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SD11.R23
Kuiu Timber
Sale Area
Final Environmental
Impact Statement
CATALOGING PREP
U.S.D.A., NAL
NOV 0 « 2007
USDA
United States
Department of
Agriculture
Forest Service
Tongass
National
Forest
R10-MB-604
July 2007
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, 1997, as amended
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
NEPA Economic Analysis Tool
NEPA
National Environmental Policy Act
NFMA
National Forest Management Act
NIC
Non-interchangeable Component
OGR
Old-growth Habitat Reserve
RMA
Riparian Management Area
RMO
Road Management Objective
ROS
Recreation Opportunity Spectrum
SEIS
Supplemental Environmental Impact Statement
TTRA
Tongass Timber Reform Act
VCU
Value Comparison Unit
VQO
Visual Quality Objective
WAA
Wildlife Analysis Area
United States
USDA Department of
Forest
Service
Alaska Region
Tongass National Forest
648 Mission Street
Ketchikan, AK 99901
Phone: (907) 225-3101
Fax: (907)228-6215
Agriculture
File Code: 2410
Date: July 16, 2007
Dear Reader,
Enclosed is your copy of the Final Environmental Impact Statement (FEIS) for the Kuiu Timber
Sale Area. This FEIS is being released at this time without an accompanying Record of Decision
(ROD) in view of the settlement agreement between the parties in the Natural Resources Defense
Council V. U.S. Forest Service; Southeast Alaska Conservation Council v. U.S. Forest Service;
and Organized Village of Kake v. U.S. Forest Service. This settlement was filed in the U.S.
District Court on May 1 8, 2007. In it, the Forest Service agreed to postpone any decision for
timber sales on Kuiu Island until at least 30 days after publication in the Federal Register of the
Notice of Availability of the Final Environmental Impact Statement for the Tongass Forest Plan
review process. The amended Forest Plan, FEIS and ROD are scheduled for release sometime in
September, 2007.
The Tongass Forest Plan Amendment was begun after the Kuiu Project was initiated, and the
current revised Forest Plan (1997) allows for the activities in the Kuiu Project Area to take place.
Depending on the outcome of the current Annendment Record of Decision, a decision on the
Kuiu Project may or may not be applicable, as the Land Use Designations (LUDs) of the area
may be changed. LUDs identify what can and can not take place relative to various management
activities across the Tongass National Forest.
The FEIS will be reviewed for consistency with the new Forest Plan Amendment decision. Any
portions of this project will be adjusted as necessary to comply with the management direction in
that decision.
In response to concerns and corrections noted in both public comments to the Draft
Environmental Impact Statement (DEIS) and internal reviews, the FEIS reflects several changes
from the DEIS. Note that one alternative in the Kuiu Timber Sale Area FEIS does not directly
affect any inventoried roadless areas. The complete list of changes may be found in Chapter 2 of
the FEIS. Noteworthy changes include:
• Reclassification of 6.5 miles of temporary road construction to new National Forest
System (NFS) roads
• Decrease in the maximum total miles of new road construction, from 19 miles
maximum to 10.4 miles maximum
• Reduced acreage under consideration due to resource concerns, resulting in revised
timber volume estimates
Caring for the Land and Serving People
Printed on Recycled Paper
updated timber sale economics analysis, using a different economic model and revised
parameters
A Notice of Availability will be published in the Federal Register for the Kuiu Timber Sale Area
FEIS, initiating the 30-day notice period as required in CFR 1506.10 (b). Again, a ROD for this
project will not be issued until at least 30 days after the publication of the Notice of Availability
in the Federal Register for the Tongass Forest Plan Amendment FEIS and decision.
If you would like further information or additional copies of the FEIS, please contact Tiffany
Benna, District NEPA Coordinator at (907) 772-3871.
Sincerely,
Kuiu Timber Sale
Area
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 Tiffany Benna, Planning Team Leader
Information Contact: Tongass National Forest
P.O. Box 1328
Petersburg, Alaska 99833
(907) 772-3871
Abstract: The Tongass National Forest proposes to harvest timber and
build associated temporary roads in the Kuiu Timber Sale
Area on Kuiu Island. This EIS examines one no-action
alternative and four action alternatives with a range of
harvest levels from approximately 9.6 to 33.3 million board
feet (mmbf) of timber. Alternatives consider both clearcut
harvest and partial harvest methods. One alternative includes
some helicopter yarding. All alternatives include the choice
of two log transfer facilities (LTF), one of which would
require reconstmction. All action alternatives include
reducing the number of miles of open road in the Project
Area. Options for the location, size and habitat composition
of three small old-growth habitat reserves are considered.
Summary
Background
The Forest Plan embodies the provisions of the National Forest
Management Act (NFMA), its implementing regulations, and other
guiding documents. The Forest Plan sets forth in detail the direction
for managing the land and resources of the Tongass National Forest,
and this EIS tiers to the 1997 Forest Plan and 1993 Forest Plan SEIS.
The process of remedying the shortcomings identified by the Ninth
Circuit Court of Appeals is in progress with a Eorest Plan Amendment
DEIS released in January 2007. The current revised Forest Plan allows
for the activities in the Kuiu Project Area to take place. Delaying
planning and analysis regarding road building and timber harvest, even
for a short time period, have a significant effect on the amount of
timber available for sale in the next year, due to the time needed for
sale preparation, appraisal and advertisