshawk habitat in the project area. Specifically, we 

request that the DEIS discuss nest buffer sizes, foraging habitat and matrix land protections 

– especially for nest sites located outside of the OGRs. 

 H. Fragmentation, Connectivity and Old Growth Reserves: Impacts to TLMP 

Conservation Strategy 

 1. The Forest Service Needs to Discuss the Inter-agency OGR Recommendations 

and Implement Those Recommendations 

During scoping, we requested an extended scoping period because of several concerns 

pertaining to the scoping notice. The LUD and Unit Pool maps did not take into account the 

updated old-growth reserve proposals in the 2008 Forest Plan revision. We requested an 

updated and accurate unit pool map that reflects modifications to small old growth reserves 

based on interagency small old growth reserve review recommendations that were 

incorporated into the forest plan. The reserve locations affected the available unit pool – 

without the updated map, we were not able to evaluate and comment on the proposed action. 

We further pointed out that the amended forest plan map did not adopt all of the interagency 

old-growth reserve proposals. We requested that the Forest Service consider making a nonsignificant amendment to the new forest plan and modify old-growth reserves to conform to 

the interagency biologist’s recommendations or explain why the recommendations were 

rejected. 

Throughout the wildlife section the DEIS asserts that the old-growth reserve component of 

the Conservation Strategy on Kupreanof adequately protects endemics and a number of MIS 

species.142 NEPA requires discussion of a “full range of responsible opinion on environmental 

effects.”143 We believe this means that the Forest Service must explain to the public the 

reasons for modifying the inter-agency recommendations and disclose the inter-agency 

recommendations in the DEIS with a map so that the public can review and comment on 

fragmentation and connectivity. 

It appears that the not all of the interagency OGRs providing east-west connectivity were 

adopted. Cutting units 276 -280 were include in a previous OGR recommendation but in the 

DEIS they appear as cutting units.144 We have often found it difficult to seek out and review 

 

142 DEIS at 3-69; 3-74. 

143 Seattle Audubon Soc. V. Moseley, 798 F.Supp. 1473, 1479 (W.D. Wash. 1992). 144 Parsely et al, 2006. Draft Subsistence Alternative. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 147 Appendix D
31 

material necessary to analyze the effectiveness of old growth reserves. The DEIS should have 

provided a map showing both the interagency recommendations and the public should not 

have to delve into the TLMP planning record to evaluate the history of OGR development in a 

project area. 

In sum, please discuss the history of OGR design for the project area and include maps of 

the interagency recommendations. Please also explain the reasons for any divergences from 

the interagency recommendations. 

 2. Fragmentation and Connectivity 

In scoping comments, we requested that the DEIS detail what impacts additional logging and 

other development activities in the surrounding area will have on wildlife populations by fully 

explaining the extent of habitat fragmentation in the area to date, and analyzing the 

cumulative effects from the logging and road construction associated with this project. We 

also requested that the Forest Service discuss and map both low elevation coarse canopy 

forest (and such forest generally) in the sale units, and at larger scales. We requested 

specific details about the current and future state of wildlife travel corridors and connectivity 

in the area. 

The DEIS asserts that “[c]onnectivity is maintained in the project area.”145 It refers to OGR 

adjustments that provide for connectivity but does not explain what those adjustments are or 

discuss the inter-agency recommendations. The single paragraph provided about 

connectivity in the DEIS and the Wildlife Resource report does little more than cite Forest 

Plan amendment changes without explaining what those adjustments were or how they apply 

in the project area. It did not discuss the number and nature of the connections between 

various non-development areas nor does discuss the adequacy of those that are connected. 

There is no map showing important connections. There is no discussion of how adequate or 

marginal those connections may be, or how project development will affect them. Corridor 

width, habitat type, elevation and degree of continuity of interior old-growth forest are 

important factors, and must be considered in view of the connectivity needs of a spectrum of 

species. 

Further, in scoping comments, we requested that the Forest Service address the issue of 

connectivity between Kupreanof and other biogeographic provinces. The 1997 Tongass Land 

Use Plan established, in as much as it was possible, an unbroken reserve of un-logged and 

unroaded lands stretching from Prince of Wales Island’s Honker Divide and Thorne River to 

the northern shores of POW. The Forest Service has also acknowledged the importance, and 

has cited as an administrative goal in public presentations, the connecting of the POW 

reserves to the inventoried roadless areas of Kupreanof Island. The purpose of this large 

system of connecting reserves was and is to maintain connectivity in an already heavily 

damaged and fragmented landscape. The central Kupreanof Timber Sale Project will 

compromise this established conservation strategy and makes a mockery of the Forest 

Service’s public statements. This concern was not addressed anywhere in the DEIS or 

planning record. 

The treatment of these topics in the DEIS is wholly unsatisfactory and does not satisfy 

NEPA’s requirements to take a hard look at project impacts and to facilitate public 

participation. Please include a connectivity analysis in further NEPA documentation that 

 

145 DEIS at 3-73. 

148 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
32 

includes maps of important connections, considers connectivity between islands and 

addresses species-specific needs. 

VII. Subsistence 

We were disappointed that this DEIS did not consider subsistence as an alternative driving 

issue. The project area is rated in the Tongass Fish and Wildlife Resource Assessment as 

having the “highest sensitivity to disturbance” in ADF & G’s “Sensitivity to Disturbance of 

Subsistence Use Areas” map.146 But the subsistence section included a mere 7 pages of 

content that mostly reviewed past use of a limited number of subsistence resources rather 

and failed to evaluate impacts on the wide range of subsistence uses. 

We requested a detailed discussion of impacts of the proposed road building and logging 

activities on the existing uses of the forest by nearby residents and other forest users. This is 

a particular concern as much of the project area and surrounding lands (including northern 

Kuiu Island) are already heavily fragmented and contain large portions of what is currently, 

or soon to be, unsuitable deer habitat due to canopy closure in the extensive created 

openings and second-growth stands. 

 A. The Analysis of Subsistence Use Fails to Take a Hard Look at Community Uses 

The amended Forest Plan seems to exclude the southern portions of Central Kupreanof from 

consideration as part of the Kake Community Use Area. Our impression is that the project 

area lies within the traditional and ancestral territory of the Kake Tlingit and the southern 

portion of the project area will in any event become increasingly important to subsistence use 

should the Forest Service proceed to increase the density of cutting units in the watersheds 

closest to Kake. The Organized Village of Kake has actively opposed timber sales within its 

ancestral lands in recent years, and we are concerned that further timber extraction would 

significantly restrict subsistence and other cultural and traditional uses. 

It is necessary to consider that many such activities have been displaced from places where 

they once occurred, that continuing displacements caused by past forest development can be 

expected, and that additional displacements or diminishments are adverse and need to be 

avoided. We attached to our scoping comments the document “Position Paper on Customary & 

Traditional Gathering (Subsistence)” by the Organized Village of Kake, April 13, 1997. This 

document details the extent and variety of forest resources used for subsistence and the 

DEIS needed to take impacts to multiple forest resources into account. 

 B. Access 

In scoping comments, we requested an assessment of the impacts on subsistence from 

increased access for sport hunting and fishing due to more roads. The DEIS defers project 

level analysis of road closures and road management objectives to the District Access Travel 

Management process.147 With regard to competition for wildlife, the DEIS concludes with the 

self-contradictory statement that “[i]ncreased access can be favorable for subsistence users 

but may have a long-term adverse impact to users if over-harvesting occurs.”148 Ultimately, 

the DEIS concludes that “[n]one of the action alternatives are expected to have any effect on 

 

146 Cariello, J. 2008. ADF & G Sport Fish Division Scoping Comments. 

147 DEIS at 3-91. 

148 DEIS at 3-91. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 149 Appendix D
33 

the competition between rural and non-rural residents since none of the alternatives change 

the existing access patterns to other communities.”149

We request a more complete evaluation of access issues. Please explain whether there is 

enough motorized access now available to subsistence resource users and whether project 

impacts to subsistence use areas will be responsible for increased access needs to other 

areas. Please also consider that this is not simply a rural-non-rural hunting issue in terms 

of competition but rather an issue of a growing guided sport hunting industry and evaluate 

competition through this lens. 

 C. Subsistence Use of Deer 

Three of the bio-province’s top ranked watersheds for winter deer habitat are within the 

project area. Kake’s subsistence activities have been severely impacted by past public and 

private land timber harvests. Intensive high-grading of higher habitat-value old growth has 

contributed to reduced winter carrying capacity for deer not only here but also on Kake’s 

other major subsistence use area, northern Kuiu Island. The DEIS states that the most 

important area for Kake’s subsistence use of deer is Admiralty Island but fails to mention 

that this area is not as easily accessible for Kake residents. The central Kupreanof project 

will only put additional strains on subsistence uses by residents of Kake. 

Also, analysis of project impacts on subsistence should also consider and fully disclose 

impacts of other proposed timber projects in the area. In particular, there is a large timber 

sale planned on northern Kuiu Island and several others that have been planned around the 

project area. Please specify in the DEIS the status and impacts of these and other projects 

as they have the potential to concentrate subsistence harvest efforts on central Kupreanof. 

Further, the DEIS needs to analyze competition from other predators. Modeling of the 

deer/wolf community is necessary to fully, fairly and accurately discuss and evaluate project 

impacts on deer subsistence hunting. It is well known that Kuiu Island is a predator pit 

where deer populations have not been able to recover due to predation from wolves and black 

bear. As both these species consume deer in the project area, the DEIS needs to discuss and 

analyze competition for subsistence deer harvests from other predators. 

 D. ANILCA Compliance 

The DEIS determines that “in terms of cumulative effects, this project is not expected to 

affect subsistence use of deer in the reasonabl[y] foreseeable future” and that “[n]one of the 

action alternatives has a significant possibility of a significant restriction to subsistence 

uses.”150 This conclusion is based solely on the measurement of changes in POG.151 As we 

have previously explained, this measurement fails to take into account the numerous factors 

affecting deer habitat in the project area nor does it consider the full range of subsistence 

resources used. Please reevaluate the significant restriction finding after fully analyzing 

impacts to subsistence resources. 

Further, the DEIS restates the form language frequently cited in other similar documents 

with regard to whether the Forest Service is using the minimum amount of public land 

necessary to accomplish its objectives – that “[i]t is not possible to lessen timber harvest in 

 

149 DEIS at 3092. 

150 DEIS at 3-89; 3-92. 

151 DEIS at 3-89. 

150 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
34 

one area, and concentrate it in another without influencing one more more rural 

communities’ important subsistence use areas.”152 This recitation of pre-prepared language 

fails to evaluate the concentration of large scale timber projects in affected community use 

areas. By scheduling timber harvest in this project area in combination with the Kuiu 

project and the pending development of the Tonka project, the Forest Service actually is 

concentrating timber harvest in one locale. We request that the Forest Service verify whether 

or not it is concentrating harvest in the Kake and Petersburg community use areas by 

comparing past, current and proposed timber harvest in these areas with other community 

use areas. 

VIII. Hydrology/Fisheries/Effects to Aquatic Habitat 

We discuss some concerns with effects to fisheries habitat in the following subsections and 

also incorporate here by reference the comments of Greenpeace et al. regarding fisheries and 

hydrology impacts from this sale. 

 A. The Forest Service Must Conduct a Watershed Analysis 

The TLMP directs the Forest Service to conduct watershed analyses in cases where there are 

multiple risks to fish in the watershed. Because of the level of past development in this area, 

the likelihood of increased sediment yield risks or erosion potential, and the high density of 

existing and proposed roads along with past maintenance problems, we request a full 

watershed analysis be conducted as required by the TLMP. The reasons why an analysis is 

required are detailed in the following discussion. 

 

 1. Road Construction/Reconstruction 

We have particular concerns about the number of failed culverts across the Tongass. The 

Forest Service is proceeding with road construction and reconstruction on the Tongass 

without adequate assurances that existing and future problems will be fixed. There are 

approximately 2,000 red culverts restricting fish passage on the Tongass and the proposed 

action will add further passage restrictions.153 The Forest Service recently signed a preroading contract for the Sea Level sale at a cost of $580,000 to build 6.9 miles of road for the 

purpose of accessing $215,000 worth of timber. Yet this project leaves 42 red stream 

crossings remaining in area watersheds without any guarantee of funding.154

The explanation of effects relies on mitigation measures that may never be implemented. The 

DEIS says that newly constructed road would be stored within 10 years but defers specific 

road closure analysis to the pending Petersburg ATM.155 This information should be 

included in this DEIS because the Forest Service needs to fully analyze the likelihood of 

implementation of mitigation measures in order to fully assess the cumulative effects of this 

project on affected watersheds. We request that a revised DEIS provide detailed information 

on funding for mitigation measures such as road closures and culvert repairs and detail the 

history of implementation of mitigation measures from past projects. Without this 

information, it is impossible for the public to meaningfully analyze project impacts to 

watersheds. 

 

152 DEIS at 3-93. 

153 Mecum, R. 2008. NMFS Scoping Comments for the Central Kupreanof Timber Harvest. 

154 DEIS at 3-101. 

155 DEIS at 3-104, 3-108. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 151 Appendix D
35 

 2. Hydrologic Function 

The DEIS states that project effects are likely only at small scales for short periods of time 

and changes in water yield, peak flow and timing of water delivery “are assumed to be site 

specific and have negligible effects at the watershed scale.”156 The DEIS minimizes the level 

of hydrologic effects indicating that percentages of harvested acres by watershed are well 

below the 20% threshold that impedes hydrologic recovery. Please evaluate past harvests at 

the scale of riparian forests. Across the biogeographic province, riparian forests have been 

logged at a much higher rate than is shown by cumulative watershed harvest. This concern 

is particularly pertinent in the Big John Bay and Hamilton Creek watersheds where proposed 

clearcuts abut previously harvested stands in numerous locations. 

 3. Stream Class Designation Concerns: Need for a Full Watershed Analysis 

ADF & G requested that the Forest Service undertake additional late-season verification of 

stream class boundaries between class II and class III streams located within timber unit 

boundaries.157 There has been recent evidence of salmon utilization of class III stream 

segments that challenges existing classifications.158 Undetected class III stream usage can 

create conditions where BMPs fails to provide intended protections for headwater tributary 

productivity and for fish populations that may seasonally access these stream segments.159

 B. High-Value Watershed Concerns 

The DEIS entirely failed to take a hard look at project-level impacts to high value watersheds 

or even discuss the unique features of watersheds that will be compromised by this project. 

The encyclopedic recitation of cumulative harvests and road densities combined with the 

uninformed reliance of future mitigation measures entirely failed to address these important 

concerns. 

 a. Marxan Rankings 

This project takes place in watersheds of high ecological value. There are 1,000 miles of 

freshwater salmon habitat in this biogeographic province, making it the fourth highest 

ranked in the region for all salmon combined.160 The major salmon producing watersheds on 

Kupreanof will be directly impacted by this project. VCU’s 4360 and 4380 are ranked under 

the Audubon- Nature Conservancy Marxan Ranking Program as being in the highest tier of 

ecological importance within their bio-geographic province. VCU 4290 is in the 2nd highest 

tier. Four of the bio-geographic province’s most productive salmon producing watersheds are 

within the project area, Hamilton Creek, Castle River, Big John Creek and the Keku 

Creek/Irish Lakes system. These watersheds provide one of the highest amounts of 

freshwater salmon habitat in the region but the project area also has one the highest 

proportions of development LUDs and lowest amounts of protection in the region. The 

community of Kake depends on these watersheds for its fishing dependent economy. 

 b. Unique Fishery Values 

 

156 DEIS at 3-105. 

157 Cariello, J. 2008. ADF & G Sport Fish Division Scoping Comments. 

158 Id. 

159 Id. 

160 Schoen, J. & D. Albert. 2007. Southeast Alaska Conservation Assessment Ch. 4.17. 

152 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
36 

The Forest Service has previously considered four project area watersheds for designation as 

Wild, Scenic and Recreational Rivers but concluded that these watersheds contained no 

features unique to the bio-geographic province.161 However, Castle River and Hamilton Creek 

contain populations of Fall/Winter Steelhead that are unique to the biogeographic province 

and receive special management protections form ADF & G.162 ADF & G requested that the 

Forest Service consider the impacts of increased road access, timber harvest and road 

construction activities to these unique populations.163

 c. Stream Temperature Data 

The DEIS notes that water temperature exceedances have been noted on Hamilton Creek and 

assumes that the exceedances are likely due to the characteristics of the wide channel.164 In 

our administrative appeal of the TLMP, we pointed out that there have been numerous 

stream temperature exceedances throughout the state of Alaska and some particularly 

egregious temperature-related fish kills in intensively managed watersheds on Prince of 

Wales Island. 

Please discuss stream temperature considerations in some detail. When were the 

exceedances recorded? Is the historical stream gage still in operation and if so, how often 

have is it checked? The cumulative effects of climate change and land management may 

pose significant risks to fishery resources and we encourage the Forest Service to take a hard 

look at stream temperature data prior to commencing management activities in high value 

watersheds. 

 C. Use of LTFs 

The LTF proposed for use was recently removed from Alaska’s impaired waterbody list in 

2002 after being listed in 1996. Please evaluate the likelihood that further use could result 

in woody debris accumulation that can impair site productivity for an extended period of 

time. Please include the results of recent dive monitoring surveys, including the existing 

extent and depth of bark accumulation and discuss the expected amount of additional debris 

from the proposed action by alternative. After reviewing this information, please consider the 

option of using barges for transport rather than the LTF. 

X. Timber/Vegetation Silviculture 

 A. NEPA Required the Forest Service to Take a Hard Look at Cedar Decline and 

Regeneration and NFMA and TLMP Require Specific Responses to These Issues 

In our scoping comments, we emphasized concerns about a trend across the forest to highgrade certain types of forest structure stands and cedar species. This problem is magnified 

in the project area because of history of intensive high-grading on both federal and private 

lands within the Kupreanof/Mitkof Island biogeographic province. Highgrading poses risks 

to old-growth associated species including deer, wolves, the American marten, small 

mammals (especially endemics), and marbled murrelets. 

 

161 Cariello, J. 2008. ADF & G Sport Fish Division Scoping Comments. 

162 Id. 

163 Id. 

164 DEIS at 3-97. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 153 Appendix D
37 

Because of these concerns, we requested a thorough discussion of forest stand diversity, tree 

species diversity, species composition within the sale units, and canopy texture variation and 

opportunities for compensatory low-grading. We asked for information about what 

percentage of each sale unit and the project area as a whole is composed of Alaskan yellow 

and red cedar; what percentage of the cedar is dead, in decline, healthy green trees; and 

what percentage of each sale unit is comprised of each of the four canopy texture descriptors 

as well as the number and average diameter of each species to be removed compared to the 

number, average diameter, and diameter distribution of trees expected to be felled, in 

comparison to the same statistics for the affected WAAs and western Kupreanof Island as a 

whole. The DEIS did not respond to these comments. 

NEPA’s “hard look” demanded a more serious inquiry into these issues. Further, the 

diversity provision of the NFMA planning regulations requires the Forest Service to preserve 

tree species diversity and analyze the consequences of forest-wide cedar highgrading in 

circumstances where the agency prescribes diversity reductions to meet multiple use 

objectives. 

 Management prescriptions, where appropriate and to the extent practicable, shall preserve and 

enhance the diversity of plant and animal communities, including endemic and desirable 

naturalized plant and animal species, so that it is at least as great as that which would be expected 

in a natural forest and the diversity of tree species similar to that existing in the planning area. 

Reductions in diversity of plant and animal communities and tree species from that which would be 

expected in a natural forest, or from that similar to the existing diversity in the planning area, may 

be prescribed only to meet overall multiple use objectives. Planned type conversion shall be 

justified by an analysis showing biological, economic, social and environmental design 

consequences, and the relation of such conversions to the process of natural change.165

Because of the high appraisal value of exportable cedar and the deficit sale advertisement 

prohibition, the majority of recent sales have occurred in locations on the southern Tongass 

that contain high percentages of cedar. For the same reasons, sales in the planning stage 

and future federal timber harvests and public land transfers will also occur in cedarsaturated sections of the southern Tongass. A recent market analysis using 2005 prices 

demonstrated this problem. The analysis demonstrated that it was significantly more 

difficult to overcome the deficit sale advertisement ban for north Tongass timber sales than 

for southern Tongass timber sales largely because of the availability of cedar.166

Recent timber sales data corroborates that analysis. Even though cedar was roughly 20% of 

the volume cut in between 2001 1n3 2007, it generated nearly half the value.167 In between 

2003 and 2007, nearly 187 MMBF of the total 221 MMBF sold Tongass-wide came from the 

Petersburg, Wrangell, Ketchikan, Thorne Bay and Craig Ranger districts. 

The DEIS discusses cedar composition but declines to analyze it in any meaningful way and 

ultimately relies on unsupported assumptions in stating that levels of timber harvest “are not 

expected to have an adverse effect on the quantity or composition of cedar.”168 But the 

composition of Southeast Alaska forests is changing due to yellow cedar decline and other 

issues and the Forest Service needs to evaluate how individual timber projects contribute to 

the cumulative impacts on these changes. 

 

165 36 C.F.R. § 219.27(g). 

166 Housley, R. 2007. 

167 FS cut and sold reports. 

168 DEIS at 3-127. 

154 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
38 

 1. NFMA, NEPA and the Forest Plan Require Analysis and Management 

Responses to Cedar Decline at the Project Level 

The TLMP amendment FEIS points out that yellow cedar decline is “one of the most 

widespread and important forest problems on the Tongass.”169 The 2008 TLMP requires the 

Forest Service to monitor forest health and evaluate silvicultural prescriptions in light of 

future stand diversity, particularly overstory species such as yellow-cedar.170 Further, TLMP 

requires the Forest Service to evaluate other units in the project area for the purpose of 

examining the re-establishment of desirable tree species.171

Further, the failure to adequately analyze cedar decline in the biogeographic province and to 

review cedar regeneration prescriptions also violates NEPA in various ways. The absence of 

any discussion of more recent studies undermines the scientific integrity of the DEIS and 

deprives the public and the decisionmaker “of the full range of responsible opinion on 

environmental effects.”172 

In our scoping comments, we indicated that there was ample recent documentation about 

cedar die-off and pointed out that it is more important than ever to conserve yellow cedar. 

We were shocked that the DEIS cited a ten-year old study for the purpose of explaining that 

“[t]he cause of yellow-cedar decline is not completely understood” but “could be caused by 

freeze damage to fine roots.”173 Forest Service scientists have produced four studies since 

that time that refine the root-freezing hypothesis and more clearly tie cedar decline to a topic 

entirely ignored in this DEIS – climate change.174 Also, the Forest Service has clearly 

indicated that yellow cedar decline does alter stand structure, favors succession of other 

conifer species, alters understory successional species and “may lead to diminishing 

populations (but not extinction) of yellow-cedar, particularly when the poor regeneration 

of the species is considered.”175

 The brief analysis provided for this subject was particularly disconcerting because, as noted 

by the DEIS, there are approximately 84,000 acres of mapped cedar decline on Kupreanof 

Island.176 The Forest Health Report included in the planning record contains a map that 

makes clear that the most severe case of cumulative yellow cedar decline is in the project 

area. The material in that report suggests that Kupreanof and neighboring Kuiu Island 

appear to be the two locations in Southeast Alaska where the combination of terrain and 

temperature are most likely to facilitate yellow cedar decline.177

NEPA also requires the Forest Service to consider the cumulative impacts of a proposed 

action which are defined as follows: 

 

169 2008 TLMP Amendment FEIS at 3-120. 

170 2008 TLMP at 4-70 – 71; 4-14. 

171 2008 TLMP at 4-75. 

172 40 C.F.R. § 1502.24; 40 C.F.R. § 1500.1(b); Seattle Audubon Soc. V. Mosely, 798 F.Supp. 1473, 

1479 (W.D. Wash. 1992). 

173 DEIS at 3-125. 

174 See http://www.fs.fed.us/r10/spf/fhp/cedar (providing links to more recent Forest Service studies 

of cedar decline that provide guidance on causes, landscape considerations and regeneration and 

conservation strategies). 

175 Forest Health Report at 59. 

176 DEIS at 3-125. 

177 Forest Health Report. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 155 Appendix D
39 

[T]he incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (Federal or non-Federal) or person 

undertakes such other actions. Cumulative impacts can result from individually minor but 

collectively significant actions taking place over a period of time.178

The cumulative effects of climate change and timber harvest are a significant issues that 

merits detailed analysis. Logging creates openings that create greater soil and air 

temperature fluctuations that directly pertain to the freeze/thaw cycle and cedar decline: 

Air and soil temperatures respond primarily to exposure. Open canopies provide inlets for solar 

radiation that warm vegetation and the soil surface and also allow more rapid loss of energy at 

night. Denser forest canopies intercept solar radiation by shading during warm periods and 

insulate the loss of energy during cold periods, thus creating buffered, less extreme temperature 

conditions. Soils located under open canopies warm more quickly in spring than the soil under 

dense canopies, as expressed by the rapid accumulation of soil degree days in the open canopy 

forest zones. The surface of these soils is also exposed to slightly colder night temperatures due 

to less insulation from the canopy.179

Also, Forest Service scientists have observed that yellow cedar “does not reproduce 

prolifically and may require measures to ensure that it successfully regenerates.”180 These 

scientists are developing a yellow cedar conservation strategy and advise “an active forest 

regeneration program is needed” and that the “success of natural regeneration (e.g., seed tree 

harvests) needs to be evaluated.”181 Further, “[s]urviving yellow-cedar trees in patches of 

intensive decline could have experienced selective pressure favoring spring cold tolerance and 

would be good candidates for genetic testing.”182

We reiterate our request that the Forest Service indicate in the DEIS what portion of yellowcedar proposed for harvest in this project is in decline and what portion is healthy. We 

further request details about regeneration in the biogeographic province so that the public 

can review whether the assumptions made in the DEIS are supported by evidence given that 

the assumptions made contradict the best available science. 

The failure to adequately analyze yellow-cedar decline warrants production of a revised DEIS. 

Please review and discuss the implications of the more recent studies on yellow cedar decline 

produced by Forest Service scientists based in Juneau. In light of these studies and the 

extent of cedar decline in this biogeographic province, the revised DEIS should incorporate 

the findings of these studies into project planning and include alternatives that eliminate any 

logging of healthy yellow cedar trees. 

 2. Red Cedar 

 In scoping comments, we requested that the Forest Service ensure protection of the 

northernmost red cedar stands. It has been noted that neighboring Mitkof Island contains 

 

178 40 C.F.R. § 1508.25(c)(3). 

179 D’Amore, D.V. & P.E. Hennon. 2006. Evaluation of soil saturation, soil chemistry and early spring 

soil and air temperatures as risk factors in yellow cedar decline. USDA Forest Service, Pacific 

Northwest Research Station, Junea, AK. 

180 http://www.fs.fed.us/r10/spf/fhp/cedar/regen.html. 

181 http://www.fs.fed.us/r10/spf/fhp/cedar/management.html. 

182 http://www.fs.fed.us/r10/spf/fhp/cedar/regen.html. 

156 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
40 

some of the northernmost stands of red cedars in the archipelago.183 The DEIS indicates that 

the action alternatives will take between 79 and 191 MBF of red cedar but neither the unit 

cards nor the DEIS disclose the location of these stands. We specifically requested that 

cruise stand data and field observations on stand structure be included in the DEIS and this 

information was critical for the public to be able to review whether or not red cedar would be 

taken from the northernmost extent of its range. Because of the significance and value of 

red cedar, the same TLMP, NFMA and NEPA requirements raised in our discussion of yellow 

cedar also apply here. 

It is important for the public to know how the project’s silvicultural prescriptions will affect 

the success of regeneration efforts. Please disclose the species composition of previous sales 

in the area and the progress of regeneration efforts in those sales, by species. Recent deerexclusion studies indicate that red cedar regeneration in analogous forest types can be 

drastically impeded by deer browsing because of its palatability.184 The authors’ conclusion 

is particularly pertinent to this project area: 

The likelihood that young, year-round palatable, redcears can escape deer browsing in an 

understorey already severely depleted in resources for deer is understandably very limited. Our 

results indicate that any effort to restore redcedar regeneration in old-growth forest patches will 

need to achieve a significant reduction in deer abundance and maintain this reduction over a long 

period of time.185

Ironically, red cedar canopies benefit deer by intercepting more snow than other forest types. 

We recommend that the Forest Service drop any cutting units that contain red cedar. In the 

event that the Forest Service proceeds with planning for red cedar harvest, please discuss 

any proposed cutting units that contain red cedar in detail. We request that you evaluate 

regeneration in these stands and discuss the significance of removing the northernmost 

stands of this species in the context of a changing climate. 

 3. Conclusion 

Yellow-cedar decline and red-cedar regeneration are two of the key areas where the Forest 

Service erred in deferring climate change mitigation to adaptive management at some as yet 

undetermined point in the future. Please discuss the cumulative effects of climate change, 

harvest of live yellow and red cedar trees in subsequent NEPA documentation and discuss 

efforts to monitor these issues in this biogeographic province and identify how the Forest 

Service has implemented its adaptive management approach with regard to these issues. 

 B. The DEIS Needs to Explain the Justifications for Clearcutting 

The DEIS does not provide an adequate justification for the even-aged management 

prescriptions. Previous entries have clearcut large blocks of forest to the detriment of oldgrowth dependent species and salmon runs. If the Forest Service must proceed with this 

project, the revised DEIS should include alternatives that rely on light-touch partial cutting 

prescriptions that fully address wildlife and watershed concerns. 

 

183 Schoen, J. & D. Albert. 2007. Southeast Alaska Conservation Assessment at 4.17. 

184 Stroh, N., C. Baltzinger & J. Martin. 2007. Deer prevent western redcedar (thuya plicata) 

regeneration in old-growth forest of Haida Bwaii: Is there a potential for recovery? Forest Ecology and 

Management 255 (2008) 3873-3979. 

185 Stroh et al. 2007. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 157 Appendix D
41 

The DEIS does not explain whether the clearcutting prescription is for the purpose of 

minimizing windthrow, eliminating dwarf mistletoe or other concerns. The DEIS seems to 

imply that clearcutting is justified “where there are no other conflicting resource issues so 

that residual trees are not damaged by traditional logging systems.”186 It also cites the need 

to improve timber sale harvest economics and logging feasibility.187

NFMA’s standards are clear. Clearcutting may only be used when “it is determined to be the 

optimum method” to meet Forest Plan objectives and requirements and where “such cuts are 

carried out in a manner consistent with the protection of soil, watershed, fish, wildlife, 

recreation, esthetic resources and the regeneration of the timber resource.”188 This means 

that clearcutting is appropriate “only in exceptional circumstances” and when these 

exceptional circumstances exist, the Forest Service must “proceed cautiously” and “only after 

a close examination of the effects that [clearcutting] will have on other forest resources.”189

The DEIS failed to conduct the requisite “close examination” of effects on other forest 

resources. Concerns raised about clearcuts include: (1) creation of young-growth forests 

that are poor habitat for wildlife and understory plant species; (2) reduction of plant 

biodiversity; (3) diminishment of old growth stand structural components; (4) reduction of 

slope stability, increased landslide activity and accelerated erosion and sediment production 

leading to degraded fish habitat.190 All of these concerns point to prescriptions that require a 

much higher forest retention level per unit. Wildlife experts recommend retaining more than 

50% of stand basal area to protect small mammal habitat needs.191 

The DEIS also does not explain the role of TLMP guidance in the decision to proceed with the 

development of large-scale clearcut alternatives. The unit cards do not provide information 

about windthrow risks to units and the DEIS indicates that dwarf mistletoe is minor in the 

project area.192 

Further, the absence of windthrow analysis is particularly troubling because several portions 

of the project area would place new clearcuts adjacent to previous clearcuts that are now or 

approaching the stem exclusion stage. This problem is particularly evident in VCU 4271. 

For example, units 207 and 314 propose 97 and 100 acre clearcuts that abut previously 

harvested stands. This scenario often creates “creeping megacuts” where one contiguous 

clearcut can easily exceed Forest Plan size limits. If cutting unit density is so high in this 

VCU that new units must abut the old ones, there is no reason to clearcut additional units in 

the VCU. 

In sum, we request that the revised DEIS and unit cards provide information about 

windthrow risks, dwarf mistletoe and cedar decline. This information should also include an 

evaluation of the effects of clearcutting on other forest resources. 

 

 

186 DEIS at 3-129. 

187 DEIS at 3-129. 

188 16 U.S.C. § 1604(g)(3)(F)(i), (v). 

189 Sierra Club v. Thomas, 105 F.3d 248,k 251 (6th Cir. 1998). 

190 McClellan et al,. 2000. Alternatives to Clearcutting in the Old Growth Forests of Southeast Alaska: 

Study Plan and Establishment Report. Gen. Tech. Rpt. PNW GTR 494. Portland, OR: U.S. Department 

of Agriculture, Forest Service, Pacific Northwest Research Station. 40 p. 

191 Flynn, R. & M. Ben-David (AR 985 in TLMP planning record). 

192 DEIS at 3-126. 

158 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
42 

 C. Biogeographic Province Highgrading of Large Tree Old-Growth 

An EIS needs to disclose the effect of continued highgrading on the Tongass and this DEIS 

needs to analyze this project in light of continued highgrading.193 The wildlife section 

analyzed POG removal at various scales but the DEIS contains no analysis of highgrading the 

large tree old-growth forests that provide winter carrying capacity for deer. 

Even though the biogeographic province has a high amount of POG, the amount large-tree 

old-growth is low compared to other provinces.194 Therefore, even though only 16% of the 

original POG has been taken, “a conservative estimate indicates that nearly half of the largetree forest has been logged in this province.”195 Nearly half of the remaining large-tree oldgrowth occurs in the timber base.196

In the revised DEIS, please evaluate this project in light of remaining large-tree POG. This 

analysis should include a discussion of highgrading at multiple scales: (1) at the stand level 

in terms of past selections of large tree and high value species and future harvests of these 

species; (2) at the landscape scale and (3) at the biogeographic landscape scale. 

X. Appendix A 

 

Appendix A contains an explanation of the reasons for proceeding with this large sale. We 

recommend that the Forest Service revise this DEIS to include an updated and accurate 

market demand analysis that includes a realistic assessment of the viability of the timber 

industry and that does not overinflate the ability of the timber sale program to offset the 

declines in timber industry employment. 

NEPA mandates that an EIS must not rely on misleading economic assumptions and 

similarly, an economic analysis cannot rely on unexplained assumptions, inaccurate data or 

outdated reports.197

The administrative appeals of the 2008 TLMP amendment by SCS et al., SEACC and The 

Wilderness Society addressed our concerns with the market demand analysis and we will not 

discuss them in detail here. In general, we continue to maintain that the market demand 

analysis and other reasons for developing large sales suffer from the following flaws: 

(1) the Forest Service has misinterpreted Section 101 of the TTRA’s language directing it 

to “seek to meet market demand” as a mandate rather than an exhortation that is 

limited by NFMA’s requirement to be “consistent with providing for the multiple use 

and sustained yield of all forest resources; 

(2) the 2006 market demand analysis and 2008 addendum create four scenarios that rely 

on unrealistic assumptions; 

(3) the history of the timber program over the past decade clearly demonstrates that even 

the low volume scenarios were overly optimistic and 

(4) the most realistic scenario applicable to the current situation is neither the limited 

lumber nor the expanded lumber scenario but rather a scenario of declining demand. 

 

193 NRDC v. U.S. Forest Service. 2005. 

194 Schoen, J. & D. Albert. 200. Southeast Alaska Conservation Assessment at 4.17. 

195 Id. 

196 Id. 

197 Hughes River Watershed Council v. Glickman, 81 F.3d 437, 446 (4th Cir. 1996); Van Abbema v. 

Fornell, 807 F.2d 633, 639-42 (7th Cir. 1986); Johnston v. Davis, 698 F.2d 1088, 1094 (10th Cir. 1983). 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 159 Appendix D
43 

In sum, the Forest Service needs to reevaluate its market demand studies prior to proceeding 

with a project of this scale. At current rates of harvest, there is enough volume in Gates 1 

and 2 of the timber pipeline now to supply the timber industry for half a decade without this 

sale. If the Forest Service proceeds with further planning on this project, we request that 

there be a further addendum to the market demand analysis that evaluates a declining 

demand scenario and considers realistic targets for the timber pipeline. 

XI. Climate Change 

In scoping comments, requested an evaluation of the expected effect of climate change on 

seasonal soil moisture, frequency and intensity of storms, land slides, and changes to 

precipitation patterns. We also asked for an evaluation of the cumulative habitat loss from 

natural forces combined with those from past, proposed, and planned future logging. This 

DEIS entirely omitted discussion of climate change impacts even though the leading 

hypothesis for the 84,000 acres of cedar decline in the project area pertains directly to a 

warming climate. 

NEPA requires the Forest Service to analyze the cumulative effects of climate change 

impacts.198 We addressed a number of specific and projected impacts thoroughly in our 

administrative appeal of the TLMP. In a revised DEIS, please discuss the following subjects: 

(1) the potential for managing the Tongass for carbon sequestration and the loss of 

project area sequestration capacity in the near term;199

(2) whether climate change may affect the ability to reach a desired Forest Plan condition 

in the project area such as forest succession;200

(3) “whether some element of the proposal will result in direct, indirect or cumulative 

effects on GHG emissions or the carbon cycle and the direction of effects”201 and 

(4) whether timber harvest in watersheds cumulatively increases risks due to severe 

precipitation events, landslides and other projected results of climate change. 

XII. Conclusion 

As noted at the outset, it is necessary to re-start the scoping process if the Forest Service is 

to proceed with the volume proposed in the action alternatives. We further request that the 

revised DEIS consider the general and specific concerns about the quantity and quality of 

information provided in the current document because it deals with too many issues in a 

cursory manner. Finally, we emphasize that we would very much prefer to review a DEIS 

that responds to the current status of the timber industry, the needs of the communities of 

Kake and Petersburg and the impacts to fish and wildlife by providing alternatives consisting 

primarily of small sales with an emphasis on avoiding priority watersheds, minimizing road 

construction and avoiding high value deer habitat. Such a DEIS would provide the public a 

much better opportunity to offer constructive comments pertaining to specific cutting units. 

 

198 40 C.F.R. § 1502.22(b)(1); Center for Biological Diversity v. Nat’l Highway Traffic Safety Admin., 583 

F.3d 1172 (9th Cir. 2008). 

199 See FSEEE. January 2009. Help make national forests key to mitigating climate change. 

(proposing amendments to federal laws and forest plans that provide legal authority for making carbon 

sequestration a priority use for national forests). 

200 Kimbell, G. 2009. Climate Change Considerations in Project Level NEPA Analyses. 

201 Id. 

160 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
44 

Sincerely,* 

*Electronic signatures are provided in a separate attachment. 

Paul Olson 

Conservation Director 

Sitka Conservation Society 

Box 6533 

Sitka, AK 99835 

(907) 747-7509 

paul@sitkawild.org

Buck Lindekugel 

Conservation Director 

SEACC 

419 6th Street #200 

Juneau, AK 99801 

Buck@seacc.org

(907)586-6942 phone 

(907)463-3312 fax 

References: 

Alaska Department of Fish & Game (2006). Comments on the Tetra Tech preliminary draft of 

the proceedings of the Tongass Conservation Strategy Review Workshop (of April 2006), June 

15, 2006. 

Caouette, J.P.; Kramer, M.G; Nowacki, G.J. (March 2000): “Deconstructing the Timber 

Volume Paradigm in Management of the Tongass National Forest, PNW-GTR-482. 

Caouette, J; DeGayner, E.(2005). Predictive mapping for tree sizes and densities in Southeast 

Alaska. Landscape & Urban Planning 72 (2005) 49-63. 

Cook, J.; Dawson, N.; McDonald, S. 2006. Conservation of highly fragmented systems: The 

north temperate Alexander Archipelago. Biol. Consv. 133(2006) 1-15. 

Greenwald, N. 2007. Queen Charlotte Goshawk Granted Protection as Endangered Species 

in Canada, But Not Alaska. Portland, OR: Center for Biological Diversity, November 8, 2007. 

Harris, A.S. (1999). Wind in the Forests of Southeast Alaska and Guides for Reducing 

Damage, PNW-GTR-244. 

Juday, G.P.; R.A. Ott; D.W. Valentine; & V.A. Barber (April 1998). Forests, climate stress, 

insects, and fire. In: Weller, G. and P.A.Anderson (eds.) 1998. Implications of global change 

in Alaska and the Bering Sea region. Proceedings of a workshop, June 1997. Center for 

Global Change & Arctic System Research, University of Alaska, Fairbanks. 157p. 

Kiester, A.R; and Eckhardt, C. (March 1994): “Review of Wildlife Management & Conservation 

Biology on the Tongass National Forest: A Synthesis with Recommendations.” PNW Research 

Station, Corvallis, Oregon. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 161 Appendix D
“Develop, Conserve, and Enhance Natural Resources for Present and Future Alaskans.” 

February 2, 2009 

Chris Savage 

District Ranger 

Petersburg Ranger District 

PO Box 1328 

Petersburg, AK 99833 

RE: Central Kupreanof Timber Sale DEIS 

Dear Mr. Savage: 

The State of Alaska reviewed the Draft Environmental Impact Statement (DEIS) for the U.S. 

Forest Service’s proposed Central Kupreanof Timber Sale. Specifically, this project 

proposes to harvest 28.2 to 70.2 MMBF of timber from approximately 1,327 to 3,647 acres, 

and to construct up to 25.1 miles of new National Forest System (NFS) roads, 6.1 miles of 

temporary roads, and to reconstruct up to 9.1 miles of existing NFS roads, depending on 

alternative. Under all the action alternatives, the harvested timber volume would be hauled 

to the existing permitted log transfer facility at Hamilton Bay. The DEIS identified 

Alternative 3 as the Forest Service’s preferred alternative for this project. This alternative 

proposes to harvest approximately 70.2 MMBF of timber from an estimated 3,647 acres, and 

would involve the construction of 25.1 miles of new NFS roads, 6.1 miles of temporary 

roads, and the reconstruction of 9.1 miles of existing road. 

These comments were compiled based on input from the Department of Natural Resources, the 

Department of Fish and Game, and the Department of Environmental Conservation. 

Introduction and Context 

The State appreciates the opportunity to review this document. We share the goal of conducting 

a well-designed timber sale in this area. Unfortunately, for a variety of reasons, we find the 

DEIS, as currently written, inadequate under the National Environmental Policy Act and 

insufficient as a timber sale planning tool. For example, we find that none of the alternatives are 

economically viable. In addition, the Wildlife section and Road Cards lack critical information 

necessary to evaluate the proposal. To address these and other deficiencies, we request the DEIS 

be revised and republished for another round of public review per 40 C.F.R. 1502.9. We fully 

recognize that additional work will be necessary to develop an improved DEIS and we are 

available to assist in this effort. As you know, since completion of the Tongass Land 

 

 DEPARTMENT OF NATURAL RESOURCES 

 OFFICE OF PROJECT MANAGEMENT AND PERMITTING 

SARAH PALIN, Governor 

550 W. 7TH AVENUE, SUITE 1400 

ANCHORAGE, ALASKA 99501 

PH: (907) 269-8431 / FAX: (907) 334-8918 

ed.fogels@alaska.gov

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February 2, 2009 

Management Plan, state resource agencies and the Forest Service have been working together to 

forge a more cooperative relationship. Through implementation of this more collaborative and 

constructive approach, we are confident this timber sale can be designed and adequately 

analyzed in a new DEIS – leading to a successful, economically sound project that also meets 

environmental protection goals and standards. 

ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION 

(Contact: Kevin Hanley, 907- 465-5364) 

Alaska Coastal Management Program

With the notable exception of instream work activities within fish bearing waters, per 11 

AAC 112, the activities described in the DEIS are consistent with the Alaska Coastal 

Management Program under the terms of the Tongass National Forest General Consistency 

Determination (GCD) issued on December 4, 2006. Timber harvest activities under the 

scope of this GCD meet or exceed the standards of the Alaska Forest Resources & Practices 

Act (AFRPA) and Regulations. 

Clean Water Act Section 319 and National Environmental Policy Act (NEPA)

The following comments address both Clean Water Act Section 319 and NEPA concerns: 

 

Stream Crossing Structures on Roads 45808 and 45897 

According to the information presented in the road cards, the culverts that are proposed for 

the Class II stream crossings on Roads 45808 and 45897 will be incapable of providing 

upstream fish passage given the gradients at the crossing sites. Specifically, these include the 

following: 

Road 45808: An 84-inch culvert is proposed for a Class II HC2 channel with a gradient of 6-

15 percent. 

Road 45897: At milepost 1.44, “48in culverts” are proposed for a Class II HC2 channel with 

a bankfull width of 3-50 feet, an incision depth of 3-33 feet, and a gradient of 6-15 percent; at 

milepost 1.58, “48in culverts” are proposed for a Class II HC4 channel with a bankfull width 

of 13-50 feet, an incision depth of 20-66 feet, and a gradient of greater than 6 percent; at 

milepost 1.98, “48in culverts” are proposed for a Class II HC3 channel with a bankfull width 

of 23 feet, an incision depth of 56 feet, and a gradient of 6-15 percent; and at milepost 2.83, 

“48in culverts” are proposed for a Class II Alluvial Fan channel with a bankfull width of 3.4 

feet, and incision depth of 2.5 feet, and a gradient of 18 percent. 

With gradients of 6 to 18 percent, all of these structures would create velocity barriers to 

upstream juvenile fish passage. In addition, the channel incision depths of the streams at 

mileposts 1.44, 1.58, and 1.98 of Road 45897 would require substantial amounts of fill for 

the installation of culverts at these locations, and the culvert proposed for the alluvial fan 

channel at milepost 2.83 would be very susceptible to clogging by bedload and woody debris. 

Consequently, we request bridges, rather than culverts, be installed at these locations to 

ensure the maintenance of fish passage, which is a requirement of not only AS 16.05.841, but 

also the Section 404(f)(1) silvicultural exemption of the Clean Water Act. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 163 Appendix D
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February 2, 2009 

Hamilton Bay Log Transfer Facility 

According to the DEIS (page 3-40), the Hamilton Bay LTF “is a steel piling and concrete 

dock facility” at which the operator will have the option to barge or raft the logs from the 

project area. As indicated in the DEIS (page 3-104), the waters adjacent to the LTF, 

including the log storage area, were placed on the 1996 Section 303(d) list of impaired 

waterbodies due to an exceedance of the water quality standard for residues, specifically, the 

accumulation of bark and woody debris as result of log transfer, storage, and rafting activities. 

Although these waters were subsequently removed from the Section 303(d) list in 2002 and 

are currently in compliance with the Water Quality Standards, given the limited flushing 

capability of this inner portion of Hamilton Bay, the in-water transfer of up to 70 MMBF of 

timber has the potential to once again exceed the residues standard. Therefore, since barging 

is indicated as being feasible at this site, we request it be used in lieu of conventional inwater log transfer, storage, and rafting to avoid the deposition of additional bark and woody 

debris on the benthic habitat of this portion of Hamilton Bay. 

ALASKA DEPARTMENT OF FISH AND GAME 

(Contact: Jim Cariello, 907-772-5224) 

Alaska Coastal Management Program

With the notable exception of instream work activities within fish bearing waters, per 11 AAC 

112, the activities described in the DEIS are consistent with the Alaska Coastal Management 

Program under the terms of the Tongass National Forest General Consistency Determination 

(GCD) issued on December 4, 2006. Timber harvest activities under the scope of this GCD are 

expected to meet or exceed the standards of the AFR&PA and Regulations. 

Alaska Forest Resources and Practices Act

The information provided on the road cards appear to be conceptual and lack site specific stream 

information and proposed culvert size. Due to the lack of information we are unable to evaluate 

this project in accordance with 11 AAC 95.305. The preferred alternative is proposing the 

construction of 25.1 miles of road with 139 stream crossings therefore this represents a 

significant impact to fish habitat and water quality. The road location section on the road cards 

appear to be generic statements and lack site specific information on unstable areas and 

identification of slopes greater than 67%. The lack of information makes it difficult to evaluate 

the project in accordance with 11 AAC 95.285 and 11 AAC 95.290. 

National Environmental Policy Act

ROADS 

The preferred Alternative 3 is proposing the construction of 25.1 miles of new NFS road, 6.1 

miles of temporary road and the reconstruction of 9.2 miles of existing road. There will be 139 

new stream crossings constructed. Of particular concern are the Castle River and Hamilton 

River watersheds, identified as primary sport fish produces in the Tongass Fish and Wildlife 

Resource Assessment (1998). The DEIS Alternative 3 is proposing 29 new stream crossings in 

the Castle River watershed and 31 in the Hamilton River watershed. 

164 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
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February 2, 2009 

The road cards only identify eight stream crossings (AHMU Class I & II) with site-specific 

design criteria. Most of the structures recommended are inadequate for fish passage and do not 

meet FRPA requirements for hydraulic conveyance based on the site specific information 

provided. It appears the stream measurements for these crossings on the road cards (gradient, 

bankfull width, incision) are estimates taken from the Channel Type Users Guide. The lack of 

field data on stream crossing sites along with missing road location information on the road cards 

raises doubt whether the road location has been field verified and if areas of instability and 

slopes exceeding 67% have been properly identified. 

In addition, NFS road reconstruction associated with Alternative 3 would require the 

replacement of two Class I and four Class II crossings. The DEIS should have included crossing 

information along with recommended structures for these locations. 

The ADF&G requests this information to determine if the stream crossing structures are 

designed and constructed in accordance with FRPA standards11 AAC 95.300 and 11 AAC 

95.305 as well as the Soil and Water Conservation Handbook (FSH 2509.22) and TLMP 

Standards and Guidelines. 

ROAD CARDS 

Road 6326

The Road Card for Route No.6326 (Appendix B page 278-280) indicates the .50 mile long road 

is planned however, aerial photos indicate the road has already been constructed. The USFS GIS 

roads cover does not show this road existing. Road Condition Survey data indicates maintenance 

needs with five ditch relief culverts needed. This section of road did not appear on the North 

Irish timber sale maps and it appears it may have been constructed without any NEPA analysis. 

Please explain the history of this road and why the DEIS does not acknowledge that this road has 

already been constructed. 

Road 45897

The first major crossing (at about 1000’) is indicated as a Class III crossing. Has this site been 

sampled for fish? It is questionable that the stream would go Class I to III without some amount 

resident Class II habitat. If possible, adjust road layout to avoid the need for a fish pipe. 

The following sites are proposing 48” culverts in high gradient streams where fish passage 

design will be difficult and it is also questionable whether these structures will meet FRPA 

requirements for hydraulic conveyance. Final designs will need to be reviewed by ADF&G 

Division of Habitat in accordance with the Title 16 MOU: 

Road 45897 MP 1.44 

Road 45897 MP 1.58 

Road 45897 MP 1.98 

Road 45897 MP 2.83 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 165 Appendix D
Central Kupreanof Timber Sale DEIS Page 5 of 11 

February 2, 2009 

Road 45808

The following site is proposing an 84” culvert with a stream gradient of 6-15% where fish 

passage design will be difficult. Final designs will need to be reviewed by ADF&G Division of 

Habitat in accordance with the Title 16 MOU: 

Road 45808 2+00(no milepost noted) 

Road 45886

MP 0.09 Can the road be re-located slightly to avoid the need for the stream crossing? If not, 

final designs will need to be reviewed by ADF&G Division of Habitat in accordance with the 

Title 16 MOU. 

Road 45887

The proposed temp road crosses a Class I stream yet there is no indication of the type of structure 

proposed nor stream geometry. We recommend a temporary log stringer bridge with no instream 

work required. 

Road 45892

At approximately 1500’ the road crosses an alluvial fan with many, small drainages noted in Unit 

254. Locate road at apex of fan to avoid culvert problems and road failure. Numerous V notches 

are crossed (Class III) with no site specific design criteria noted. Road card indicates large 

culverts will be required. 

ROAD RECONSTRUCTION 

The reconstruction of 9.2 miles of NFS road is proposed in Alternative 3, requiring the 

replacement of two Class I and four Class II crossings. Road cards should include site specific 

design criteria for these six sites along with any structures on Class III streams associated with 

reconstruction. 

RED PIPES 

The DEIS does not recognize the cumulative impacts to fish habitat from past road construction. 

With approximately half of the existing stream crossings impeding fish passage, we request the 

DEIS address existing impacts to fish habitat and include actions that would correct fish passage 

deficiencies during implementation of the timber sale and not defer them until road closure at a 

later date. 

In addition, the DEIS indicates on page 3-101 “there are 61 red crossings, 6 gray crossings, and 

56 green crossings within the project area and on the haul route between the project area and 

the Little Hamilton LTF. While 19 of these may be corrected through the proposed road 

closures identified through the RAP process the remaining culverts will be prioritized on a forest 

wide level.” It is unclear how 19 of these crossings may be corrected when the preferred 

alternative states “An indirect effect of this alternative would be the closure of 2.0 miles of NFS 

Roads 6330 and 6327 within 10 years of harvest, including removal of two red fish crossings.”

UNIT CONCERNS

Unit 314: Could the 45886 road alignment to be changed to avoid the stream crossing? 

166 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
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February 2, 2009 

Unit 273: Stream #8/9 is indicated as a Class III crossing. Has this site been sampled for fish? 

It is questionable that the stream would go Class I to III without some amount resident Class II 

habitat. If possible, adjust road layout to avoid the need for a fish pipe. 

WINDTHROW 

The DEIS does not acknowledge the potential for windthrow adjacent to units and on stream 

buffers. Page 3-125 of the DEIS states: “Survey crews examined leave trees and unit edges of 

previous harvest units and stands within the proposed harvest units for windthrow and found 

only minor amounts. The risk of significant wind disturbance as a result of timber harvest in the 

project area was determined to be low due to the insignificant amount of preexisting windthrow 

and an analysis of contributing risk factors. Additional wind protection measures are not 

planned for any of the proposed harvest units.” 

The Kupreanof Island Analysis, page 66, states “The southern end of Kupreanof Island has large 

areas of wind disturbance, but windthrow is found throughout the island.” 

The proposed Threemile Timber Sale harvest was designed to mimic natural disturbance. 

The Threemile Timber Sale FEIS (April 2004) discussed in detail natural disturbance ecology 

and acknowledged “The strongest windstorms on Kuiu Island usually come from the southeast to 

the southwest (Kramer, 1997 and Harris, 1989).” Since the Threemile project area is adjacent to 

the Central Kupreanof project area, it is reasonable to expect similar wind disturbance. Since the 

DEIS is proposing a substantial amount of harvest in the southern end of Kupreanof Island in 

watersheds with high fisheries values, unit cards should address this potential, along with 

measures taken to minimize windthrow. 

The Forest Plan calls for providing reasonable assurance that Riparian Management Areas 

(RMAs) are windfirm. Where the risk of windthrow is moderate or greater, RMAs are protected 

by leaving additional windfirm trees standing adjacent to the RMA. The Unit Cards do not 

include any measures to assure the windfirmness of the RMA. A review of aerial photos of the 

project area show many wind generated stands. Unit 279 for example is adjacent to a wind 

generated stand. 

IDENTIFICATION OF FISH STREAMS 

We request the DEIS include a description of field methods used to verify stream classes, 

identify fish presence and the upper limit of fish habitat. Recent studies indicate seasonal 

movement of fish into higher gradient streams where they might not have been present during 

summer months. We are concerned that fish sampling methods may not be capturing the upper 

extent of fish habitat. ADF&G staff would like to visit several units in summer and fall to 

confirm the accuracy of the determination of the upper extent of fish habitat and will report our 

findings to USFS staff. 

ECONOMICS 

Logging costs evaluated using NEAT_R included barging to the Silver Bay Mill in Wrangell. 

Though this may be the closest the mill has not purchased a USFS sale for years, has no current 

sales under contract and is currently not operating. Appraisal to the Viking Lumber Mill in 

Klawock would be a more realistic appraisal point. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 167 Appendix D
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February 2, 2009 

Table S-1 and Table 2-1 need a footnote to make it clear that an Indicated Bid in parenthesis ( ) 

represent a negative value. 

WILDLIFE CONCERNS 

The DEIS does not provide sufficient information for agency staff and the public to evaluate the 

impacts of the proposed actions on wildlife and their habitats. As stated in 40 CFR §1501 (b) 

“...NEPA documents must concentrate on the issues that are truly significant to the action in 

question, rather than amassing needless detail.” The DEIS for the Central Kupreanof Timber 

Harvest does not meet this standard. In order to analyze and provide substantive comments on 

the potential impacts of the proposed action alternatives on wildlife and their habitats, the 

following information and analysis needs to be included in a revised or supplemental DEIS: 

• A higher quality LUD map showing the location of Old Growth Reserves relative to 

existing units, the unit pool, and existing and planned roads. This is particularly 

important given that the initial public scoping for this project was done with an outdated 

and inaccurate LUD and unit pool map. 

• A coarse canopy habitat map needs to be provided at the same scale as the various 

action and no action alternative maps, and should provide landscape features such as 

existing roads, existing units, volume strata, and the location of old growth reserves that 

allow the reviewer to easily evaluate the location of coarse canopy stands relative to 

proposed harvest units. Also include tables showing the impacts of the various action 

alternatives on this stand type and the resulting changes from the historic condition. 

• Maps showing volume strata or the location of high volume stands in relation to existing 

and planned harvest units and roads, at the same scale as the various action and no action 

alternative maps, and with landscape features such as existing roads, existing units, and 

the location of old growth reserves that allow the reader to easily evaluate the location of 

coarse canopy stands relative to proposed harvest units. Similar to coarse canopy, 

include tables showing the impacts of the various action alternatives on high volume 

stands and the resulting changes from the historic condition. 

• The department continues to have concerns about increasing road densities at various 

locations and geographic scales within the Petersburg Ranger District, including the 

Mitkof/Kupreanof biogeographic province. The DEIS does provide some information 

on open and total road densities at the project level scale, however, it does not address 

cumulative road densities at larger geographic scales. While road densities do not 

currently exceed established recommendations at the smaller project level, human 

access, hunter and trapper harvest, and illegal kill may lead to wolf mortality concerns 

within the biogeographic province. 

• The Central Kupreanof Project Area occurs in a landscape where productive old growth 

stands are naturally fragmented by noncommercial forest lands and muskegs. Because 

old growth fragmentation from both past and planned timber harvest further reduces the 

size and connectivity of old growth forest stands, we request the DEIS include an 

analysis of interior old growth habitat patches and impacts of fragmentation. 

• The northern goshawk has been previously petitioned for T&E listing status, the DEIS 

contains virtually no information on goshawks, even though there are 5 to 6 known 

goshawk nesting areas located within the project area.. The DEIS simply states 

“...Queen Charlotte goshawks have a moderate to high probability of occurring in the 

168 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
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February 2, 2009 

project area and have a potential for measurable effects to the population in the analysis 

area.” Rather than summarizing the analysis of impacts to northern goshawks from this 

project, the document simply refers readers to the Biological Evaluation in the planning 

record. 

• The Kupreanof Island Analysis (USDA Forest Service, 2000) states that ...“The Forest 

Plan has identified Mitkof/Kupreanof biogeographic province as a higher risk area for 

marten.” The DEIS, however, contains no maps of marten winter habitat relative to 

existing and planned timber harvest and roads, and no information regarding the impacts 

of the various action alternatives on high value marten habitat or habitat capability trends 

at the project level, island-wide, and the biogeographic scales. Despite the relatively 

large scale of this project, including up to 70 MMBF of old growth timer and over 31-

miles of new road, the DEIS simply concludes on (Pg 71) “...there is not an anticipated 

effect to the marten population.” We disagree with that statement. 

• Deer are an extremely important species in the region, not only in terms of recreational 

and subsistence hunting opportunity and also as a prey base for maintaining viable wolf 

populations. The DEIS provides little to no analysis or discussion of deer habitat 

capability in the Central Kupreanof Project area and little to no information concerning 

the impacts of the proposed action on important deer winter habitat. 

ALASKA DEPARTMENT OF NATURAL RESOURCES/DIVISION OF FORESTRY 

(Contact: Clarence Clark, 907- 225-3070) 

GENERAL 

Chapter 1, page 2 of the Central Kupreanof Timber Harvest DEIS list 3 purposes for the project 

[emphasis added]: 

1. Manage the timber resource for production of sawtimber and other wood products from 

suitable lands made available for timber harvest on an even-flow, long-term sustained 

yield basis, and in an economically efficient manner. 

2. Seek to provide a timber supply sufficient to meet the annual market demand for 

Tongass National forest timber and the market demand for the planning cycle. 

3. Provide for a diversity of opportunities for resource uses that contribute to the local and 

regional economies of Southeast Alaska. 

The Central Kupreanof Timber Harvest DEIS does not meet any of the 3 purposes as stated 

above. None of the four alternatives presented in the document provide a timber supply that 

meets market demand in an economically efficient manner and contributes to the local and 

regional economies of southeast Alaska. All of the three action alternatives have negative 

indicated bid values; with the DEIS preferred alternative (Alt. 3) being the most negative. In 

light of the Congressional mandate to offer only positive value timber sales on the Tongass, we 

request the revised EIS include an economically viable alternative that addresses this mandate. 

A subset of units from existing alternatives may provide the opportunity to offer a positive value 

timber sale. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 169 Appendix D
Central Kupreanof Timber Sale DEIS Page 9 of 11 

February 2, 2009 

During our review of the DEIS we used Alternative 3 as a foundation to develop an economic 

alternative for the timber sale project; based upon a rough appraisal using information provided 

in the Draft Environmental Impact Statement and Regional Timber Valuation Appraisal 

information, this economic alternative appraises approximately $3/mbf (negative 3 dollars per 

mbf) at this point in time. In January of 2006, the State of Alaska and the USFS Tongass 

National Forest signed a Memorandum of Understanding for the purpose of “...the development 

of economically and technically viable timber sales on the Tongass National Forest....” Under 

this MOU the State of Alaska is interested in working with the USFS to modify Alternative 3 to 

provide an economically alternative for the Central Kupreanof Timber Harvest project. 

Alaska Forest Resources and Practices Act

Chapter 3, page 43 to 44, last paragraph states: “These roads would be intermittent service roads 

(maintenance level one) within ten year and would be physically blocked or natural vegetation 

allowed to eliminate motorized access. Drainage structures would remain in place with 

additional cross drains (water bars and dips), and the road would be considered stored.” 

Under the definition of Road Storage in Chapter 4, it states that drainage structures in live 

streams are completely removed. As copied from other documentation: 

Storage definition from MOU between State of Alaska and USDA Forest Service, Alaska 

Region on Coastal Zone Management Act / Alaska Coastal Management Program – 

Consistency Reviews. (CZMA MOU #00MOU-111001-026) 

Storage: Remove or bypass all drainage structures to restore natural drainage patterns, add 

water bars as needed to control runoff, revegetate. This is intended to be the primary 

maintenance strategy applied on intermittent use roads during their closure cycle. In this 

strategy, bridges and culverts on live streams are completely removed to restore natural 

drainage patterns. Cross drains and ditch relief culverts will be bypassed with deep water 

bars but left in place to minimize the cost of reusing these roads in the future. Due to the 

isolated nature of the road system, which makes maintenance costly and difficult, and their 

infrequency of use, storage is the most appropriate strategy for these roads. Maintenance 

Level 1, closure and basic custodial maintenance, is assigned. Storage eliminates car and 

truck use, and discourages use by other motor vehicles. 

This level of maintenance is synonymous with FRPA closed roads. 

Chapter 3, page 44 and Chapter 4, page 18: The text on page 44 indicates that temporary roads 

will be decommissioned; culverts and bridges will be removed. The definition for Road 

Decommissioning in Chapter 4 does not specifically mention removal of bridges. Based on the 

text on page 44, presume when time comes to decommission the roads, any bridges will be 

removed. Will the removal of culverts include relief culverts or just those on surface waters? 

Chapter 3, page 47 to 48, Alternative 2, 3, 4: States that the specified roads will be closed and 

placed into storage, any red fish crossings would be pulled at time of storage. As indicated in 

Comment #1, storage translates to closed under Alaska Forest Resources and Practices Act; to be 

considered closed under AFRPA (11 AAC 95.320), all bridges, culverts, and fills need to be 

removed from surface waters. 

170 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Central Kupreanof Timber Sale DEIS Page 10 of 11 

February 2, 2009 

Chapters 3, page 52: States “side slopes of greater than 72% would be mitigated by full bench 

construction...” Under AFRPA Best Management Practices, full bench construction or other 

mitigation measures are usually required on slopes greater than 67% (11 AAC 95.290). 

Appendix B, page 235: Second to last paragraph states that when roads are stored, bridges and 

culverts may be removed from live streams. As stated in the USFS definition of road storage, 

structures are completely removed from live streams when a road is placed into storage. 

Appendix B, page 238: Describes the AFRPA road status definitions. Besides the text given, for 

closed roads in areas accessible to highway vehicles the definition also includes road being 

blocked to highway vehicles (11 AAC 95.320(b)(3)). 

Appendix B, page 243 (and other subsequent road cards), Travel Management Narrative: States 

that within ten years, roads will be maintenance level one and the roads will be closed/stored by 

being physically blocked with gate or vegetation and drainage structures will remain in place. 

As stated in the definition of road storage, structures are to be removed from live streams when a 

road is placed into storage. If drainage structures are to remain in place and the road considered 

closed by presence of gate, the road would be classified as inactive under AFRPA and would 

need to be maintained to the appropriate standards (11 AAC 95.315(c)). 

Appendix B, page 263 (and other subsequent road cards): Maintenance Narrative states 

“AFRP&A Regs. Inactive status: Road is stored.” USFS definition of stored road is equivalent 

to closed road under AFRPA. Inactive road under AFRPA is roughly equivalent to USFS 

maintenance level 2. 

Appendix B, page 267 and page 273, 6327 and 45891 roads: The road cards mention the 

crossing of 20 to 30 feet deep v-notches. Best management practices under AFRPA recommend 

a bridge as the preferred structure when crossing deep v-notches or when excessive fill is needed 

for culvert placement (11 AAC 95.300(a)(7)). 

ALASKA DEPARTMENT OF NATURAL RESOURCES/ANILCA PROGRAM 

(Contact: Sally Gibert, 907- 269-7477) 

Timber Sale Relationship to the District Access Travel Management Plan 

The DEIS identifies new and/or improved temporary roads associated with timber harvest areas, 

which are intended for remediation when implementation is complete. It appears (e.g., Chapter 

3, top of page 91) these roads will be available during their temporary life for public use, 

including for subsistence purposes. While we would support this intent, we understand there are 

legal impediments to allowing such public access on temporary roads in active timber harvest 

areas. We request the revised EIS clarify the status of these temporary roads and explore ways to 

allow short-term or limited off-highway vehicle use if possible. As you know, recently harvested 

areas often create productive habitat on the short term and consequently provide enhanced 

opportunities for wildlife and firewood harvest. Over time, such short-term subsistence access 

opportunities could contribute to the intent in Section 811(a) to “ensure that rural residents 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 171 Appendix D
Central Kupreanof Timber Sale DEIS Page 11 of 11 

February 2, 2009 

engaged in subsistence uses shall have reasonable access to subsistence resources on public 

lands.” 

To the extent the DEIS provides for or allows motorized access for subsistence activities during 

the life of the project, the eventual restriction of such subsistence access will require a formal 

closure process to comply with ANILCA Section 811(b), as expressed in the Regional Forester’s 

“Interim Guide: Providing Access for Subsistence Purposes (ANILCA 811) During Access and 

Travel Management Planning,” dated May 23, 2008. This implementation requirement also 

applies to the 1.1 to 2.0 miles of “existing” Forest Service roads that will be closed after timber 

harvest activities are complete. We are available to discuss possible ways to intersect this timber 

sale DEIS and the annual update of the Motor Vehicle Use Map. 

ANILCA Section 810 Analysis 

The Subsistence Section in the Environment and Effects Chapter includes information and 

conclusions that would clearly be a part of a Section 810 Analysis, even though the organization 

of the document does not indicate this explicitly. We also note the Subsistence discussion 

references other sections and other documents that contain certain related analyses. While the 

DEIS contains an “ANILCA Compliance” section that briefly notes conclusions drawn 

elsewhere in the document, it does not reference where the various analyses are located. We 

therefore recommend a titled “ANILCA Section 810 Analysis” section that consolidates the 

pertinent information and conclusions that meet the specific requirements of ANILCA and 

existing Service policy. 

Thank you very much for the opportunity to comment on the Logjam Timber Sale DEIS. If 

you have any questions, you can reach me at 907-269-8423. 

Sincerely, 

Ed Fogels 

Director 

172 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
January 30, 2009 

United States Forest Service 

Attn: Tiffany Benna 

Petersburg Ranger District 

12 North Nordic Drive 

PO Box 1328 

Petersburg, AK 99833-1328 

Re- Central Kupreanof Timber Harvest DEIS Comments 

Submitted electronically on behalf of Audubon Alaska, The Alaska Wilderness League, 

and Trout Unlimited to tbenna@fs.fed.us . 

The Central Kupreanof area contains important fish and wildlife habitat including some 

of the most productive salmon producing watersheds on the central islands of the 

Tongass. Audubon Alaska and Trout Unlimited believe the timber harvest activities 

proposed in the Central Kupreanof Timber Harvest Draft Environmental Impact 

Statement preferred alternative pose significant potential risk to fish and wildlife habitats 

and the long-term viability of both resident and anadromous fish populations within large 

portions of the sale area. We are especially concerned in this regard with respect to the 

Irish/Keku Lakes system (VCU 4290), the Upper Castle River area (VCU 4360) and 

Duncan Bay (VCU 4380). These VCU’s were identified as Conservation Priority 

Watersheds through the TNC-Audubon Conservation Assessment (Albert, and Schoen 

2007; http://conserveonline.org/workspaces/akcfm) 

which was in turn, was used by Trout Unlimited (TU) to identify 31 High Value Fish 

Producing Tongass VCU’s which TU recommended for conservation status as part of the 

recent Tongass Land Management Plan Revision. In addition, the Castle River was 

identified as a one of the top 19 quality fish-producing watersheds in the region by the 

Alaska Department of Fish and Game. Salmon are an important keystone species in 

southeast Alaska and are used by a host of other wildlife species including many birds, 

bears, and wolves. 

Our concerns for salmon conservation in these VCU’s are largely based on the findings 

noted in the “Summary of the 1997 Fish Habitat Risk Assessment Panel” (Dunlap, 1997) 

which was convened by the Forest Service to analyze the impacts of the management 

activities proposed in the seven alternatives in the 1997 TLMP. A full summary of these 

findings is available at http://www.fs.fed.us/pnw/tlmp_app/050797a.pdf , however the 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 173 Appendix D
five primary issues of concern (summarized below) bear directly on the actions proposed 

in the Central Kupreanof Timber Sale EIS. 

1. Roads, especially those that cross streams, may have negative effects on fish 

habitat. The panel identified Prince of Wales, Kupreanof, Kuiu and Chichagof 

Islands as having road densities currently sufficient to be of concern to 

maintaining adequate fish habitat. 

2. Risk to fish habitat increased as the amount of timber harvest increased. 

3. Allocation of reserves free from timber harvest, which include entire watersheds, 

reduces risks to fish habitat. 

4. Watershed Analysis should be conducted prior to management activities (road 

construction and timber harvest). 

5. Protection of the upper portions of watersheds is important to preserving fish 

habitat throughout entire stream systems. 

The DEIS preferred alternative proposes the addition of 25.1 miles of new roads to the 35 

miles of roads presently in these VCU’s. The DEIS also proposes 139 new stream 

crossings in addition to the existing 117 stream crossing (61 of which are “red pipes”) 

(Table S-1 DEIS). We do not believe the DEIS adequately addressed the cumulative 

impacts of the proposed 60 miles of road and 256 total stream crossings. Furthermore, 

the proposed roads and stream crossing quite clearly run counter to the recommendations 

set forth for optimizing the protection of fish habitat set forth by the Fish Habitat Risk 

Assessment Panel. 

Given the high anadromous fish production of the Central Kupreanof VCU’s named 

above and their significant contributions to commercial, sport, and subsistence fisheries 

in the region, we believe VCU’s 4290, 4360 and 4380 should be removed entirely from 

the project. Doing so will protect the outstanding fisheries and wildlife values in the area 

while still providing timber for harvest in adjacent areas. In summary, TU and Audubon 

Alaska strongly object to harvesting timber and building roads in Conservation Priority 

Watersheds with high fish production areas and valuable wildlife habitats. 

We encourage the Forest Service to revise this sale accordingly. Thank you for the 

174 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
opportunity to comment; we look forward to further collaborative participation in the 

future regarding the Central Kupreanof Timber Sale. 

 

Sincerely, 

 Mark Kaelke 

Trout Unlimited 

Southeast Alaska Project Director 

419 Sixth Avenue # 200 

Juneau, AK 99801 

Laurie Cooper 

Rainforest Program Director 

Alaska Wilderness League 

419 6th Street, #228 

Juneau, AK 99801 

John Schoen, Ph.D. 

Senior Scientist 

Audubon Alaska

441 West Fifth Avenue, Suite 300

Anchorage, AK 99501

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 175 Appendix D
Tiffany Brenna 

Tongass National Forest 

Petersburg Ranger District 

Attn: Central Kupreanof Timber Sale 

PO Box 1328 

Petersburg, Alaska 99883 

Re: Comments on Central Kupreanof Timber Sale DEIS 

February 2, 2009 

Dear Ms. Brenna: 

The following comments are submitted on behalf of The Wilderness Society for the 

Central Kupreanof Timber Sale Draft Environmental Impact Statement (DEIS). Thank 

you for the opportunity to provide comments on the proposed timber sale. 

The Wilderness Society (TWS), founded in 1935, is a non-profit membership 

organization devoted to preserving wilderness and wildlife, protecting America's prime 

forests, parks, rivers, deserts, and shorelines, and fostering an American land ethic. With 

over 310,000 members and supporters nationwide, TWS has many members in Alaska 

who use the Tongass National Forest and are concerned with management of its natural 

resources and roadless areas. The Tongass National Forest, an internationally significant 

and nationally valued natural treasure, must be managed to conserve biological diversity, 

support local communities and their quality of life, and protect the ecological integrity of 

the coastal temperate rainforest in southeastern Alaska. 

The Central Kupreanof timber sale proposes to harvest 28.2 to 70.2 MMBF of timber 

from approximately 1,327 to 3,647 acres, and to construct up to 25.1 miles of new 

National Forest System (NFS) roads, 6.1 miles of temporary roads, and to reconstruct up 

to 9.1 miles of existing NFS roads, depending on alternative. The DEIS identifies 

Alternative 3 as the Forest Service’s preferred alternative for this project. This 

alternative proposes to harvest approximately 70.2 MMBF of timber from an estimated 

176 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
3,647 acres, and would involve the construction of 25.1 miles of new NFS roads, 6.1 

miles of temporary roads, and the reconstruction of 9.1 miles of existing road. 

We have several concerns with the project as it is currently proposed and with the 

2008 Tongass Land Management Plan (TLMP) to which it is tiered. Our concerns with 

this project include: the proposed harvest of significant amounts of timber from areas of 

high ecological significance, the flawed economic demand analysis that is the underlying 

basis for the purpose and need of this project, the importance of the area to the 

communities of Kake and Petersburg for subsistence and cultural reasons, and the 

proposed harvest of timber in Inventoried Roadless Areas (IRA). 

Much of the project area has been heavily fragmented from past logging and road 

construction. The project significantly increases harvest, builds more roads, greatly 

increasing the road density, and threatens numerous fish and wildlife species. Because of 

the significant damage in this area from past logging and road construction, the 

importance of this area to Kake residents for subsistence and other activities, and the 

impacts of this project on IRAs, we do not support this timber sale as planned.

Summary of Concerns 

Flawed Economic Demand & Suitability Analysis: The Tongass Timber Reform Act 

(TTRA) provides that the Forest Service may provide a timber supply that (1) meets 

annual market demand for timber from the forest and (2) meets the annual market 

demand from the forest for the planning cycle. In August of 2005, the 9th Circuit Court 

of Appeals ruled that a previous error in calculating demand required the Forest Service 

to revise the Forest Plan. In response, new timber demand projections were completed 

and published in 2006.1 

The new timber demand projections are in error and we have repeatedly made this 

case, based on economic analysis, in our comments on previous timber sales and in our 

TLMP appeal last May. We incorporate by reference the May 15, 2008 appeal by The 

Wilderness Society of the 2008 Tongass Land Management Plan. We have also attached 

a copy to our comments. 

Additionally, as our appeal of the Forest Plan shows, we believe the process of 

determining the suitability of lands for timber management was flawed. We question the 

suitability of the lands in this project area, as well as across the Forest. We believe NFS 

lands on the Tongass have been improperly allocated to management areas (MAs) that 

allow commercial timber harvest. Absent this misallocation, we believe much of this sale 

area and many other areas across the forest would have been assigned to non-timber 

 

1

 Brackley, A.,D.J. Parrent, and T.D. Rojas et al., 2006. Timber products output and timber harvests in 

Alaska: projections for 2005-2025. Gen. Tech. Rep. PNW-GTR-677. Portland, OR: U.S. Department of 

Agriculture, Forest Service, Pacific Northwest Research Station. 33pp. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 177 Appendix D
management MAs. This issue is ripe for consideration given the project proposal at hand. 

Our appeal of the Forest Plan provides more detail on each of the concerns. 

Ecological Context: We have considered information developed in the The Nature 

Conservancy (TNC) / Audubon Alaska “Conservation Assessment for the Coastal 

Forests Ecoregion” to evaluate the ecological values and current condition of the 

watersheds contained in this planning area. The majority of the proposed units in the 

preferred alternative fall in top tier, ecologically significant watersheds 

The Central Kupreanof area contains some of the most productive salmon producing 

watersheds on the Tongass. The preferred alternative poses significant potential risk to 

fish habitat and the long-term viability of both resident and anadromous fish populations 

within large portions of the sale area. We are especially concerned with the Irish/Keku 

Lakes system (VCU 4290), the Upper Castle River area (VCU 4360) and Duncan Bay 

(VCU 4380), all three of which were identified as Conservation Priority Watersheds 

through the TNC/Audubon conservation assessment. In addition, Upper Castle River 

was identified as a one of the top 19 quality fish-producing watersheds in the region by 

the Alaska Department of Fish and Game. 

Development of Phases: Upper Castle River (VCU 4360) is identified as a high priority 

watershed by five of the six ranking systems considered in the development of the 

Tongass Timber Supply Program Adaptive Management System. In document 1637 

from the 2008 TLMP Planning Record, all suitable acreage in VCU 4360 is deferred to 

Phase 2. Yet in spite of the watershed’s significant value to many stakeholders, 

acknowledged in the Forest Service planning process, the VCU was somehow ultimately 

included in Phase 1 and added to the Central Kupreanof timber sale. We can find no 

explanation for why this change was made; it defeats the purpose of the phasing process. 

Inventoried Roadless Areas: The preferred alternative proposes to harvest up to 1,339 

acres of timber in Inventoried Roadless Areas (IRAs). Several of the units, 275-277, and 

279-281, are in an IRA and in VCU 4360, a high value TNC/Audubon watershed and the 

VCU that at one point was deferred until Phase 2. Roadless areas are an important 

concern as they are essential to subsistence, water quality, conserving biological 

diversity, and providing opportunities for solitude and recreation. We do not support 

timber harvest at such a large scale in such a critically important IRA, and see no valid 

reason for moving forward with any project that directly or indirectly degrades roadless 

areas and associated resources. 

Wolf Mortality and Road Density: The construction of additional roads associated with 

the Central Kupreanof Project will increase road density. Studies have shown that roads 

can have a negative impact on wolf survival and long-term population viability. Rather 

than build new roads the Forest Service should address ways to close existing roads to 

reduce wolf mortality in the area. The DEIS says little about road density other than 

providing present road density in the project area. There is no disclosure of post-project 

178 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
road density and no discussion of the cumulative effects of other road construction 

projects that are likely to occur. In 2004, the Alaska Department of Fish & Game 

(AF&G) indicated that “the high likelihood of future timber harvest and road construction 

within small areas” implicated long term wolf mortality and viability concerns.2 ADF&G 

pointed out that road density in some portions of this biogeographic province already 

exceed established guidelines for wolf mortality.3 ADF&G personnel reiterated these 

concerns during the interagency review process.4 Further, ADF&G pointed out that the 

Kake/Petersburg Inter-tie or roads associated with timber projects such as this one will 

trigger or approach recommended thresholds for wolf mortality.5

Under the Forest Plan, the identification of wolf mortality concerns triggers several 

duties. At a minimum, wolf sustainability concerns trigger the duty to further analyze 

project level impacts: “[l]ocal knowledge of habitat conditions, spatial locations of roads, 

and other factors need to be considered by the interagency analysis rather than solely 

relying on road densities.”6

Community Use: Three of the biogeographic province’s top ranked watersheds for winter 

deer habitat are within the project area. Kake’s subsistence activities have been severely 

impacted by past public and private land timber harvests. Intensive high-grading of 

higher habitat-value old growth has contributed to reduced winter carrying capacity for 

deer in this project area, and in Kake’s other major subsistence use area, northern Kuiu 

Island. The DEIS states that the most important area for Kake’s subsistence use of deer 

is Admiralty Island but fails to mention that this area is not as easily accessible for 

residents. The central Kupreanof project will only put additional strain on subsistence 

use activities. 

Analysis of project impacts on subsistence should also consider and fully disclose 

impacts of other proposed timber projects in the area. In particular, there is a large timber 

sale planned on northern Kuiu Island and several others that are planned around the 

project area. 

Future Timber Sale Planning 

In spite of our significant concerns with this sale and with the 2008 Tongass Land 

Management Plan, we remain interested in working with the Forest Service to identify 

future timber sales that meet community and industry needs. We recognize that in the 

coming years there will be considerable challenges in providing the existing industry with 

 

2

 Lowell, R. 2004. Letter to Patricia Grantham re Wolf Mortality and Road Density. ADF&G Division of 

Wildlife Conservation, Petersburg, AK: March 23, 2004. 

3

 ibid 

4

 Planning Record Document # 113. 

5

 Lowell, R. 2004. Letter to Patricia Grantham re Wolf Mortality and Road Density. ADF & G Div. of 

Wildlife Conservation, Petersburg, AK: March 23, 2004. 

6

 TLMP at 4-95. 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 179 Appendix D
timber volume, and that many of the upcoming sales meant to fill that void were designed 

without the benefit of the collaborative relationships that have developed through the 

Tongass Futures Roundtable. We have been closely involved in the 5-year timber sale 

planning process, and acknowledge the efforts of the agency and other partners to work 

toward future management of the Tongass that multiple stakeholders can support. It is 

clear that no one is interested in continuing the yearly, agonizing process of poring over 

sales in a desperate attempt to figure out what sales may or may not meet the needs of the 

diverse stakeholders and the existing industry. 

Our hope is that as we, other members of the conservation community, and additional 

stakeholders work with the agency and partners to revise some aspects of these sales, and 

work to find immediate volume, future timber sales will truly begin transitioning the 

industry to something other than old growth clearcut timber harvest, a future to which 

multiple stakeholders within and outside of the Roundtable have made a stated 

commitment. 

Future timber sales must begin to consider and include opportunities for young 

growth harvest, prescriptions other than clearcut, and be in areas that make biological, 

economic, and social sense. The Central Kupreanof timber sale is not such a project. 

Timber sales should include a range of forest management activities evaluated from a 

holistic, resource-balanced perspective. Activities might include restoration, thinning 

(for wildlife, riparian, and timber purposes), road storage and decommissioning, small 

scale timber harvest, and existing condition inventories. We envision such a process 

would help transition toward a new style of forest management, one that takes an 

ecosystem level perspective and is not driven by large scale, old growth clearcut harvests. 

Conclusion 

In addition to concerns about logging in high value biological, roadless, and social 

areas, we are particularly dismayed to see that the Forest Service continues to offer very 

large sales, such as Central Kupreanof, based on an inflated demand scenario, that are 

unlikely to have buyers. It is hard for us to imagine, given the rapid increase in fuel costs 

over the past two years, that this project will attract a buyer, especially considering the 

negative bid estimate. Our concern is that planning such sales squanders valuable Forest 

Service resources and time that could be better spent on other opportunities, such as 

young growth inventory or restoration activities. 

This type of sale perpetuates the tiring pattern of designing sales that conservation 

groups and other stakeholders have concerns with, and will eventually appeal or litigate, 

making it nearly impossible to end the cycle many interests are trying to break out of. 

Timber sales such as Central Kupreanof, Kuiu, and Central Gravina make it especially 

difficult for us to work with the agency to find the common ground and future we all 

desire. 

180 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
The Wilderness Society does not oppose continued logging in the Tongass. But we 

do believe timber harvest levels should be based on realistic projections of actual market 

demand and that taxpayers should not be subsidizing activities that undermine other 

valuable forest resources. Timber is just one of many resources found in the Tongass, 

and demand for this resource has been steadily declining. The Wilderness Society 

believes that the Forest Service should manage the Tongass in a manner that reflects its 

true worth, investing in stewardship activities that more accurately reflect market 

conditions, that apply the most relevant science, that respect community values, and that 

benefit current and future generations. Some examples include: restoring high value 

watersheds previously impacted by logging; shifting timber production from old-growth 

to young-growth; establishing a harvest level more appropriately scaled to market 

demand from existing local mills; and permanently protecting ecologically and socially 

valuable areas of the forest. 

The Tongass contains many other economic assets in addition to its timber resources, 

including wild salmon streams, clean water and scenic views, all of which could be 

negatively impacted by the logging activity proposed in this DEIS. 

We strongly believe the Forest Service should not be planning such large timber sales 

on the Tongass, particularly those that enter ecologically important, roadless watersheds. 

Coupled with the significant impacts to this area from past logging and the importance of 

this area to Kake residents for subsistence, we urge the Forest Service to cancel this 

project and instead look at ways to begin restoring this area. 

Sincerely, 

Karen Hardigg 

Alaska Forest Program Manager 

The Wilderness Society 

Central Kupreanof Timber Harvest FEIS Appendix D ▪ 181 Appendix D
182 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Central Kupreanof Timber Harvest FEIS Appendix D ▪ 183 Appendix D
184 ▪ Appendix D Central Kupreanof Timber Harvest FEIS Appendix D
Central Kupreanof Timber Harvest FEIS Appendix D ▪ 185 Appendix D
Appendix E 

Biological 

Evaluations 

For Plants and 

Wildlife 
Appendix E 

Table of Contents 

Biological Evaluation for Plants..............................................1 

Biological Evaluation for Wildlife..........................................20 
BIOLOGICAL EVALUATION FOR PLANTS 

For the 

Central Kupreanof Timber Harvest FEIS 

July 2009 

Petersburg Ranger District 

Tongass National Forest 

Prepared by: __/s/ Mary A. Clemens____________________________ Date: _July 26, 2009 

 Mary A. Clemens 

 Forester, Petersburg Ranger District 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 1
INTRODUCTION 

The proposed Central Kupreanof Timber Sale is located in the central part of Kupreanof Island 

on the Petersburg Ranger District of the Tongass National Forest. It is approximately 14 miles from 

Kake, Alaska, and connected by the existing Kake road system. The project area includes lands within 

Value Comparison Units (VCUs) 426, 427.1, 429, 436 and 438, an area of approximately 152,517 acres. 

Plant surveys were conducted within areas of proposed timber harvest and new road construction 

and a few areas outside of proposed units. The surveys concentrated on high probability areas with 

sensitive plant habitat. The purpose of a Biological Evaluation is to analyze the possible effects of the 

proposed activities on threatened, endangered, proposed, and sensitive plants. 

PROJECT DESCRIPTION 

The Central Kupreanof Timber Sale EIS proposes three alternatives for timber harvest and road 

construction plus a no-action alternative (Table 1). The existing Log Transfer Facility (LTF) at 

Hamilton Bay is the proposed site for log transport. Proposed new roads in the area range from 2.2 to 

31.2 miles, depending on the alternative. These will all be closed when the timber sale is complete. In 

addition, 2.6 to 9.1 miles of road are proposed for reconstruction. 

Table 1. Central Kupreanof Proposed Harvest and Road Construction by Alternative 

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

Acres in units proposed for harvest 0 ac 2,505 ac 3,647 ac 1,327 ac 

Proposed new road miles (incl. temp.) 0 mi 11.2 mi 31.2 mi 2.2 mi 

Proposed miles of road reconstruction 0 mi. 2.9 mi 9.1 mi 2.6 mi 

Muskeg/Forested wetland mosaic and 

Forested wetland acres proposed for 

harvest 

0 ac 188 ac 324 ac 109 ac 

Proposed miles of new and 

reconstructed roads crossing 

 wetlands 

 

0 mi 0.6 mi 

(~2.9 

acres) 

1.9 mi 

(~9.2 

acres) 

0.4 mi 

(~1.9 

acres) 

In addition to the timber harvest activities proposed, each action alternative includes project 

opportunities that are suitable for potential stewardship contracting opportunities. The following 

projects are proposed in the project area.

Fisheries/Hydrology

The Road Analysis Process (RAP), updated with this project, recommends road management objectives 

for the Kake Road System. Ultimate storage/closure of these roads and these fisheries/hydrology 

projects will depend on the analysis and decisions made in the District Access and Travel Management 

Plan. Implementation of the recommended road management objectives will result in the removal of 19 

culverts that do not meet fish passage standards. 

Recreation

Maintain the four recreational hiking trails in the area: Cathedral Falls (0.5 mi.), Goose Lake (0.75 mi.), 

2 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Hamilton Creek (1.0 mi.), and Big John Bay (1.75 mi.). The total length of all trails combined is about 

four miles. The work could include annual brushing, condition surveys and replacement of gravel as 

needed. Structure work on the trails could also be included depending on the extent and difficulty of the 

work. Gravel for trail maintenance in the past has been obtained locally in Kake.

Conduct annual maintenance for the Big John Bay Cabin including preparing it for occupancy in the 

spring and winterizing it at the end of the season. In addition, deferred maintenance and repairs could 

also be considered for this project. The cabin can be accessed by hiking the 1.75-mile trail off Road 

45001 or by boating to Big John Bay.

Invasives

Hand-pull a small population of spotted knapweed located on Road 6337. Work could involve up to a 

half-day of work annually for a t least five years and possibly monitoring and/or hand-pulling beyond 

that depending on how well the plants respond to the treatment. Proper disposal of the pulled weeds 

would be specified as part of the project design, most likely burning in a controlled manner. Other 

roadside weed populations could also be included, but this is currently the highest priority invasive plant 

within the project area.

Silviculture/Wildlife

Currently, there are approximately 325 acres of precommercial thinning to accomplish in second-growth 

stands that could potentially be done under a stewardship contract on the Kake road system. These 

stands are approximately 25 years old and an individual prescription will be written for each stand to 

identify species and spacing of the leave trees. These prescriptions will consider future timber 

production and wildlife habitat improvement in their design. There is the possibility of using the cut 

material for some type of product if the contractor is interested. 

Transportation

There are approximately 114 miles of Forest Service System roads in the Kake road system, which 

encompasses the Central Kupreanof EIS project area. Of those 114 miles of roads there are 

approximately 94 miles of open roads that need maintenance to remain open. This maintenance 

generally includes brush cutting, blading of the road surface, ditching and cleaning of culverts to keep 

proper drainage. Of the 94 miles of open road there are approximately 38 miles of mainline roads 

(6040, 6328, 6314, 6314S) that take first priority for maintenance. 

Petersburg Ranger District historically has approximately $70,000 per year to spend on road 

maintenance in Kake. On the average it costs $2,000 per mile to maintain roads, which equates to 35 

miles of road per year that can be done in Kake. Generally, two thirds of the mainline roads are done 

and the remaining portion is spent on selected side roads. 

SENSITIVE PLANTS 

The only plant federally listed or proposed by the U.S. Fish and Wildlife Service in Alaska is 

Polystichum aleuticum C. Christensen, which is endangered. It is only known from Adak Island and is 

not expected to occur in the project area. 

The Regional Forester’s sensitive species list was undergoing revision during the analysis for the Central 

Kupreanof project. The Regional Forester signed the revised list on February 2, 2009. The revised list 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 3

Appendix E
does not include several plants analyzed in the biological evaluation for this project. The following 

plants were analyzed but are no longer designated as sensitive: Glyceria leptostachya, Hymenophyllum 

wrightii, and Poa laxiflora. The two sensitive species found in the Central Kupreanof area, Wright 

filmy fern (Hymenophyllum wrightii), and Davy mannagrass (Glyceria leptostachya), have been 

removed from the 2009 Alaska Region Sensitive Species List. Furthermore, 11 rare plants are newly 

designated as sensitive in the 2009 list revision. None of the newly added species were found in the 

project area. Only one species on the revised list has been documented on the Petersburg Ranger 

District. The lichen Lobaria amplissima has been found on trees on windswept, exposed beaches on 

south Mitkof Island and Tebenkof Bay on Kuiu Island. Due to the project’s advanced stage when the 

list was approved and signed, the Central Kupreanof project surveys and following analysis were based 

on the 2002 list. The difference would be fewer effects to sensitive species in the area with the revision 

since none of the new species were found in the project area. The 2002 and 2009 sensitive species lists 

can be found in Appendix A. 

On the 2002 Sensitive Species List, nineteen vascular plants are designated as Sensitive in the Alaska 

Region (Appendix A). Recent studies of these plants resulted in taxonomic revisions of six of them. 

Based on the work of taxonomic authorities, these six plants are now included in more broadly 

distributed or abundant taxa. Because of this they no longer warrant status as being Sensitive Species 

and will be removed from the list, which is undergoing revision. The six taxa and brief description of 

their taxonomic status are shown here: 

1) Arnica lessingii ssp. norbergii is not recognized by Wolf (2006) in the Flora of North 

America (he recognizes no subspecies within Arnica lessingii); 

2) Carex lenticularis var. dolia now includes the somewhat more common C. enanderi (Standley 

et al., 2002); 

3) Draba kananaski is considered to be a synonym for the more common D. juvenilis (AlShehbaz et al., in press); 

4) Platanthera gracilis is considered to be a synonym for P. stricta (Sheviak, 2002) although 

they differ somewhat; 

5) Puccinellia glabra and 

6) Puccinellia kamtschatica are both considered to be synonyms for the widespread P. 

nutkaensis (Davis & Consaul, 2007). 

Because of their abundance and taxonomic status, these taxa will not be analyzed further in this 

Biological Evaluation. 

Three of the above species were suspected to occur on the Petersburg Ranger District: Carex 

lenticularis, Platanthera gracilis, and Puccinellia kamtschatica. Now, the following nine sensitive 

plants are known or suspected to occur on the Petersburg Ranger District of the Tongass National 

Forest: 

Edible thistle (Cirsium edule) suspected 

Davy mannagrass (Glyceria leptostachya) known 

Wright filmy fern (Hymenophyllum wrightii) known 

Truncate quillwort (Isoetes truncata) suspected 

Calder lovage (Ligusticum calderi) suspected 

Loose-flowered bluegrass (Poa laxiflora) known 

Unalaska mist-maid (Romanzoffia unalaschcensis) suspected 

4 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Queen Charlotte butterweed (Senecio moresbiensis) suspected 

Circumpolar starwort (Stellaria ruscifolia ssp. aleutica) suspected 

PRE-FIELD REVIEW OF EXISTING INFORMATION 

A pre-field review of existing information concerning the plants listed above was conducted for the 

project area. This review included the Regional Forester’s Sensitive Species List, Alaska Natural 

Heritage Program (AKNHP) data base records, and botanical literature (some titles are listed in the 

references section of this report). 

PLANTS KNOWN. There were no previously documented sightings of sensitive plants in the project 

area. The nearest documented sightings were: 

Species: Poa laxiflora Location: Totem Bay, Kupreanof Island 

 (Approx.7 miles from project area) 

Glyceria leptostachya Location: North Mitkof Island 

 (Approx. 13 miles from project area) 

Hymenophyllum wrightii Location: North Mitkof Island 

 (Approx. 13 miles from project area) 

 

PLANTS SUSPECTED. The following general habitats (or plant communities) occur in the project 

area: coniferous forest, forest edge, seeps, wet areas, stream banks, and riparian areas 

The sensitive plants from the 2002 List shown below are suspected to occur in the project area since the 

area contains appropriate habitat and/or is within the known or suspected range of the plants. 

Loose-flowered bluegrass (Poa laxiflora) 

 Found in moist lowland woods, open-forested meadows, upper beaches, and along streams. 

Wright’s filmy fern (Hymenophyllum wrightii) 

Found at the base of trees, on downed logs, and rock outcrops in damp humid woods. 

Davy mannagrass (Glyceria leptostachya) 

Found in wet areas, usually along streams, ponds, and lake margins. Roots are often submerged. 

Unalaska mist-maid (Romanzoffia unalaschcensis) 

Found on rock outcrops, along stream banks, beach terraces, and open rocky areas. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 5

Appendix E
The following species were not analyzed further for the reasons stated:

 

Truncate quillwort (Isoetes truncata) 

Found immersed in shallow freshwater pools or ponds. These habitats will not be disturbed 

with the proposed activities. 

 

Calder lovage (Ligusticum calderi) 

Found in alpine habitats and margins of subalpine and mixed conifer stands, on limestone 

substrate. These habitats will not be disturbed with the proposed activities. 

 

Queen Charlotte butterweed (Senecio moresbiensis) 

Found in alpine and subalpine habitats with open, rocky, or boggy slopes, grassy talus slopes, or 

rocky heaths, usually on limestone substrate. These habitats will not be disturbed with the 

proposed activities. 

 

Circumpolar starwort (Stellaria ruscifolia ssp. aleutica) 

Found on moist gravelly sites and along creeks in mountains. These habitats will not be 

disturbed with the proposed activities. 

Edible thistle (Cirsium edule) 

Found on forest edges, stream banks and dry meadows. In Southeast Alaska, it has only been 

found on the mainland on the Ketchikan/Misty Fiords District. It is suspected to occur on the 

Wrangell and Petersburg Districts because they also include mainland habitat. Since Kupreanof 

Island and the project area are nearly 20 miles from the nearest mainland and over a hundred 

miles from the known occurrences, this species is unlikely to occur in the project area and is not 

being analyzed further. 

FIELD SURVEY FOR SENSITIVE PLANTS

Sensitive plant surveys of Level 3 intensity were conducted for the project area (see Appendix B for 

definitions of plant survey intensity levels). Detailed maps showing the exact route that the botanist 

traveled on the ground are on file at the Petersburg Ranger District. Daily plant survey forms, 

completed according to protocol for the Alaska Region, are also on file at the Petersburg Ranger 

District. Survey data and sensitive plant locations will be entered into the Natural Resource Information 

System (NRIS) database by December 1, 2008. 

The following sensitive plants from the 2002 list were located during the 2006 and 2007 surveys: 

Wright filmy fern (Hymenophyllum wrightii) and Davy mannagrass (Glyceria leptostachya). See 

Appendix D for a complete plant list for the project area. 

Date(s) of survey(s): June 14-19, July 26-31, and August 26, 2006; June 18-19, July 26-29, and August 

14-15, 2007 

Project surveyed by: Mary Clemens, Forester, Petersburg Ranger District and Joni Johnson, Ecologist, 

Tongass National Forest 

6 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
The plant surveys took place at the appropriate time of year to identify sensitive plants known or 

suspected in the project area. 

EFFECTS

Determination of risks to populations of sensitive plants takes into account: size, density, vigor, habitat 

requirements, location of the population, and consequence of adverse effect on the species as a whole 

within its range and within the National Forest. 

Effects Common to All Action Alternatives 

Trail Maintenance and Cabin Maintenance 

There would be no effects to threatened, endangered, sensitive, or rare plants from the proposed 

stewardship project of maintaining the four area trails and Big John Bay cabin. 

Invasive Plant Control 

There would be no effects to threatened, endangered, sensitive or rare plants from the proposed invasive 

plant control stewardship project. 

Fisheries/Hydrology 

There would be no effects to threatened or endangered plants from the proposed fisheries/hydrology 

stewardship project of pulling culverts on fish streams on closed roads. While no known populations of 

sensitive or rare plants would be affected, correcting or pulling culverts has the potential to affect 

unknown populations and habitat at stream crossings. 

Silviculture/Wildlife 

There would be no effects to threatened, endangered, sensitive or rare plants from the proposed 

silviculture stewardship project of pre-commercial thinning second-growth stands. 

Transportation 

The proposed transportation stewardship project of maintaining the Kake area roads would not adversely 

affect any known threatened, endangered, sensitive or rare plants in the project area. One sensitive plant 

species, Davy mannagrass (Glyceria leptostachya), is sometimes found in roadside ditches and could be 

affected by ditch maintenance. However, this species thrives in disturbed areas, so increased 

disturbance could actually enhance its habitat and populations. Also, this species is more abundant on 

the Tongass than once thought, so it was dropped from the 2009 Sensitive Plant List. 

Microsales 

The proposed Microsale areas along NFS roads 6030, 6040, 6314, 6314S, 6326, 6328, 6334, 6336, 6339 

and 6367 may adversely impact unknown individual sensitive plants but would not likely result in a loss 

of viability in the planning area, nor cause a trend toward federal listing for any species. 

Direct Effects 

Known and unknown sensitive plants may be destroyed and habitat lost in road corridors due to 

trampling by workers, machinery, and deposition of road materials, Plants may be destroyed in timber 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 7

Appendix E
harvest units due to trampling by workers, trees falling on the plants, trees dragged over the plants 

during removal or slash deposited on the plants. Plants may also be destroyed from operation of shovel 

yarding equipment, and habitat alteration from soil compaction. 

Specifically, the proposed timber harvest activities would have direct effects on the sensitive species of 

Hymenophyllum wrightii (2002 List). Populations of Hymenophyllum wrightii were found in nine 

proposed units and in three locations outside proposed units. Fourteen known populations would not be 

protected with the proposed alternatives 2 and 3 and three known populations would be protected with 

the proposed alternatives because they occur in riparian buffer zones or in a unit no longer being 

considered for harvest. In Alternative 4, one more population would be protected by the changed shape 

of Unit 310 (thirteen affected populations). 

Since this small, inconspicuous gametophyte is being found more and more often on the Tongass, 

including many sightings on the Petersburg Ranger District, it was removed from the 2009 Alaska 

Sensitive Species List. Considering the increased sightings, habitat protection and removal from the list, 

it is not likely that destroying 14 populations would affect the viability of the species on the Tongass. 

The proposed activities (timber harvest and road building) would have direct effects on the habitat or 

individuals of the fern Hymenophyllum wrightii, by removing old logs from the forest floor, and 

crushing and churning the soils and decomposing wood that occurs under old stumps and logs. This fern 

is known to occur in damp, humid forests and wet, rock outcrops. Approximately 31,622 acres of the 

152,517 acres within the project area are considered to have productive forests suitable and available for 

timber harvest. These acres are also potential habitat for Hymenophyllum wrightii. Depending on the 

Alternative, timber harvest could affect from 1,327 to 3,647 acres of spruce/hemlock old-growth forest 

habitat known to contain the preferred habitat for this tiny fern. This equates to approximately 4.2 

percent to 11.5 percent of the potential Hymenophyllum wrightii habitat in the project area that is 

suitable for timber harvest. 

An additional 12,884 acres of productive forest in the project area are not suitable for timber harvest 

because of steep slopes or because they are within riparian or beach buffers or old-growth reserves that 

do not permit commercial timber harvest. These areas are additional potential habitat for 

Hymenophyllum wrightii that are not at risk of timber harvest. 

The timber harvest activities, including associated road construction and reconstruction, would also 

likely affect some undetected sensitive plants, especially Hymenophyllum wrightii, since timber is 

harvested in its forest habitat. More Hymenophyllum wrightii populations are also likely to occur in 

areas where no harvest is proposed since most surveys were concentrated in proposed units and only 

limited surveys were done in non-harvest areas. 

One population of Davy mannagrass (Glyceria leptostachya) on the 2002 List was found on the north 

shore of Kluane Lake east of Unit 254. The population is not within a proposed unit and would not be 

directly affected by timber harvest or road construction activities. 

Approximately 103,400 acres of the project area (excluding state and private lands) contain nonproductive forest habitats and non-forest habitats such as muskeg and alpine. The other three suspected 

sensitive plants in this project area occur in habitats that would generally not be considered productive 

8 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
forest, or are in buffer zones with limited disturbance from timber harvesting. However, to access 

harvest units, each action alternative proposes some road construction through wetlands. Alternative 2 

proposes 0.6 miles, Alternative 3 proposes 1.9 miles, and Alternative 4 proposed 0.4 miles. With less 

than two miles crossing wetlands, the effects to the habitats of these species would be minimal within 

the project area. 

Indirect Effects 

Indirect effects on these species in other locations as a result of timber harvest and road construction are 

essentially undocumented at this time. However, changes in the habitat condition may have some 

indirect effects such as soils moisture changes, light regime changes and increased susceptibility to 

disturbances (human and natural). Some of the possible changes include increased groundwater 

hydrology due to decreased levels of evapotranspiration after harvest; alterations due to possible 

sedimentation caused by landslides or windthrow as a result of timber harvest or roading activities; 

increased competition from native or non-native species that may establish as a result of road building 

activities and other disturbance; impacts caused by changes in the light regime as a result of canopy 

removal; and increased disturbance caused by humans who may access these area for recreation or 

subsistence use. 

Specifically, indirect effects to the habitat or individuals of the suspected Hymenophyllum wrightii

(HYWR) due to the proposed activities include the increase in solar radiation and changes in the 

humidity levels of the microhabitats where HYWR grows. It has mainly been found under old growth 

tree stumps, on decomposing wood, and on soil in dark damp places on the forest floor. Harvesting 

activities would remove the forest overstory and crush the associated shrubs, thus increasing the chance 

of gametophyte desiccation and mortality. Eventually, the stumps of felled trees would lose their waterholding capacity because the bark would decompose and fall off at a very rapid rate compared to in the 

forest, and the increased light would initiate the growth of other species in the stump such as mosses and 

lichens that are adapted to higher light regimes and can out compete the gametophyte. 

Known and previously unknown populations of sensitive plants adjacent to and in the project area could 

be indirectly affected by the introduction of invasive plants due to increased human activities, which 

compete with native plants in disturbed habitats. See the Risk Assessment for Invasive Plants for the 

Central Kupreanof Timber Harvest EIS (Clemens 2008). 

Cumulative Effects 

The area being considered for cumulative effects is the Tongass National Forest since most of the known 

and suspected plants on the Petersburg District have ranges extending across the forest. The viability of 

a species on the forest is often related to the number of occurrences found across the forest and the 

likelihood that those populations could be affected by activities. 

On the Tongass, approximately 500,000 acres have been harvested out of approximately 5,600,000 acres 

of productive forest. This means about 9% of the potential habitat for H. wrightii has been harvested. 

But not all of the remaining productive forest on the Tongass allows timber harvest. Wilderness areas, 

semi-remote and remote recreation LUDs, old-growth reserves, and wild rivers do not allow commercial 

timber harvest. Also, areas with slopes over 72% on unstable soils and areas within riparian, beach and 

estuary buffers are considered unsuitable for timber harvest. The cumulative impact of management 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 9

Appendix E
activities upon Hymenophyllum wrightii population viability may be moderated through the maintenance 

of potential habitat in these areas of productive forest that are unsuitable for timber harvest. 

Timber harvest and road building on the Tongass have the potential to negatively affect the greatest 

amount of H. wrightii habitat, but they are not the only activities that could affect the habitat. Trails, 

recreation cabins, developed recreation sites, mineral activities, and dispersed hiking all contribute to 

negatively affecting the potential habitat. Currently on the Tongass, however, these other activities affect 

productive forest land to a much lesser degree. 

Davy mannagrass is sometimes found in roadside ditches and could be affected by proposed roadwork 

activities. However, this species thrives in disturbed areas, so increased disturbance could actually 

enhance its habitat and populations. 

The other three suspected sensitive plants in the project area generally occur in habitats not considered 

productive forest (such as muskeg and alpine), or in buffer zones where timber harvest is restricted such 

as streamsides, lakeshores, and beach fringe. Therefore, the effects to the habitats of these species 

would be minimal across the Forest. Although there is anticipated road construction through additional 

wetlands with implementation of the Forest Plan, the locations of all new roads are analyzed to 

minimize impacts to soils, water and associated resources in accordance with BMPs. Road locations will 

be completed to avoid wetlands whenever practicable. 

Since there would be no direct or indirect effects in Alternative 1, there would be no cumulative effects 

in Alternative 1. For Alternatives 2, 3, and 4, the Catalog of Events was referenced. The following 

cumulative effects may impact sensitive species or their habitat within the project area; road and trail 

construction, road storage or decommissioning, gravel extraction, timber harvest, and recreation. While 

individual populations and areas of potential habitat may be impacted by the proposed activities within 

the project area and across the Forest, cumulatively, the effects would not likely to lead to federal listing 

of any species. 

As more sensitive plant surveys are conducted and more potential habitats surveyed, specialists are 

learning better methods on how to look for these plants. With this increasing knowledge, more plants are 

being found. Across the Tongass National Forest, from just the surveys concentrated in areas of 

proposed activities, approximately 86 populations of Hymenophyllum wrightii have been found, 

seventeen populations in the Central Kupreanof proposed activity area alone. As stated earlier, the 

regional sensitive plant species list was revised and Hymenophyllum wrightii and Glyceria leptostachya 

were removed from the list due to the recent findings of abundant populations across the Forest. 

Risk Assessment 

A risk assessment for each sensitive plant known or suspected in the project area must be conducted 

since only Level 3 (limited focus) surveys for plants were done. The level of consequence and level of 

likelihood are determined for each plant from the evaluation of direct, indirect and cumulative effects of 

the proposed project on sensitive plant populations. Levels of consequence and levels of likelihood are 

described in Appendix C. A risk assessment considers two factors: 1) the consequences of adverse (or 

beneficial) effects on the population, and 2) the likelihood or probability that these effects will occur. 

10 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Alternative 1 (No Action) – The consequences of adverse impacts to the four sensitive plants in this 

analysis due to project activities are none. The likelihood of adverse effects is none. 

Alternatives 2, 3, and 4 

Poa laxiflora 

P. laxiflora has been found in over 30 locations on the Petersburg Ranger District, mainly forest/beach 

edge habitats and beach meadow. The habitat for this taxon is largely protected on the Tongass National 

Forest through riparian and beach buffers. The consequences of adverse impacts to this species are low

because numerous other populations of Poa laxiflora have been found on the forest with most of the 

occurrences in beach fringe, which is protected from timber harvest. The likelihood of adverse impacts 

is low because its preferred habitat along streams and beaches is not likely to be affected by the 

proposed activities because of riparian and beach buffers. No populations were found during surveys 

within the project area. 

Hymenophyllum wrightii 

H. wrightii is found in older forest habitats and was found at two locations on Mitkof Island in the 1960s 

on the Petersburg Ranger District and one location on Baranof Island on the Sitka Ranger District. In 

2006, increased expertise in identification led to documenting over 68 new sightings, including several 

new populations on Mitkof and Kupreanof islands. The jump in documented sightings in 2006 and 

since suggests that this tiny fern has largely been overlooked in the past and may be more common than 

once thought. The miniscule plant (gametophyte) is found in moist shaded areas on the undersides of 

downed logs and at the base of trees. It was documented in the Central Kupreanof project area in 17 

locations. The consequences of adverse impacts to this species are low because of the increased number 

of known sightings on the Petersburg Ranger District and other locations on the Tongass. The 

likelihood of adverse effects of the known populations of this species is high because timber harvest 

would affect up to 14 populations in Alternatives 2, 3, and 4 and also affect preferred habitat in those 

alternatives. 

Glyceria leptostachya 

G. leptostachya is a perennial grass occurring principally in disturbed wet areas within southeastern 

Alaska. Sightings in recently disturbed wet areas suggest that this plant is a pioneer species. Primary 

habitat for this species includes lakeshores and stream banks, swamps, wet meadows and standing or 

slow moving shallow water. The consequences of adverse impacts to this sensitive plant due to project 

activities are none because this plant has demonstrated the ability to colonize newly disturbed wet areas 

if in the project area vicinity. This is based on evidence indicating that the occurrence of this plant on 

the forest is more abundant than previously thought. The likelihood of adverse effects of the known 

populations of this species is low because the one known population was found on a lake shore outside 

of any unit. Also, while road maintenance or reconstruction may impact the ditches and associated wet 

habitats, this disturbance to its population could have beneficial effects to populations. Some seeds and 

plants would survive any ditch or wetland habitat disturbance and re-colonize the area with time. 

Negative cumulative effects are unlikely because multiple populations occur across the forest. 

Romanzoffia unalaschcensis 

R. unalaschcensis has been found on the Sitka and Thorne Bay Ranger Districts. It is suspected to occur 

on the Petersburg District. It is found on rock outcrops, along stream banks, beach terraces, and open 

rocky areas. The consequences of adverse impacts to this species are moderate to high since there are 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 11 Appendix E
few documented sightings on the forest. The likelihood of adverse impacts is none because the potential 

habitat would not be affected with the proposed activities. No plants were found during surveys within 

the project area. 

Determination 

Based on the rationale described above, the alternative courses of action will result in the following 

impacts on the known and suspected sensitive plants: 

Alternative 1 (No Action) – No impact to any sensitive plant species. 

Alternatives 2, 3, and 4 – For Hymenophyllum wrightii Alternatives 2, 3, and 4 would impact some 

individual plants and habitat, but would not likely contribute to a trend toward federal listing or cause a 

loss of viability to the species because: several known populations in the project area would not be 

affected; the species is being found in increasing numbers across the forest; and many of the 

documented sightings on the Tongass are in areas of low risk of being affected by activities such as 

beach buffers and wilderness.

For the other three sensitive plants analyzed (Poa laxiflora, Glyceria leptostachya, and Romanzoffia 

unalaschcensis) these alternatives may impact individuals or habitat but are not likely to contribute to a 

trend toward federal listing or cause a loss of viability to the population or species, as generally the 

potential habitat for these species are not considered productive forest (such as muskeg and alpine), or in 

buffer zones where timber harvest is restricted such as stream sides, lakeshores, and beach fringe. Also, 

only minimal road construction (up to about two miles) is proposed crossing wetlands. 

Determinations are per the May 15, 1992, letter of direction from the WO. 

Additional Management Recommendations 

If any previously undiscovered sensitive plants are encountered at any time prior to or during 

implementation of this project, protect the population and avoid any disturbance in the area containing 

the population (and similar habitats in that vicinity). The District or Forest Botanist/Ecologist should be 

notified immediately to evaluate the population and recommend avoidance or mitigation measures. 

12 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
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North America, north of Mexico, Part 21: Magnoliophyta: Asteridae (in part): Asteraceae, Part 3. 

Oxford University Press, New York. 

USDA, NRCS 2008. The PLANTS database (http://plants.usda.gov/) National Plant Data Center, 

Baton Rouge, LA 70874-4490 USA. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 13 Appendix E
Appendix A.

Alaska Region Sensitive Plants, June 2002. 

Aphragmus eschscholtzianus Eschscholtz’s little nightmare 

Arnica lessingii ssp. norbergii Norberg arnica 

Botrychium tunux Moonwort fern, no common name

Botrychium yaaxudakeit Moonwort fern, no common name 

Carex lenticularis var. dolia Goose-grass sedge 

Cirsium edule Edible thistle 

Draba kananaskis Tundra whitlow-grass 

Glyceria leptostachya Davy mannagrass 

Hymenophyllum wrightii Wright filmy fern 

Isoetes truncata Truncate quillwort 

Ligusticum calderi Calder lovage 

Papaver alboroseum Pale poppy 

Platanthera gracilis Bog orchid 

Poa laxiflora Loose-flowered bluegrass 

Puccinellia glabra Smooth alkali grass 

Puccinellia kamtschatica Kamchatka alkali grass 

Romanzoffia unalaschcensis Unalaska mist-maid 

Senecio moresbiensis Queen Charlotte butterweed 

Stellaria ruscifolia ssp. aleutica Circumpolar starwort 

Alaska Region Sensitive Plants, February 2009 

Aphragmus eschscholtzianus Eschscholtz’s little nightmare 

Botrychium spathulatum Spatulate moonwort 

Botrychium tunux Moonwort fern, no common name

Botrychium yaaxudakeit Moonwort fern, no common name 

Cirsium edule var. macounii Edible thistle 

Cochlearia sessifolia Sessileleaf scurvygrass 

Cypripedium guttatum Spotted lady’s slipper 

Cypripedium montanum Mountain lady’s slipper 

Cypripedium parviflorum var. pubescens Large yellow lady’s slipper 

Ligusticum calderi Calder lovage 

Lobaria amplissima Lichen, no common name 

Papaver alboroseum Pale poppy 

Piperia unalascensis Alaska rein orchid 

Platanthera orbiculata Lesser round-leaved orchid 

Polystichum kruckebergii Kruckeberg’s swordfern 

Romanzoffia unalaschcensis Unalaska mist-maid 

Sidalcea hendersonii Henderson’s checkermallow 

Tanacetum bipinnatum subsp. huronense Dune tansy 

14 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Appendix B. 

Survey intensity level for plants. 

LEVEL 1 = “FIELD CHECK” 

The surveyor gives the area a quick “once-over” but does not walk completely through the project area. 

The entire project area has not been examined. 

LEVEL 2 = “CURSORY” 

The surveyor gives the area a “once-over” by walking through the project area. The entire project area 

has not been examined. 

LEVEL 3 = “LIMITED FOCUS” 

The surveyor closely examines one or more habitat-specific locations within the project area, but does 

not look at the rest of the area. 

LEVEL 4 = “GENERAL” 

The surveyor gives the area a closer look by walking through the project area and walking around the 

perimeter of the area or by walking more than once through the area. Most of the project area is 

examined. 

LEVEL 5 = “INTUITIVE CONTROLLED” 

The surveyor has closer look by conducting a complete examination of specific areas of the project after 

walking through the project area and perimeter or by walking more than once through the area. 

LEVEL 6 = “COMPLETE” 

The surveyor has walked throughout the survey area until nearly all of the area has been examined. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 15 Appendix E
Appendix C. 

Criteria for Risk Assessment. 

Factor 1. Consequence of Adverse Effect From a Particular Activity 

 LOW: None, or questionable adverse effect on habitat or population. 

 No cumulative effects expected. 

MODERATE: Possible adverse effects in habitat or on population. 

 Cumulative effects possible. 

HIGH: Obvious adverse effects on habitat or population. 

 Cumulative effects probable. 

Factor 2. Likelihood of Adverse Effect from a Particular Activity 

NONE: Activity will not affect habitat or population. 

 (no further risk assessment needed). 

LOW: Activity controllable by seasonal or spatial restrictions. 

and not likely to affect habitat or populations. 

MODERATE: Activity not completely controllable or intense administration of project needed 

to prevent adverse effects on habitat or population. Adverse effects may occur. 

HIGH: Activity not controllable and adverse effects on habitat or populations likely 

to occur. 

This process serves only to document the rationale for arriving at conclusions as per WO letter dated 

May 12, 1992 

16 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Appendix D. Central Kupreanof Species List from Surveys in 2006 and 2007

Trees 

Alnus rubra 

Chamaecyparis nootkatensis 

Picea sitchensis 

Pinus contorta 

Thuja plicata 

Tsuga heterophylla 

Tsuga mertensiana 

Tall Shrubs

Alnus sinuata 

Cladothamnus pyrolaeflorus 

Cornus stolonifera 

Malus diversifolia 

Menziesia ferruginea 

Oplopanax horridus 

Ribes bracteosum 

Ribes lacustre 

Ribes laxiflorum 

Rubus parviflorus 

Rubus spectabilis 

Sambucus racemosa 

Salix sitchensis 

Spiraea douglasii 

Vaccinium ovalifolium 

Vaccinium parvifolium 

Viburnum edule

Low Shrubs

Andromeda polifolia 

Empetrum nigrum 

Kalmia polifolia 

Ledum groenlandicum 

Linnaea borealis 

Rubus arcticus ssp stellatus 

Rubus chamaemorus 

Rubus pedatus 

Vaccinium caespitosum 

Vaccinium oxycoccos 

Vaccinium uliginosum 

Vaccinium vitis-idaea 

Forbs

Achillea millifolium 

Aconitum delphinofolium 

Actaea rubra 

Aquilegia formosa 

Arnica amplexicaulis 

Aruncus sylvester 

Caltha biflora 

Caltha palustris 

Circaea alpina 

Claytonia sibirica 

Clintonia uniflora 

Conioselinum pacificum* 

Coptis asplenifolia 

Coptis trifolia 

Cornus canadensis 

Cornus suecica 

Dodecatheon jeffreyi 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 17 Appendix E
Drosera rotundifolia 

Epilobium angustifolium 

Epilobium latifolium 

Epilobium spp 

Equisetum arvense 

Erigeron peregrinus 

Fauria crista-galli 

Fritillaria camschatcensis 

Galium kamtchaticum 

Galium trifidum 

Galium triflorum 

Gentiana douglasiana 

Gentiana platypetala 

Geum calthifolium 

Geum macrophyllum 

Goodyera oblongifolia 

Heuchera glabra 

Hypopitys monotropa 

Ligustichum scoticum* 

Listera caurina 

Listera convallarioides 

Listera cordata 

Lysichiton americanum 

Malaxis paludosa 

Maianthemum dilatatum 

Menyanthes trifoliata 

Microseris borealis 

Mitella pentandra 

Moneses uniflora 

Nuphar polysepalum 

Oenanthe sarmentosa 

Osmorhiza chilensis 

Osmorhiza purpurea 

Parnassia fimbriata 

Parnassia spp. 

Pinguicula vulgaris 

Plantago major* 

Platanthera unalaschcensis – Hamilton Trail 

Platanthera dilatata 

Platanthera saccata 

Potentilla anserine pacifica* 

Potentilla palustris 

Prenanthes alata 

Pyrola secunda 

Ranunculus pacificus* 

Ranunculus uncinatus 

Rumex occidentalis* 

Sanguisorba menziesii 

Sanguisorba spp. 

Stellaria calycantha 

Streptopus amplexifolius 

Streptopus roseus 

Streptopus streptopoides 

Tellima grandiflora 

Tiarella trifoliata 

Tolfieldia glutinosa 

Trientalis europaea 

Valeriana sitchensis 

Veratrum viride 

Vicia gigantea* 

Viola adunca 

Viola glabella 

Viola langsdorffii 

Viola spp.

18 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Sedges

Carex aquatilis 

Carex echinata 

Carex laeviculmis 

Carex lyngbyei* 

Carex macloviana 

Carex mertensii 

Carex paucifolia 

Carex pluriflora 

Carex sitchensis 

Eriophorum angustifolium 

Scirpus microcarpus 

Scirpus caespitosus 

Rushes

Juncus ensifolius 

Luzula parviflora 

Grasses

Agrostis aequivalvis 

Deschampsia caespitosa* 

Elymus glaucus 

Elymus hirsutus 

Glyceria leptostachya 

Trisetum cernuum 

Ferns

Adiantum pedatum 

Asplenium trichomanes – Unit 208 

Asplenium viride 

Athyrium filix-femina 

Blechnum spicant 

Cystopteris fragilis 

Dryopteris austriaca 

Gymnocarpium dryopteris 

Hymenophyllum wrightii 

Polypodium glycyrrhiza 

Polystichum braunii 

Pteridium aquilinum 

Thelypteris limbosperma 

Thelypteris phegopteris 

Clubmosses

Lycopodium annotinum 

Lycopodium clavatum 

Lycopodium inundatum 

Lycopodium selago 

Liverworts

Conosephalum conicum 

Lichens 

Alectoria sarmentosa 

Bryoria spp. 

Cladonia rangiferina 

Cladonia bellidiflora 

Hypogymnia duplicata 

Icmadolphia ericetorum 

*Beach species, found on Hamilton Bay Trail and Big John Bay Trail outside project 

area. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 19 Appendix E
Biological Evaluation 

For The 

Central Kupreanof Timber Harvest Project 

USFWS, reference #71440-SL-2009-0026 

Petersburg Ranger District 

Tongass National Forest 

Prepared By: /s/ Amanda M. Williams Date: 17 February 2009_ 

 Amanda M. Williams 

 Wildlife Biologist/Petersburg Ranger District/Tongass National Forest 

Reviewed By: /s/ Chuck Parsley Date: 17 February 2009

Chuck Parsley 

Wildlife Biologist/Petersburg Ranger District/Tongass National Forest 

Updated By: /s/ Chuck Parsley Date: July 2, 2009 

Chuck Parsley 

Wildlife Biologist/Petersburg Ranger District/Tongass National Forest 

20 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
TABLE OF CONTENTS 

Biological Evaluation for the Central Kupreanof Timber Harvest Project, Petersburg Ranger 

District, Tongass National Forest 

J:\fsfiles\office\prd\ptimber\Central_Kupreanof_EIS\03-16) Resources\04) Wildlife\a) Resource 

Report 

I. INTRODUCTION 3 

II. PROJECT DESCRIPTION 3 

III. THREATENED, ENDANGERED, CANDIDATE AND PROPOSED SPECIES 4 

SPECIES NOT ADDRESSED IN DETAIL 7 

Effects Analysis 8 

Affected Environment 8 

HUMPBACK WHALE 8 

STELLER SEA LION 10

 YELLOW-BILLED LOON 12 

Determinations 122 

IV. SENSITIVE SPECIES 133 

Affected Environment 144 

KITTLITZ’S MURRELET 144 

Effects Analysis 15 

NORTHERN/QUEEN CHARLOTTE GOSHAWK 166 

ALEUTIAN TERN 188 

BLACK OYSTERCATCHER 20 

Determinations 21 

VI. REFERENCES 222 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 21 Appendix E
I. INTRODUCTION

Biological Evaluations (BE) provide a process to review all Forest Service planned, funded, 

executed or permitted programs and activities for possible effects on threatened, endangered, 

proposed or sensitive species (TEPS) (Forest Service Manual 2672.4). BEs are intended to help 

ensure that Forest Service actions do not contribute to a loss of viability or any native or desired nonnative plant or animal species or contribute to trends toward Federal listing of any species. They 

provide a process and standard to ensure that TEPS species receive full consideration in the 

decision-making process (FSM 2672.41). 

The effects analysis in the BE is required to address any direct, indirect, and cumulative effects of an 

action on threatened or endangered species or their critical habitat (50 Code of Federal Regulations 

[CFR] 402.02) and on sensitive species or their habitat (FSM 2672.42). This BE also complies with 

Section 7 of the Endangered Species Act (ESA), which requires all Federal Agencies, in consultation 

with the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS), to 

insure that their actions are not likely to jeopardize the continued existence of threatened, 

endangered or proposed species or adversely modify their habitat. 

Current management direction on desired conditions for Threatened, Endangered, Proposed and 

Sensitive species on the Tongass National Forest can be found in the following documents: 

 Forest Service Manual and Handbooks (FSM/H 2670/2609) 

 National Forest Management Act (NFMA) 

 Endangered Species Act (ESA) 

 National Environmental Policy Act (NEPA) 

 Tongass National Forest Land and Resource Management Plan (referred to as the Forest 

Plan) (USDA 2008a) 

 Species specific recovery plans that establish population goals for recovery of those species 

 Regional Forester policy and management direction (i.e., Sensitive Species List) 

The Forest is organized into Land Use Designations (LUD) for management purposes. Each LUD 

has specific goals, objectives, desired conditions and management prescriptions which are discussed 

in Chapter 3 of the Forest Plan. LUDs within the project area include: Timber Production 

(approximately 72%), Old-growth Habitat (approximately 12%), Semi-remote Recreation 

(approximately 10%), Modified Landscape (approximately 5%), and Special Interest Area (<1%), 

Remote Recreation and Wilderness (<1%) (DEIS Vol. A, pp. 1-7 through 1-8, Dec. 2008). 

The Forest Plan provides specific information on how TEPS species will be managed. Forest-wide 

desired conditions and goals for fish and wildlife are included in Chapter 2 of the Forest Plan. The 

Forest Plan standards and guidelines for TEPS species provide the direction for species management 

within the project area (USDA 2008a, pp. 4-14, 4-89 through 4-100). The direction is incorporated 

by reference.

II. PROJECT DESCRIPTION

The Petersburg Ranger District of the Tongass National Forest, Alaska Region (Region 10), of the 

USDA Forest Service, is proposing the Central Kupreanof Timber Harvest Project. The project is 

located centrally on the western portion of Kupreanof Island, approximately 30 air miles northwest 

22 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
of Petersburg. The northern end of the project area begins about 9 miles southeast of the 

Community of Kake and will utilize the Kake road system. The project area contains portions of the 

Castle, Rocky Pass, North Kupreanof, and South Kupreanof Inventoried Roadless Areas. 

Approximately 123,297 acres of inventoried roadless area are included within the project area 

boundary (DEIS Vol. A, pp. 1-4, Dec. 2008).

There are four alternatives for the Central Kupreanof Timber Harvest Project. These alternatives 

range from “No-Action” which is the current existing status of the project area, which includes no 

new construction of roads and no timber volume harvested, action alternatives which may harvest up 

to approximately 70.2 MMBF (sawlog and utility) from 3,647 acres, 25.1 miles of new NFS road 

constructed, 9.1 miles of reconstructed road, and 6.1 miles of temporary road constructed. 

The Central Kupreanof Timber Harvest Project includes approximately 152,517 acres, and its 

boundaries follow the boundary of value comparison units (VCUs) 429, 438, 426, 436, and 427.1 

(DEIS Vol. A, p. 1-4, Dec. 2008). The project includes seven Land Use Designations (LUDs) – 

Timber Production, Old-growth Habitat, Semi-remote Recreation, Modified Landscape, Special 

Interest Area, Remote Recreation and Wilderness. The interdisciplinary team has identified several 

projects within the project area that could serve as stewardship opportunities alongside the timber 

harvest proposal, including trail maintenances, pre-commercial thinning opportunities (both for 

silvicultural and wildlife purposes), fisheries and hydrology opportunities, and road maintenance 

activities (DEIS Vol. A, p. 1-2, Dec. 2008). 

The purpose of this project is to: (1) Manage the timber resource for the production of sawtimber 

and other wood products from suitable lands made available for timber harvest on an even-flow, 

long-term sustained yield basis, and in an economically efficient manner; (2) Seek to provide a 

timber supply sufficient to meet the annual market demand for Tongass National Forest timber and 

the market demand for the planning cycle; (3) Provide for a diversity of opportunities for resource 

uses that contribute to the local and regional economies of Southeast Alaska (DEIS Vol. A, pp. 1-2 

and 1-3, Dec. 2008). 

III. THREATENED, ENDANGERED, CANDIDATE AND PROPOSED SPECIES

In compliance with the Forest Plan and ESA, species that are listed as threatened, endangered, 

candidate or proposed in this area were identified. Federally listed threatened and endangered 

species are those plant and animal species formally listed by the Fish and Wildlife Service or 

National Marine Fisheries Service under authority of the Endangered Species Act of 1973, as 

amended. An endangered species is defined as one that is in danger of extinction throughout all or a 

significant portion of its range. A threatened species is defined as one that is likely to become an 

endangered species within the foreseeable future throughout all or a significant portion of its range. 

Petitioned species are species that are actively being considered for listing. 

The FWS and NMFS Internet web sites were consulted, for the preparation of this document because 

they provide occurrence and habitat information. An email correspondence from Katharine Savage 

(NMFS) to Chuck Parsley (USDA FS) was also obtained for clarification of current listed species 

recognized by NMFS. 

The FWS list of threatened, endangered, candidate and proposed species for all of Alaska is shown 

in Table 1 (USDI 2007a). The Kittlitz’s murrelet is a candidate species that is covered in the Forest 

Service Sensitive Species listing, further on in the document, and will not be covered here. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 23 Appendix E
These species listed in Table 1 are not known to occur in southeast Alaska or on the Tongass 

National Forest, therefore they are not known to occur in or around the analysis area per information 

from (http://alaska.fws.gov/fisheries/endangered/listing.htm) and informal consultation with the 

FWS (Steve Brockmann, 13 February 2009, and reference number #71440-2009-SL-0026). A 

Section 7 Consultation with the US Fish and Wildlife Service will occur prior to the initiation of this 

project (if needed). These species (listed below) will not be addressed further in this Biological 

Evaluation. 

Table 1. Threatened, endangered, candidate and proposed species managed by the FWS and location description 

throughout Alaska (USDI 2009a).

Common Name Scientific Name ESA Status Location Description 

Eskimo Curlew Numenius borealis Endangered 

Occurred in the arctic and is 

assumed to no longer occur in 

Alaska (USDI 2007a and 

2006a). 

Short-tailed Albatross Phoebastria albatrus Endangered 

Occupies coastal waters in the 

Gulf of Alaska and the Aleutian 

Islands (USDI 2001). 

Spectacled Eider Somateria fischeri Threatened 

Occupies coastal waters in 

northern and western Alaska 

(USDI 1999 and 2007b). 

Polar Bear Ursus maritimus Proposed 

Lives only in the Northern 

Hemisphere (USDI 2006b, p. 

1). 

Steller's Eider Polysticta stelleri Threatened 

Occurs in northern and 

western Alaska (USDI 1999 

and 2007b). 

Steller Sea Lion 

(Eastern AK DPS)* Eumetopias jubatus Threatened 

Includes sea lions born on 

rookeries from CA north 

through Southeast Alaska 

(NMFS 2008). 

Steller Sea Lion 

(Western AK DPS)* Eumetopias jubatus Endangered 

Includes sea lions born on 

rookeries from Prince William 

Sound westward (NMFS 

2009). 

Northern sea otter 

(SW Alaska 

Population) 

Enhydra lutris kenyoni Threatened 

The FWS listed only the sea 

otter populations in southwest 

Alaska as threatened (USDI 

2005, pp. 5-6). 

Leatherback Sea 

Turtle Dermochelys coriacea Endangered Species is "known to occur" in Alaska (USDI 2009a). 

Bowhead whale Balaena mysticetus Endangered Species is "known to occur" in 

Alaska (USDI 2009a). 

Finback whale Balaenoptera 

physalus Endangered Species is "known to occur" in 

Alaska (USDI 2009a). 

Humpback whale Megaptera 

novaeangliae Endangered Species is "known to occur" in 

Alaska (USDI 2009a). 

Yellow-billed Loon Gavia adamsii Candidate 

Nest near freshwater lakes in 

the arctic tundra and winter 

along the Alaskan coast to the 

Puget Sound (USDI 2009b). 

24 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
* DPS = Distinct population segment. 

The list of Alaska threatened, endangered, and proposed species from the NMFS is shown in Table 

2. Occurrence information was obtained from an email correspondence from Katharine Savage, 

NMFS, on 12 February 2009. A Section 7 Consultation will occur with the NMFS prior to initiation 

of this project (if needed). 

Table 2. Summary of NMFS (email correspondence 12 February 2009) listed threatened, endangered, proposed & 

candidate species for the Central Kupreanof Timber Harvest Project area and Alaska (NMFS 2009). 

Common Name Scientific Name Status 

Steller sea lion (Eastern DPS)* Eumetopias jubatus Threatened 

Steller sea lion (Western DPS)* Eumetopias jubatus Endangered 

Blue whale Balaenoptera musculus Endangered 

Bowhead whale Balaena mysticetus Endangered 

Fin whale Balaenoptera physalus Endangered 

Humpback whale Megaptera novaengliae Endangered 

North Pacific Right Whale Eubalaena japonica Endangered 

Sei whale Balaenoptera borealis Endangered 

Sperm whale Physeter macrocephalus Endangered 

Beluga whale (Cook Inlet DPS)* Delphinapterus leucas Endangered 

Spotted seal Phoca largha Candidate 

Bearded seal Erignathus barbatus Candidate 

Ringed seal Phoca hispida Candidate 

Green sea turtle Chelonia mydas Threatened 

Loggerhead turtle Caretta caretta Threatened 

Olive ridley turtle Lepidochelys olivacea Threatened 

Leatherback turtle Dermochelys coriacea Endangered 

Pacific herring (Lynn Canal DPS)* Clupea pallasi Candidate 

Puget Sound Chinook salmon Oncorhynchus tshawytscha Threatened 

Lower Columbia River Salmon Oncorhynchus tshawytscha Threatened 

Upper Columbia River Salmon Oncorhynchus tshawytscha Endangered 

Upper Willamette River Salmon Oncorhynchus tshawytscha Threatened 

Snake River Spring/Summer Salmon Oncorhynchus tshawytscha Threatened 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 25 Appendix E
Snake River Fall Salmon Oncorhynchus tshawytscha Threatened 

Snake River Sockeye Salmon Oncorhynchus nerka Endangered 

Upper Columbia River Steelhead Oncorhynchus mykiss Endangered 

Middle Columbia River Steelhead Oncorhynchus mykiss Threatened 

Lower Columbia River Steelhead Oncorhynchus mykiss Threatened 

Upper Willamette River Steelhead Oncorhynchus mykiss Threatened 

Snake River Basin Steelhead Oncorhynchus mykiss Threatened 

* DPS = Distinct population segment. 

SPECIES NOT ADDRESSED IN DETAIL 

Blue, right, finback, sei beluga, and sperm whales are generally found in off-shore (pelagic) marine 

waters of the Bering Sea, Chukchi Sea, Cook Inlet, North Pacific Ocean and/or Gulf of Alaska 

(NMFS 1998a, NMFS 1998b, and NMFS 1991a). No critical habitat has been designated for these 

species in Alaskan waters. Bowhead whales are distributed in seasonally ice-covered waters of the 

Arctic and near-Arctic, generally north of 54°N and south of 75°N in the western Arctic Basin. The 

majority of the Western Arctic stock migrates annually from wintering areas in the northern Bering 

Sea, through the Chukchi Sea in the spring, to the Beaufort Sea where they spend much of the 

summer before returning again to the Bering Sea in the fall to overwinter. No critical habitat has 

been designated for this species in Alaskan waters (Shelden and Rugh 1995). These species 

generally are not known to occur in the project area. These species do not occur in habitats likely to 

be affected by this project. Therefore, no effects to these species are expected and they will not be 

discussed further in this document. 

The spotted, bearded, and ringed seals that are listed in Alaska occur further north than the 

Petersburg Ranger District, in the Bering Sea and the Chukchi Sea (NMFS 2009), therefore are not 

impacted by our project area, and will not be discussed further in this document. 

The green, leather back, olive ridley and loggerhead sea turtles occur in the Gulf of Alaska and some 

species are found as far west as the Aleutian Islands. Adults are highly migratory, but the details and 

locations of migrations are largely unknown. These turtle species have been documented to occur in 

Southeast Alaska (NMFS 2009), but those sightings are considered incidental and the species are not 

common to the Central Kupreanof Timber Harvest Project area. These turtle species are suspected 

to be uncommon in Alaska marine waters and critical habitat has not been designated in Alaskan 

waters (NMFS 2007 and NMFS and FWS 1998). Leatherback, Green, Olive Ridley and Loggerhead 

turtles have not been documented in or around the salt waters of the Central Kupreanof Timber 

Harvest project area, and they are not known to occur in habitats likely to be affected by this project. 

Therefore, no effects to these species are expected and they will not be discussed further in this 

document. 

The Pacific Herring DPS is thought to be in the Lynn Canal area and it will be several months before 

the final delineation is made so we expect no effect to the Pacific herring, resulting from the Central 

Kupreanof Timber Harvest Project (NFMA 2009). 

26 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
None of the stocks of Pacific salmon or steelhead known to originate from freshwater habitat in 

Alaska are listed under the Endangered Species Act. However, some individuals of the listed 

species originating from freshwaters in the lower 48 states occur in Alaskan outside waters. No 

critical habitat has been designated for these species in Alaskan water (USDA 2008b, p. F-7). None 

of the listed stocks of salmon or steelhead are known to originate in Alaskan streams. However, 

many species and stocks are listed that originated from freshwater habitats in Washington, Idaho, 

Oregon, and California. Some of the listed species migrate into marine waters off the coast of 

Alaska. While distribution of these stocks is primarily in outer coastal waters some are occasionally 

present in the inner waters of Southeast Alaska and they may feed on prey resources originating 

within marine and estuarine waters of the Tongass National Forest (USDA 2008b, p. F-7). Critical 

habitat has not been designated for these species in Alaskan waters, therefore, no effect to these 

species is expected and they will not be discussed further in this document. 

General Forest Plan direction for threatened and endangered species applies (USDA 2008a, p. 4-98 

through 4-100). 

Effects Analysis

The analysis area was analyzed and a determination was made to assess the direct, indirect, and 

cumulative effects of the proposed project on proposed, endangered, and threatened species or 

critical habitat (50 CFR 402.14, FSM 2671.44) (Table 3). There will be no impact to the Eskimo 

curlew, polar bear, Northern sea otter, short-tailed albatross, spectacled eider, and Steller’s eider 

listed by the FWS and the blue whale, bowhead whale, fin whale, green sea turtle, leatherback sea 

turtle, olive ridley sea turtle, loggerhead sea turtle, North Pacific right whale, sei whale, sperm 

whale, or the Pacific herring listed by the NMFS have not been documented to occur in southeast 

Alaska, or on the Tongass National Forest, or in habitats likely to be affected by the Central 

Kupreanof Timber Harvest Project or they are not listed as threatened, endangered, or proposed in 

southeast Alaska. Therefore, there should be no direct, indirect or cumulative effects to these species 

and they will not be addressed further in this document. 

Affected Environment

The NMFS and FWS listed wildlife species that may occur within the waters surrounding the project 

area include the endangered humpback whale (Megaptera novaeangilae) and the threatened Steller 

sea lion (Eumetopias jubatus). This Biological Evaluation will address the Humpback whale and 

Steller Sea Lion in further detail. 

HUMPBACK WHALE 

The NMFS listed the humpback whale as a threatened species because of over-exploitation from 

commercial whaling (NMFS 1991, p.15). Primary objectives of humpback whale recovery include 

maintaining and enhancing habitat and rescuing human related mortality, injury, and disturbance. 

Humpback whales are the most abundant of the seven species of endangered whales that occur in 

southeast Alaska waters. They are common in the inside waters of the Alexander Archipelago and 

are regularly sighted in the Inside Passage and coastal waters of the southeast Alaska panhandle 

from Yakutat Bay south to Queen Charlotte Sound. The local distribution of humpbacks in Southeast 

Alaska appears to be correlated with the density and seasonal availability of prey, particularly 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 27 Appendix E
herring (Clupea harengus) and euphausiids (NMFS 1991, p. 18). Humpback whales feed in 

southeast Alaskan panhandle waters from about May through December, although some have been 

seen every month of the year. Peak numbers of whales are usually found in near shore waters during 

late August and September, but substantial numbers usually remain until early winter (NMFS 1991). 

Important feeding areas include Glacier Bay and adjacent portions of Icy Straight, Stephens 

Passage/Frederick Sound, Seymour Canal, and Sitka Sound. Glacier Bay and Icy Straight appear to 

be important feeding areas early in the season, when whales prey heavily on herring and other small, 

schooling fishes. Frederick Sound is important later in summer, when whales feed on swarming 

euphausiids. During autumn and early winter, humpbacks move out of the Sound to areas where 

herring are abundant, particularly Seymour Canal. Other areas of southeast Alaska may also be 

important for humpbacks and need to be evaluated. These include: Cape Fairweather, Lynn Canal, 

Sumner Strait, Dixon Entrance, the west coast of Prince of Wales Island, and offshore banks such as 

the Fairweather Grounds (NMFS 1991b). The NMFS has not designated critical habitats for this 

species in Alaskan waters. Humpback whales are known to use the waters of Fredrick Sound and 

Chatham Strait, areas already having high commercial vessel use; slow-moving barge traffic should 

not increase the disturbance of these animals. 

Specific Forest Plan direction for humpback whale is given on pages 4-98 to 4-99 (USDA 2008a). 

Direct and Indirect Effects 

The implementation of the Central Kupreanof Timber Harvest Project will have no direct effects to 

the Humpback whale or its habitat because it will occur on the upland, away from such habitat. 

Generally there is limited potential to directly affect whales with the operation of an LTF/MAF (log 

transfer facility/marine access facility). 

Two potential indirect effects of LTF/MAFs and other docking facilities and associated activities 

have been identified: 1) effects on whale prey species, and 2) disturbances of whales by boat traffic 

associated with LTF/MAFs. Tugs would maintain relatively constant speeds and directions during 

towing. Constant speed and direction elicit less avoidance behavior from whales than other types of 

boating activity. Towing routes are generally well-established, and adverse effects from barge 

towing have not been documented. 

Humpback whales may inhabit shallow coastal areas where they are increasingly exposed to human 

activity. Recovery plans for the humpback whale (NMFS 1991b, p. 25) identified potential human 

induced factors that could affect individual reproductive success, alter survival, and/or limit the 

availability of habitat for these species. Recreational boating activity would vary between seasons 

and years, and no permit logging camps are anticipated, however a floating camp may occur. It is 

estimated that most recreation boating would occur within a few miles of the site, few trips would be 

made over 10 miles, and activity greater than 30 miles from a site would be negligible. This boating 

would involve frequent changes in speed and direction and may include some small amount of whale 

pursuit, if the whales are within sight of the camp or an occupied boat. The effect of such 

recreational activity on whales would depend on many factors such as size of the bay, depth of the 

waters in the bay, number of boats, individual behavior responses of the whales, etc. We do not 

anticipate any change in recreational boating patterns because no new camps are planned as a result 

of this project. All Forest-wide Standards and guidelines (S&Gs) will be implemented during the 

operation of this LTF/MAF and all operators will be required to comply with these S&Gs. 

28 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
National Forest management activities that could have an effect on habitats or populations of this 

species generally fall into the categories of direct disturbance, acoustic disturbance, and habitat 

degradation (including effects to prey species). These effects are generally associated with the 

development and use of marine access facilities (MAFs), also referred to as log transfer facilities 

(LTFs), increase marine activities, and activities that alter stream habitat that flows into marine 

environments. The proposed action would have negligible direct, indirect or cumulative effects to 

the humpback whale, because activities would not increase marine activities or alter habitat that 

could affect streams or the marine environment. 

The Central Kupreanof project area will use the existing road system and the existing Little 

Hamilton LTF/MAF for all alternatives. Located outside of the project area at the end of NFS Road 

6000, the Little Hamilton LTF/MAF is the only LTF/MAF that can be used for this project. The 

transfer of harvested timber requires that logs be hauled directly to mills by trucks, or removed from 

trucks, transferred to salt water or barges at the Little Hamilton LTF/MAF, then towed to a mill. The 

intent of this Biological Evaluation was to analyze the Little Hamilton LTF/MAF as if it were fully 

permitted for activity including barging and raft/watering logs. Barge traffic will increase due to this 

project, but the waters of Fredrick Sound and Chatham Strait are high commercial vessel traffic 

areas and humpback whales are known to use these waters. Slow-moving barge traffic should not 

increase the disturbance of these animals. No land camp is proposed in the project area and 

appropriate permits would need to be acquired by the operator for use of a floating camp (DEIS Vol. 

A, pp. 3-13 and 3-39-3 through 41, Dec. 2008). 

Cumulative Effects 

No cumulative effects are anticipated because of the operation of the Central Kupreanof Timber 

Harvest Project or raft/barge and recreational boating traffic increases that may be caused by the sale 

activities. 

STELLER SEA LION 

NMFS recognizes two distinct population segments (DPS) of Steller sea lions. The eastern DPS 

includes sea lions born on rookeries from California north through Southeast Alaska; the western 

DPS includes those animals born on rookeries from Prince William Sound westward. The regulatory 

division between DPSs is Cape Suckling (144° west longitude) in the northeast Gulf of Alaska. 

However, frequent movement is seen across this boundary by animals from both populations, 

particularly juvenile animals (NMFS 2008, p. I-3). Due to persistent decline, the western DPS was 

reclassified as threatened, found at http://www.nmfs.noaa.gov/pr/pdfs/recovery/stellersealion.pdf. 

The Western Alaska DPS (distinct population segment) does not occur in the Central Kupreanof 

Timber Harvest Project area and will not be discussed further. 

Steller sea lion habitat includes marine and terrestrial areas. Adult Steller sea lions congregate at 

rookeries; a site where breeding occurs and sea lions may haulout during the non-breeding period. 

Rookeries are generally located on relatively remote islands, often in exposed areas that are not 

easily accessed by humans or mammalian predictors. The breeding season generally extends from 

late May to early July (NMFS 2008, p. I-2). During fall and winter many sea lions disperse from 

rookeries and congregate at “haulout” areas. Rookery and haulout locations are specific and use of 

these sites changes little from year to year. Rocks, reefs, beaches, breakwaters, navigational aids, 

floating docks and sea ice may also be used as haulouts. Life history and population information is 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 29 Appendix E
contained in the Recovery Plan (NMFS 2008) and is incorporated by reference. 

Critical habitat for Steller sea lions was designated by NMFS in 1993 (50 CFR 226). Three rookeries 

and 11 haulouts were designated as critical habitat in Southeast Alaska. Since this designation, two 

additional sites, Graves Rocks and Bialy Rocks, appear to have developed into rookeries (NMFS 

2008, p. I-14). Steller sea lion critical habitat includes a 20 nautical mile buffer and three large 

offshore foraging areas (see http://alaskafisheries.noaa.gov/protectedresources/stellers/habitat.htm). 

A known haul-out occurs on the Sukoi Islands off Kupreanof Island near the Five-mile Creek 

drainage near Petersburg, Alaska. They also occur on small islands at the mouth of Keku Strait and 

on small islands to the north of the project. These areas will not be impacted by this project. 

Specific Forest Plan direction for Steller sea lion is given on pages 4-93 and 4-98 to 4-99 (USDA 

2008a). 

Direct and Indirect Effects 

Southeast Alaska populations have not declined as much as other populations. Harassment or 

displacement of sea lions from preferred habitats by human activities such as boating, recreation, 

aircraft, log transfer facilities, log raft towing, etc. is a concern with regard to long term conservation 

of the sea lion in Southeast Alaska. Forest-wide S&Gs direct the forest Service to prevent and/or 

reduce potential harassment of sea lions and other marine mammals due to activities carried out by 

or under the jurisdiction of the Forest Service. 

Steller sea lions may inhabit shallow coastal areas where they are increasingly exposed to human 

activity. Recovery plans for Steller sea lion (NMFS 2008) identified potential human induced 

factors that could affect individual reproductive success, alter survival, and/or limit the availability 

of habitat for these species. National Forest management activities that could have an effect on 

habitats or populations of this species generally fall into the categories of direct disturbance, acoustic 

disturbance, and habitat degradation (including effects to prey species). These effects are generally 

associated with the development and use of marine access facilities (MAFs), also referred to as log 

transfer facilities (LTFs), increase marine activities, and activities that alter stream habitat that flows 

into marine environments. The proposed action would have negligible direct, indirect or cumulative 

effects to the Steller sea lion, because activities would not increase marine activities or alter habitat 

that could affect streams or the marine environment. A known haul-out occurs on the Sukoi Islands 

off Kupreanof Island near the Five-mile Creek drainage near Petersburg, Alaska. They also occur on 

small islands at the mouth of Keku Strait and on small islands to the north of the project. These 

areas will not be impacted by this project. 

Cumulative Effects 

Cumulative effects are not anticipated because of the operation of this project, or barging, 

recreational boat traffic or other human activities that may be caused by the Central Kupreanof 

Timber Harvest project. 

All Forest-wide Standards and guidelines (S&Gs) will be implemented during the operation of this 

LTF/MAF and all operators will be required to comply with these S&Gs. 

30 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
YELLOW-BILLED LOON 

The yellow-billed loon is the largest of the loon species. They nest near freshwater lakes in the 

arctic tundra of Alaska on the Arctic Coastal Plain, northwestern Alaska and Saint Lawrence Island, 

and in portions of Canada and Russia. Winter range includes the coastal waters of southern Alaska 

from the Aleutian Islands to Puget Sounds and portions of Asia, Norway and potentially Great 

Britain (USDI 2009b). 

Yellow-billed loons nest exclusively in coastal and inland low-lying tundra associated with 

permanent lakes. Lakes are generally larger in size (33 acres), greater than six feet deep, are often 

connected to streams and must be fish-bearing. Important lake features include clear water, 

dependable water levels, and shoreline vegetation. Nests are constructed of mud or peat and are 

located on islands, hummocks, peninsulas or along low shorelines within three feet (one meter) of 

the water (USDI 2009b). 

The FWS developed a conservation agreement to protect yellow-loons in 2006. The yellow-billed 

loon was designated as a candidate species throughout its range and petitioned for listing as a 

threatened or endangered species in March 2009 (Federal Register 2009). 

Although yellow-billed loon nest areas have not been identified on the Tongass NF, loons may be 

observed along the Pacific coast while migrating to winter habitat. General Forest Plan direction for 

seabirds and shorebird habitats apply to this species (USDA FS 2008a, pp. 4-93 to 94) and direction 

for the protection of beach, estuary and riparian habitats maintain some habitat for this species. 

Direct and Indirect Effects 

Although yellow-billed loon nest areas have not been identified on the Tongass NF, loons may be 

observed along the Pacific coast while migrating to winter habitat. General Forest Plan direction for 

seabirds and shorebird habitats apply to this species (USDA FS 2008a, pp. 4-93 to 94) and direction 

for the protection of beach, estuary and riparian habitats maintain some habitat for this species. 

Depending upon weather, the Central Kupreanof Timber Harvest project is likely to have reduced or 

no activity during times when loons may be present. 

Cumulative Effects 

No cumulative effects are anticipated because of the operation of the Central Kupreanof Timber 

Harvest project or raft/barge and recreational boating traffic increases that may be caused by the sale 

activities. 

All Forest-wide Standards and guidelines (S&Gs) will be implemented during the operation of this 

LTF/MAF and all operators will be required to comply with these S&Gs. 

Determinations

A determination was made to assess the effects of the project on threatened, endangered, candidate 

and proposed species or their critical habitat (50 CFR 402.14, FSM 2671.44). Based on the physical 

and biological requirements of the humpback whale and Steller sea lion and considering the potential 

effects from implementing the proposed action, it is my opinion that the locations of LTF/MAFs and 

the harvest of timber scheduled by this proposed action will not adversely affect the listed species or 

their habitats. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 31 Appendix E
I therefore request, that a “no effect” determination be rendered in regard to the humpback whale, 

Steller sea lion, and yellow-billed loon for the Central Kupreanof Timber Harvest Project. This 

action is not likely to jeopardize the continued existence of a listed species or result in the 

destruction or adverse modification of critical habitat in the project area. All project activities would 

be conducted in a manner consistent with the ESA and regulations. 

Table 3. Summary of FWS and NMFS listed T & E species and determinations for the Central 

Kupreanof Timber Harvest Project. 

Species Status Determination 1

Humpback whale Endangered No Effect 

Leatherback sea turtle Endangered No Effect—not known to occur 

within the project area 

Steller sea lion Threatened No Effect. 

Yellow-billed Loon Candidate No Effect. 

Snake River Sockeye Salmon Endangered No Effect—not known to occur 

within the project area 

Upper Columbia R. spring 

Chinook salmon Endangered No Effect—not known to occur within the project area 

Puget Sound Chinook salmon Threatened No Effect—not known to occur 

within the project area 

Lower Columbia R. Chinook 

salmon Threatened No Effect—not known to occur within the project area 

Upper Willamette R Chinook 

salmon Threatened No Effect—not known to occur within the project area 

Snake River spring/summer 

Chinook salmon Threatened No Effect—not known to occur within the project area 

Snake River fall Chinook 

Salmon Threatened No Effect—not known to occur within the project area 

Upper Columbia R. steelhead Endangered No Effect—not known to occur 

within the project area 

Middle Columbia R. steelhead Threatened No Effect—not known to occur 

within the project area 

Lower Columbia R. steelhead Threatened No Effect—not known to occur 

within the project area 

Upper Willamette R. steelhead Threatened No Effect—not known to occur 

within the project area 

Snake R. Basin steelhead Threatened No Effect—not known to occur 

within the project area 

1 - Possible determinations for T&E species and Designated Critical Habitat: “no effect”, “not likely to adversely 

affect”, or “likely to adversely affect”. Possible determinations for Proposed Species and Proposed Critical Habitat: “no 

effect”, "not likely to jeopardize proposed species, or adversely modify proposed critical habitat", or "likely to jeopardize 

proposed species, or adversely modify proposed critical habitat". 

IV. SENSITIVE SPECIES

Sensitive species are those plant and animal species identified by the Regional Forester for which 

population viability is a concern on NFS lands within the region. This is evidenced by a significant 

current or predicted downward trend in population numbers, density, or habitat capability that will 

reduce a species’ existing distribution (FSM 2670.5). The Forest Service Manual states that viable 

32 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
populations and habitat of these species will be maintained and distributed throughout their 

geographic range on NFS lands (FSM 2670.22). As part of the NEPA process, Forest Service 

impacts to these species will be minimized or avoided (FSM 2670.32). The BE should identify all 

sensitive species known or suspected to occur in the analysis area or all sensitive species that the 

project potentially effects (FSM 2672.42). 

The Alaska Region Sensitive Species List was last updated in 2009 (Table 4) (FSM 2600 

Supplement No.: R-10 2600-2009-1). The Regional Sensitive Species List continues to be revised as 

new information dictates (USDA 2009). 

Table 4. Alaska Region (R10) listed sensitive species. 

Common Name Scientific Name 

Kittlitz’s murrelet Brachyramphus brevirostris 

Queen Charlotte goshawk Accipiter gentilis laingi 

Aleutian Tern Sterna aleutica 

Black oystercatcher Haematopus bachmani 

* Based on our Alaska Region and National Forest System policy, USFWS and NMFS Candidate species are considered and treated 

as FS Sensitive, analyzed as such per Regional Forester letter to Forest Supervisors, February 5, 2009 (USDA 2009). 

Affected Environment

The Alaska Region (10) listed sensitive species that may occur within the Central Kupreanof Timber 

Harvest Project are the Kittlitz’s murrelet, Queen Charlotte/Northern goshawk, Aleutian tern, and 

the Black oystercatcher. This Biological Evaluation will address these four species in further detail. 

KITTLITZ’S MURRELET 

On May 9, 2001, the Secretary of the Interior was petitioned to list the Kittlitz’s murrelet as 

endangered with concurrent designation of critical habitat under the ESA. Petitioners cited dramatic 

reductions in population size over the past decade and declining habitat quality as reasons for the 

requested listing. The species was officially designated a candidate species (warranted, but 

precluded) on May 4, 2004. A candidate species is a species for which the FWS has sufficient 

information to support a proposal to list as endangered or threatened, but for which preparation and 

publication of a proposal is precluded by higher priority listing actions. The Kittlitz’s murrelet has 

been designated as a sensitive species, added to the R10 sensitive species list. Current Forest Plan 

direction for sensitive species applies (USDA 2009). 

Kittlitz’s murrelet is a small diving seabird that is closely associated with glacial habitats along the 

Alaska mainland coast. The only North American population occurs in Alaskan waters from Point 

Lay south to the northern portions of Southeast Alaska (Endicott and Tracey Arm). The largest 

breeding populations are believed to be in Glacier Bay National Park and Preserve, Prince William 

Sound, Kenai Fjords, and Icy Bay (Kendall and Agler 1998). The Kittlitz’s murrelet population has 

shown a significant decline in Prince William Sound, Glacier Bay and in the Malaspina Forelands 

(USDI 2006c). The Prince William Sound population has shown an 18 percent per year decline and 

an 84 percent decline from 1989 to 2000. The Glacier Bay population declined approximately 80 

percent between 1991 and 2000. In the Malaspina Forelands the population has declined at least 38 

percent (5 percent per year) but possibly up to 75 percent between 1992 and 2002 (USDI 2002). 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 33 Appendix E
Major threats to this species are global warming, which is correlated with a loss of suitable habitat 

(glacial melt) and reduction in prey availability due to warming sea temperatures. Human activity in 

the marine environment, particularly vessel traffic and fishing operations, are additional threats. 

Speculated causes for Kittlitz’s murrelet decline include: glacial recession, oil pollution, gillnet 

mortality, and availability of preferred forage fish (Kuletz et al. 2003; Piatt and Anderson 1996). 

Increased disturbance from helicopter tours and cruise ships may also be a factor. 

They have been seen as far south as Frederick Sound, Snow Passage and Sea Otter Sound (Day et al. 

1999). During the breeding season they congregate near tidewater glaciers and offshore of remnant 

high-elevation glaciers. Breeding sites are usually chosen in the vicinity of glaciers and cirques in 

high elevation alpine areas with little or no vegetative cover (van Vilet 1993). When present, 

vegetation is primarily composed of lichens and mosses (Day et al. 1983). The species generally 

nests within 0.2 to 47 miles inland and a short distance below peaks or ridges on coastal cliffs, and 

on barren ground, rock ledges, or talus above timberline (Day et al. 1983). During winter and spring, 

the marine distribution of Kittlitz’s murrelet is farther offshore in the Alaska costal Current and midshelf region (USDI 2006c). 

Nesting habitat includes unvegetated scree fields, coastal cliffs, barren ground, rock ledges and talus 

above timberline in coastal mountains in the vicinity of glaciers, cirques near glaciers or recently 

glaciated areas (Day et al. 1999). 

Prey consists of fish (Pacific sand lance (Ammodytes hexapterus), Pacific herring (Clupea pallasi), 

capelin (Mallotus villosus), Pacific sandfish (Trichodon trichodon), euphausiids, amphipods and 

small crustacean (Day et al. 1999). They forage extensively near outflow from glaciers, both 

tidewater and retreated glaciers with turbid glacial streams, primarily within 656 ft (200m) from 

shore (Day et al. 1999). 

Kittlitz’s murrelet is known to occur on the oceanic glaciers that occur on the Petersburg Ranger 

District. These glacial outwashes are within landscapes that fall outside normal land disturbance 

projects and we do not expect Forest Service activities to affect these areas. This habitat is found on 

the mainland portions of the Petersburg Ranger District and potentially in the marine waters 

surrounding Kupreanof Island. It is made up of active glacial terrains and boundary range icefields 

(Nowacki et al. 2001). The majority of these ecological subsection areas are managed as natural 

settings, within wilderness or national monuments. The main areas are the Le Conte, Patterson and 

Baird Glaciers. There is no known habitat for Kittlitz’s murrelet in the Central Kupreanof Timber 

Harvest project area. 

Due to the Kittlitz’s murrelets' association with glacial habitat, this species occupies areas outside of, 

and is not known to occur in the Central Kupreanof Timber Harvest project area. Kittlitz’s murrelet 

will not be discussed further in this document. 

General Forest Plan direction for sensitive species applies (USDA 2008a, p. 4-99 through 4-100). 

Effects Analysis 

The Central Kupreanof Timber Harvest Project area was analyzed to assess the direct, indirect, and 

cumulative effects of the proposed project on sensitive species and/or their critical habitats (50 CFR 

402.14, FSM 2671.44). The Northern/Queen Charlotte goshawk, Aleutian tern, and Black 

34 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
oystercatcher will be included in the effects analysis of sensitive species in this Biological 

Evaluation. 

NORTHERN/QUEEN CHARLOTTE GOSHAWK 

The northern goshawk is identified as a species of concern throughout its range and is identified as a 

sensitive species by the Alaska Region of the USFS. In an effort to evaluate the status, population, 

and habitat ecology of the northern goshawk on the Tongass National Forest, the Alaska Department 

of Fish and Game (ADF&G) and the Forest Service (FS) conducted a goshawk study from 1991 to 

1999. A total of 63 nesting sites in Southeast Alaska were documented as a result of this study. A 

“nest site” is defined as the portion of a goshawk pair’s home range that contains all active and 

inactive nests. Of 47 nest trees (trees that include a nest), 53 percent were in Sitka spruce, 43 percent 

were in western hemlock, and 4 percent were in yellow cedar (ADGF 2006). 

Productive old growth (POG) forest is an important component of goshawk habitat in southeast 

Alaska. POG forest is characterized as an old growth forest type that generally includes older and/or 

larger trees with a dense canopy and a diverse understory. The goshawk is a wide-ranging forest 

raptor that occupies old-growth forest habitat in Southeast Alaska. Of 661 radio relocations of 

goshawks in Southeast Alaska, over 90 percent were in habitat classified as volume class 4, defined 

as 8,000 to 20,000 board feet of timber or greater. It is defined as volume strata low, medium, and 

high in the GIS database (USDA 2008a, p. 7-29). Volume strata use timber volume, soil, and slope 

information to assess POG forest. Goshawks select POG forest types at all scales (nest tree, nest site, 

post-fledging areas). However, non-productive forest types and second-growth stands are also used 

by goshawks for movement and foraging (ADGF 2006). Sixty-eight percent were in habitats 

classified as volume class 5, defined as 20,001 to 30,000 board feet of timber (USDA 2008a, p. 3-

262 through 3-265) or greater (Titus et al. 1994, p. 4). Suitable nest site habitat consists of large trees 

with a dense canopy and generally an open under-story averaging 12 to 37 acres in size (Flatten et al. 

2001). Although goshawks prefer to place their nests in mature to old growth forest types, they will 

nest in younger forest or in smaller patches of trees, and forage in young forest as well as along 

edges and in openings (Boyce et al. 2006). Although there is some documented use of second growth 

in southeast Alaska, for the most part goshawks are associated with older forests. Of 18 nest trees, 83 

percent were located in old-growth stands, and 17 percent were in second growth trees greater than 

90 years of age (Titus et al. 1994, p. 4). Goshawk nest sites generally occur far from openings, in 

stands more than 600 feet wide, on slopes of less than 60 percent, and near the toe of a slope or on a 

bench. On average, nest trees occur at 423 feet elevation but generally do not occur above 1,100 feet 

(USDA 2008b pp. D-22 through D-25; Titus et al. 1994, p. 5). 

Foraging areas comprise the largest percentage of the goshawk’s home range. Foraging habitat is 

characterized by forested stands with a greater diversity of age classes and structural characteristics 

(e.g., snags, woody debris) than nesting areas (Reynolds et al. 1992, p. 16). Breeding season home 

range size is strongly dependent upon the quality of foraging habitat and prey availability. In 

Southeast Alaska, prey remains were dominated by a few key species including Steller’s jays 

(Cyanocitta stelleri), grouse (Dendragapus spp.), varied thrush (Ixoreus naevius), red squirrel 

(Tamiasciurus hudsonicus) and woodpeckers (Picidae) (Titus et al. 1994, p. 6). In prey-rich areas 

blue grouse and red squirrel are the dominant prey items taken (ADGF 2006). Lewis (2001) found 

that red squirrels account for 19 percent of the prey deliveries to goshawk nests in prey-rich areas. 

On islands where blue grouse and red squirrels are not present, spruce grouse, Steller’s jays, and 

ptarmigan are the dominant prey items taken. Small mammals make up a small portion of the overall 

diet. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 35 Appendix E
Forest Plan standards and guidelines require the maintenance of an area of not less than 100 acres of 

POG, if it exists, generally centered over the nest tree or probable nest tree. Continuous disturbances 

likely to result in nest abandonment within the surrounding 600 feet of the nest are not permitted 

from March 15 to August 15. 

The FWS completed a review and determined that the subspecies’ populations in British Columbia 

(B.C.) and Alaska each constitute distinct population segments (DPS) of the Queen Charlotte 

goshawk. Based on difference in forest management with substantially greater existing and 

anticipated habitat loss in B.C. than in Alaska, the FWS determined that the B.C. DPS would be 

listed as threatened or endangered but the Alaska DPS would not be listed (Federal Register 2007). 

Adult home ranges on the Tongass are some of the largest recorded for the species; averaging 9,640 

acres for females and 10,625 acres for males during the nesting season, and 29,160 acres for females 

and 29,400 acres for males outside the nesting season (ADFG 2006). 

The Petersburg Ranger District has five known northern goshawk nest sites in the Central Kupreanof 

Project Area, including a new one found in the 2006 survey season, named Wishbone. In the 2 

consecutive years 2006/2007, the Central Kupreanof Timber Harvest Project Area was surveyed for 

northern goshawk nesting activity. The survey time totaled approximately 262 hours. Of these 

hours, approximately 62 were spent surveying known nesting sites and 200 were spent surveying 

potential timber sale project areas. A new goshawk site was discovered on Kupreanof Island 

adjacent to Tunehean creek, in addition to the Big John Creek and Irish Lake nest sites, previously 

known within the Central Kupreanof Timber Harvest Project. This new goshawk nest site, found in 

the southern end of the project area, was named the Wishbone nest site—because of the wishbone 

shape of the creek. Several other observations of goshawks were made in the area, but none were 

indicative of nesting behavior. The existing nest site, Big John Creek, was active in the 2006 season 

with two goshawk fledglings observed there. The Big John Creek goshawk nest had not shown signs 

of activity since 1993. Since its discovery 16 years ago, it has been surveyed all but 3 seasons (1996, 

2001, and 2004). 

Methods for conducting these surveys included broadcast calls and valley watches. This was done in 

the 2 consecutive years (2006/2007) field seasons. Broadcast call surveys were completed using a 

goshawk alarm call and juvenile begging calls amplified on a speakerphone. Calls were played at 

three intervals of 30 seconds with 15-second pauses between each. After the series of calls were 

completed, there was a one-minute pause before moving to the next station. Broadcast stations were 

completed every 400 feet along each transect. Valley watches were completed by recording any 

goshawk sightings from a stationary viewpoint over the survey area. Sites were selected for surveys 

based on availability of potential quality habitat and sites that were in units proposed for the Central 

Kupreanof Project. Known goshawk nest sites in the project area include Irish Lake, Big John Creek, 

and the new Wishbone nest. Data was recorded using a Garmin GPS unit, time, notes on available 

habitat, weather, other species observed, and if there were northern goshawk or other responses to 

the broadcast calls. 

The General Forest Plan direction includes a conservation strategy for goshawks that includes a 

system of reserves (Old Growth Habitat Reserves and other non-development LUD) and direction 

for managing the matrix between reserves (USDA 2008a, pp. 4-99 and 4-100). The primary focus of 

the matrix direction is to preserve nesting habitat around confirmed and probable nests. Information 

regarding survey methods, time, and results is from field surveys and spreadsheets from the 2 

36 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
consecutive monitoring years of 2006 and 2007. 

Eighty-one percent of the confirmed and probable nest sites in Southeast Alaska are south of 

Frederick Sound. The Regional Forester added this species to the Sensitive Species List in 1994, 

and the 2009 revision reflects the same listing (USDA 2009). 

Direct and Indirect Effects 

Direct effects to goshawks can result from disturbances that adversely affect individuals or their 

young. Indirect and cumulative effects result from the reduction of perching and foraging habitat and 

potential nesting habitat or the reduction in long-term productivity. 

The Central Kupreanof Timber Harvest Project provides for a range of action alternatives regarding 

the reduction of POG within the WAA. There is approximately 268,611 acres of POG in the WAA. 

The alternatives range from no harvest to the potential harvest of approximately 3,568 acres of POG 

within the WAA. This reduction in habitat is not considered significant, as it is only approximately a 

1.3 percent change and is not expected to affect wildlife populations (DEIS Vol. A, p. 3-82, Dec. 

2008). 

Timber harvest resulting in conversion of POG forest to young-growth, has contributed to a decline 

in goshawk habitat. In the contiguous United States, such habitat change is believed to reduce the 

number of breeding goshawks by degrading the structural character of forests used for nesting and 

foraging. However, it is still unclear how goshawk populations respond to habitat modifications 

because study of effects across a gradient of harvest intensity is lacking (Boyce et al. 2006). 

Cumulative Effects 

The proposed activity would have negligible direct, indirect or cumulative effect to goshawks 

because activities would not occur within nest buffers or within 600 feet of nest sites, or during 

applicable closures from March 15 through August 15. 

The S&Gs applied to the management activities described in the Central Kupreanof DEIS will meet 

those requirements of the Forest Plan. Known goshawk nest sites are protected by a least a 100-acre 

buffer surrounding the nest and consisting of productive old growth (POG) habitat. The prescribed 

goshawk nest site buffer for each nest site meets the S&Gs from the Forest Plan. 

No cumulative effects are expected to the goshawk by implementation of the Central Kupreanof 

Timber Harvest project. There would be a maximum of 1.3% of the POG harvested and maximum 

reduction of 28.3% cumulatively in the WAA; this reduction in habitat is insignificant and is not 

expected to affect wildlife populations. Individual goshawks may be affected by the project, but it 

will not cause a trend to federal listing or a loss of viability. 

ALEUTIAN TERN 

The Aleutian Tern (Sterna aleutica) is a coastal, colonial nesting seabird of Alaska and eastern 

Siberia. Discovered in 1868 on Kodiak Island, this species has been little studied to date. The terns 

range is coastal areas of southern and western Alaska. Breeding colonies often shift year to year, 

especially in the Northern Bering and Chukchi seas. Breeding colonies have been located along 

coast of Chukchi Sea as far north as Kasegaluk Lagoon, on Seward Peninsula, Yukon-Kuskokwim 

River Delta, along Alaska Peninsula, in scattered locations in the Aleutian Islands, on the Kodiak 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 37 Appendix E
Archipelago, on Kenai Peninsula, Copper River delta, and along the Gulf of Alaska as far east as 

Dry Bay. Aleutian terns may breed farther south and east at Lituya Bay and Glacier Bay (North 

1997). 

On its breeding grounds, this tern frequently associates with Arctic Terns (Sterna paradisaea) in 

North America. Its distribution, abundance, breeding phenology, and habitat use are fairly well 

known, but its behaviors are not well described (North 1997). 

Colonies in North America are generally located between 51°20’N and 69°50’N latitude. Colonies 

are coastal in North America, up to 3.2 km inland in sub-Arctic and boreal regions. Colonies are 

usually located on flat vegetated islands, dwarf-shrub tundra, grass and sedge meadows, sandy spits 

and islands (usually on inner side of barrier islands, in lagoon systems, or river estuaries), and 

freshwater marshes (North 1997). 

Usually forages in shallow water, including tidal “rips”, along rivers, and over inshore marine 

waters, but not in freshwater lakes along outer Alaska Peninsula. The Aleutian tern forages in nearshore marine waters, up to 11 km offshore from Seward Peninsula, and pelagic waters >50 km 

offshore from other colonies, but, the species reportedly forages nearly exclusively over bays and 

fjords. One flock observed foraging in Prince William Sound where the muddy Copper River water 

and clear marine water meet (North 1997). 

Some causes for Aleutian tern mortality include: [scarcely] shooting and trapping, [historically] 

pesticides and other contaminants; ingestion of plastics, lead, and other toxins, degradation of 

habitat, disturbance at nest and roost sites, and occasionally human research impacts at roost sites 

(North 1997). Data from studies of the Aleutian Tern Working Group recently reviewed the species 

status, natural history, uses, and threats and concluded that data suggests suspected causes of natural 

and human-induced population decline causes (FSM 2600 Supplement No.: R-10 2600-2009-1). 

Population viability concerns have been raised due to reduced size or disappearance of colonies in 

Kodiak, Prince William Sound, Yakutat, and Icy Bay. The largest colonies on record exist or existed 

on the Cordova and Yakutat Ranger Districts. An estimated population in the Cordova area of 

greater than 2,400 individuals in 1980 may be less than 400 now. Whereas some of the colonies are 

in remote sites, others exist in areas where Forest Service permitting can cause or relieve site 

perturbations (FSM 2600 Supplement No.: R-10 2600-2009-1). 

The LTF/MAF area in the Central Kupreanof Timber Harvest project is an area in the project that 

occurs at the beach and could potentially have Aleutian tern habitat. The area is approximately 0.71 

acres of the entire project, the rest of the activity will occur upland and away from any prospective 

habitat areas for the Aleutian tern. The project also includes land adjacent to Duncan Canal; however 

the activities will be upland and will not be impacting the beach areas. The direction from the Forest 

Supervisor on a new “Alaska Region Sensitive Species List, for immediate use” was distributed on 

February 5, 2009, therefore, this direction is not specifically reflected in the 2008 Forest Plan, 

however general direction for sensitive species applies.

General Forest Plan direction for sensitive species and Seabird Rookeries and Shorebirds can be 

found on pages 4-92 through 4-100. 

Direct and Indirect Effects 

The LTF/MAF area, at Little Hamilton Bay, in the Central Kupreanof Timber Harvest project, is the 

38 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
area in the project that occurs at the beach and could potentially have Black oystercatcher habitat. 

This is an existing LTF/MAF, so there will be no construction disturbance. Barge, tug, and 

recreational boat traffic as a result of the project activity will increase human presence in the area, 

but there is no known documentation of occurrence of the Black oystercatcher or critical habitat for 

the species in LTF/MAF area of the Central Kupreanof Timber Harvest Project. The LTF/MAF area 

is approximately 0.71 acres of the entire project, the rest of the activity will occur upland and away 

from any prospective habitat areas for the Aleutian tern. The project also includes land adjacent to 

Duncan Canal, however the activities will be upland and will not be impacting the beach areas, due 

to the fact that there is not an LTF/MAF in Duncan Canal and therefore will not cause barge or boat 

traffic as a result. All Forest-wide Standards and guidelines (S&Gs) will be implemented during the 

operation of this LTF/MAF and all operators will be required to comply with these S&Gs. 

Cumulative Effects 

The proposed activity for the Central Kupreanof Timber Harvest Project will have negligible effects 

to the Black oystercatcher and the associated habitat for the species. No impacts to either species 

should occur because of the limited amount of habitat available within this project. 

BLACK OYSTERCATCHER 

The Black Oystercatcher (Haematopus bachmani) is an eye-catching, with orange bill and coal black 

plumage, a member of the rocky inter-tidal communities along the west coast of North America. 

Completely dependent on marine shorelines for its food and nesting, this is a monogamous, longlived bird (Andres, B. A. and G. A. Falxa, 1995). In Prince William Sound, AK, nesting pairs 

distributed along shorelines as follows: exposed rocky shores 10%, exposed wave-cut platforms 

21%, mixed sand and gravel beaches 21%, gravel beaches 30%, sheltered rocky shores 15%, and 

sheltered tidal flats 3%. Pairs distributed fairly equitably between rocky (45%) and gravelly (55%) 

shorelines (Andres, B. A. and G. A. Falxa, 1995).

Breeding pairs establish well-defined feeding and nesting territories and generally occupy the same 

areas year after year, usually along low-sloping gravel or rocky shorelines where inter-tidal prey 

species are abundant. Pairs nest just above the high-tide line and use the inter-tidal zone to feed 

themselves and their chicks and their reproductive rates are slow. Rocky shores exposed to surf 

action and on sheltered gravel, cobble, or sandy shores and mudflats of bays and sounds are 

extremely important to microhabitat foraging. Access to foraging habitat is almost exclusively 

dependent on tides changes and surf action, with most feeding done during low tide. They feed on 

inter-tidal marine invertebrates, including molluscs (bivalves, limpets, whelks, and chitons—

generally numerous in areas of rocky substrates); but also crabs, sea urchins, isopods, and barnacles. 

Sea mussels are taken as prey in Southeast Alaska. Oysters, contrary to the name of the bird, are not 

typically a part of the diet (Andres, B. A. and G. A. Falxa, 1995). Black Oystercatchers have been 

known to congregate in the winter months in Prince William Sound where mussel beds are dense; 

prey does not however vary greatly with seasonal changes. 

Black Oystercatchers have a small global population (estimates of 8,500 – 11,000 individuals) with 

distribution from the Aleutian Islands down the Pacific Coast to Baja California. Over half, (65%) 

of the population of Black oystercatchers breeds in Alaska. Populations were affected by the 1989 

Exxon Valdez oil spill in Prince William Sound, recovery has been slow, and oil still lingers in 

nesting areas. Aggregations usually number <100 birds, but have been known to reach 350 birds on 

Kodiak Island and 600 birds in the Glacier Bay area. The highest recorded breeding densities in 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 39 Appendix E
Alaska (and British Columbia and Washington) occur on non-forested islands dominated by shell or 

gravel beaches. Nesting densities in Glacier Bay were 10 times higher on sparsely vegetated islands 

than on heavily vegetated islands (Andres, B. A. and G. A. Falxa, 1995). 

Chick survival is low due to several natural and human-induced factors; including snow conditions, 

timing, prey availability, nest predation, and human use. Data indicates extensive overlap between 

nesting territories and remote shoreline campsites. Viability of this species remains a concern and 

populations in some areas have dramatically declined, due to unknown causes (from 48 pairs to 2 

pairs in Sitka Sound), and there is high overlap between nest sites and areas permitted for 

recreational use (e.g., Prince William Sound) (FSM 2600 Supplement No.: R-10 2600-2009-1). 

Retreat of glaciers, which expose gravel moraines, and uplifting events of earthquakes create new 

nesting habitat in Alaska (Andres, B. A. and G. A. Falxa, 1995). 

The LTF/MAF area in the Central Kupreanof Timber Harvest project is an area in the project that 

occurs at the beach and could potentially have Aleutian tern habitat. The area is approximately 0.71 

acres of the entire project, the rest of the activity will occur upland and away from any prospective 

habitat areas for the Aleutian tern. The project also includes land adjacent to Duncan Canal; however 

the activities will be upland and will not be impacting the beach areas. The direction from the Forest 

Supervisor on a new “Alaska Region Sensitive Species List, for immediate use” was distributed on 

February 5, 2009, therefore, this direction is not specifically reflected in the 2008 Forest Plan, 

however general direction for sensitive species applies.

General Forest Plan direction for sensitive species and Seabird Rookeries and Shorebirds can be 

found on pages 4-92 through 4-100. 

Direct and Indirect Effects 

The LTF/MAF area, at Little Hamilton Bay, in the Central Kupreanof Timber Harvest project is the 

area in the project that occurs at the beach and could potentially have Black oystercatcher habitat. 

This is an existing LTF/MAF, so there will be no construction disturbance. Barge, tug, and 

recreational boat traffic as a result of the project activity will increase human presence in the area, 

but there is no known documentation of occurrence of the Black oystercatcher or critical habitat for 

the species in LTF/MAF area of the Central Kupreanof Timber Harvest Project. The LTF/MAF area 

is approximately 0.71 acres of the entire project, the rest of the activity will occur upland and away 

from any prospective habitat areas for the Aleutian tern. The project also includes land adjacent to 

Duncan Canal, however the activities will be upland and will not be impacting the beach areas, due 

to the fact that there is not an LTF/MAF in Duncan Canal and therefore will not cause barge or boat 

traffic as a result. All Forest-wide Standards and guidelines (S&Gs) will be implemented during the 

operation of this LTF/MAF and all operators will be required to comply with these S&Gs. 

Cumulative Effects 

The proposed activity for the Central Kupreanof Timber Harvest Project will have negligible effects 

to the Aleutian tern and the associated habitat for the species. No impacts to either species should 

occur because of the limited amount of habitat available within this project. 

Determinations

Table 5 displays a summary of determinations for fish and wildlife species listed as sensitive in 

Region 10. Determinations were based on current forest direction (Bosch 2004). The proposed 

40 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
action for the Central Kupreanof Timber Harvest Project may impact individual goshawks but is not 

likely to cause a trend toward federal listing or a loss of viability. This proposed action will not 

detrimentally impact any suitable habitat or cause disturbance to Kittlitz’s murrelet, Aleutian Tern, 

or Black Oystercatcher. It is my determination that the Proposed Action Alternatives for the Central 

Kupreanof Timber Harvest Project may impact individual goshawks and I expect no impacts to the 

Kittlitz’s murrelet, Aleutian Tern, and Black Oystercatcher. 

Table 5. Summary of determinations for sensitive species for the Central Kupreanof Project. 

Common Name Scientific Name Determination 1

Kittlitz’s murrelet Brachyramphus brevirostris No Impact; not known to 

occur in project area 

Northern goshawk Accipiter gentilis laingi 

May impact individuals but 

not likely to cause a trend to 

federal listing or a loss of 

viability 

Aleutian Tern Sterna aleutica No Impact; not known to 

occur in project area 

Black oystercatcher Haematopus bachmani No Impact; not known to 

occur in project area 

1 – Potential determinations for Sensitive Species: "no impacts", "beneficial impacts", "may impact individuals but not 

likely to cause a trend to federal listing or a loss of viability", or "likely to result in a trend to federal listing or a loss of 

viability" (Bosch 2004). 

Additional Management Measures 

If any previously undiscovered endangered, threatened or sensitive species are encountered at any 

point in time prior to or during the implementation of this project, a District Biologist would be 

consulted and appropriate measures would be enacted. 

The Forest Plan contains a comprehensive conservation strategy, using a system of Old Growth 

LUDs designed to provide old growth habitats in combination with other non-development LUDs to 

maintain viable populations of native and desired non-native fish and wildlife species and subspecies 

that may be associated with old growth forests (USDA 2008b, p. 3-174 through 3-175). This 

strategy, in addition to the implementation of Forest Plan standards and guidelines, was developed to 

maintain species viability. The application of the Forest Plan standards and guidelines is integral to 

protecting and providing habitat to maintain viable fish and wildlife populations. 

VI. REFERENCES

Alaska Department of Fish and Game. 2006. Northern goshawks on the Tongass National Forest—

summary of study findings related to forest management. Slide presentation from the 

Interagency Review of the Tongass National Forest Conservation Strategy Meeting, Ketchikan, 

Alaska. Found at http://tongass-constratreview.net/Documents/Present7-GoshawkLocalNewInfo.pdf 

Andres, B. A. and G. A. Falxa. 1995. Black Oystercatcher (Haematopus bachmani), The Birds of 

North America Online (A. Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from 

the Birds of North America Online from 

http://bna.birds.cornell.edu/bna/species/155doi:10.2173/bna.155 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 41 Appendix E
Bosch, M. 2004. BA and BE Effects, and Determinations of Effects, for TEPS Species. USDA 

Forest Service. Region 10. 2 pp. 

Boyce, D.A., Jr., R. T. Reynolds, and R. T. Graham. 2006. Goshawk status and management: what 

do we know, what have we done, where are we going? Pages 312-325 in M. L. Morrison, 

editor. The northern goshawk: a technical assessment of its status, ecology, and management. 

Studies in Avian Biology No. 31, Cooper Ornithological Society. 14 pp. 

Day, R.H., K.J. Kuletz and D.A. Nigro. 1999. Kittlitz’s murrelet (Brachyramphus brevirostris). In: 

A. Poole and F. Gill, eds., The Birds of North America, No. 435. The Birds of North America, 

Inc., Philadelphia, PA. 

Day, R. H., K.L. Oakley and D.R. Barnard. 1983. Nest Sites and Eggs of Kittlitz’s and Marbled 

Murrelets. Condor 85(3) L265-273. 9 pp. 

Federal Register. 2009. Endangered and threatened wildlife and plants: 12-month finding on a 

petition to list the Yellow-billed loon as threatened or endangered. Vol. 74, No. 56. 38 pp. 

Federal Register. 2007. Rules and regulations. 50 CFR 17. Endangered and threatened wildlife 

and plants; response to court on significant portion of the range, and evaluation of distinct 

population segments, for the Queen Charlotte goshawk (Accipiter gentilis laingi). Vol. 72, No. 

216. 18 pp. 

_________. 2006. 50 CFR Part 226. Critical habitat for Steller sea lions. 7 pp. 

_________. 2004. 50 CFR Part 402. Interagency Cooperation – Endangered Species Act of 1973, 

as amended. 4 pp. 

Flatten, C., K. Titus and R. Lowell. 2001. Northern goshawk monitoring, population ecology and 

diet on the Tongass National Forest. Grant SE-4-2-6. Alaska Department of Fish and Game, 

Douglas, Alaska. 33 pp. 

Forest Service Manual. 2005. Chapter 2600 – Threatened, endangered and sensitive plants and 

animals. Supplement No. R-10 2600-2005-1. 19 pp. 

_________. 1995. Title 2670 – Wildlife, fish and sensitive plant habitat management. Amendment 

No. 2600-95-7. 21 pp. 

_________. 1990. Title 2672.24b to 2676.17b – Wildlife, fish and sensitive plant habitat 

management. WO Amendment No. 2600-90-1. 18 pp. 

Kendall, S.J. and B.A. Agler. 1998. Distribution and abundance of Kittlitz’s murrelets in southcentral and southeastern Alaska. Colonial Waterbirds 21(1):53-60. 8 pp. 

Kuletz, K.J., S. W. Stephensen, D.B. Irons, E.A. Labunski, and K.M. Brenneman. 2003. Changes in 

Distribution and Abundance of Kittlitz’s Murrelets (Brachyramphus brevirostris) relative to 

glacial recession in Prince William Sound, Alaska. Marine Ornithology 31:133-140. 7 pp. 

42 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Lewis, S. B. 2001. Breeding season diet of northern goshawks in southeast Alaska with a 

comparison of techniques used to examine raptor diet. MS Thesis. Boise State Univ., Boise, 

ID. 112 pp. 

National Marine Fisheries Service. 2009. Email from Katharine Savage (NMFS) to Chuck Parsley 

(USDA FS), 12 February 2009, document containing current Alaska ESA TEPC listed 

species recognized by the NMFS [Table 1]; maps including sea turtle spp. range in AK and 

seal spp. range in AK. 

_________. 2008. Recovery Plan for the Steller Sea Lion (Eumetopias jubatus). Revision. 

National Marine Fisheries Service, Silver Spring, MD. 325 pp. Available from 

http://www.nmfs.noaa.gov/pr/pdfs/recovery/stellersealion.pdf. 

_________. 2007. Green, Leatherback, Loggerhead, and Olive Ridley sea turtle fact pages. From 

http://www.nmfs.noaa.gov/pr/species/turtles. 

_________. 1998a. Recovery plan for the blue whale (Balaenoptera musculus). Prepared by Reeves 

R.R., P.J. Clapham, R.L. Brownell, Jr., and G.K. Silber for the National Marine Fisheries 

Service, Silver Spring, Maryland. 42 pp. 

__________. 1998b. Draft recovery plan for the fin whale (Balaenoptera physalus) and sei whale 

(Balaenoptera borealis). Prepared by Reeves, R.R, G.K Silber and P.M. Payne for the 

National Marine Fisheries Service, Silver Spring, Maryland. 65 pp. 

__________. 1991a. Recovery plan for the northern right whale (Eubalaena glacialis). Prepared by 

the Right Whale Recovery Team for the National Marine Fisheries Service, Silver Spring, 

Maryland. 86pp. 

__________. 1991b. Recovery plan for the humpback whale (Megaptera novaeangliae). Prepared 

by the Humpback Whale Recovery Team for the National Marine Fisheries Service, Silver 

Spring, Maryland. 105 pp. 

__________ and U.S. Fish and Wildlife Service. 1998. Recovery plan for U.S. Pacific populations 

of the leatherback turtle (Dermochelys coriacea). National Marine Fisheries Service, Silver 

Spring, MD. 

North, Michael R. 1997. Aleutian Tern (Sterna aleutica), The Birds of North America Online (A. 

Poole, Ed.). Ithaca: Cornell Lab of Ornithology; Retrieved from the Birds of North America 

Online: http://bna.birds.cornell.edu/bna/species/291doi:10.2173/bna.291 

Nowacki, GG., M. Shepard, P. Krosse, W. Pawuk, G. Fisher, J. Baichtal, D. Brew, E. Kissinger and 

T. Brock. 2001. Ecological Subsections of Southeast Alaska and Neighboring Areas of 

Canada. USDA Forest Service, Alaska Region, Technical Publication R10-TP-75. October 

2001, 306 pp. 

Piatt, J.F., and P. J. Anderson. 1996. Response of Common Murres to the Exxon Valdez Oil Spill 

and Long-Term Changes in the Gulf of Alaska Marine Ecosystem. American Fisheries Society 

Symposium. 18:720-737. 17 pp. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 43 Appendix E
Reynolds, R. T., R. T. Graham, M. H. Reiser, R. L. Bassett, P. L. Kennedy, D. A. Boyce, G. 

Goodwin, R. Smith and E. L. Fisher. 1992. Management recommendations for the northern 

goshawk in the southwestern United States. Gen. Tech. Rep. RM 217. Ft Collins, CO: USDA, 

Forest service, Rocky Mountain Forest and Range Experimental Station. 90 p. 

Shelden, K.E.W. and D.J. Rugh. 1995. The bowhead whale, Balaena mysticetus: Its historic and 

current status. Mar. Fish. Rev. 57(3-4):1-20. 

Titus, K., C.J. Flatten, and R.E. Lowell. 1994. Northern goshawk ecology and habitat relationships 

on the Tongass National Forest (goshawk nest sites, food habits, morphology, home range and 

habitat data): Final Annual Project Report. USDA Forest Service Contract No. 43-0109-0272. 

Alaska Dept. of Fish and Game, Division of Wildlife Conservation. 69pp. + appendices. 

USDA Forest Service. 2009. Approval of Revised Alaska Region Sensitive Species List. Letter 

from Dennis Bschor, Regional Forester to Forest Supervisors. February 2, 2009. 2 p. 

__________. 2008a. Tongass National Forest Land and Resource Management Plan. Forest Service, 

R10-MB-603c. 

__________. 2008b. Tongass Land and Resource Management Plan, Final Environmental Impact 

Statement, Plan Amendment. Forest Service, R10-MB-603c. 

__________. 2008c. Central Kupreanof Timber Harvest Draft Environmental Impact Statement 

(DEIS). Vol. A. December 2008. 

USDI Fish and Wildlife Service. 2007a. Endangered, threatened, proposed, candidate, and delisted 

species in Alaska, April 2007. From http://alaska.fws.gov/fisheries/endangered/listing.htm. 2 

pp. 

__________. 2009a. Personal communication between Amanda Williams (USFS) and Steve 

Brockmann (FWS) for informal Section 7 Consultation, reference number: 71440-2009-SL0026; 13 February 2009. 

__________. 2009b. Yellow-billed loon (Gavia adamsii). March 2009. From 

http://alaska.fws.gov/fisheries/endangered/pdf/ybl_factsheet.pdf. 

___________. 2007b. The Steller's eider. From 

http://alaska.fws.gov/fisheries/endangered/listing.htm. 2 pp. 

___________. 2006a. The Eskimo curlew. From 

http://alaska.fws.gov/fisheries/endangered/listing.htm. 2 pp. 

__________. 2006b. The polar bear. From http://alaska.fws.gov/fisheries/endangered/listing.htm. 3 

pp. 

__________. 2006c. Alaska Seabird Information Series. Kittlitz’s murrelet. Anchorage, Alaska. 

Pp. 67-68. 2 pp. 

__________. 2005. Recovery outline for the Southwest Alaska distinct population segment of the 

44 ▪ Appendix E Central Kupreanof Timber Harvest FEIS Appendix E
Northern sea otter (Enhydra lutris kenyoni). October 2005. From 

http://alaska.fws.gov/fisheries/endangered/listing.htm. 13 pp. 

__________. 2002. Candidate and listing priority assignment form. Brachyramphus brevirostris. 

September 2002. Ecological Services, Anchorage Field Office. 

__________. 2001. Short-tailed albatross. From 

http://ecos.fws.gov/speciesProfile/SpeciesReport.do?spcode=B00Y. 2 pp. 

__________. 1999. The spectacled eider. From 

http://alaska.fws.gov/fisheries/endangered/listing.htm. 2 pp.

van Vilet, G. 1993. Status concerns for the “Global” population of Kittlitz’s Murrelet: Is the 

“Glacier Murrelet” receding? Pacific Seabird Group Bulletin 20(1):15-16. 2 pp. 

Central Kupreanof Timber Harvest FEIS Appendix E ▪ 45 Appendix E
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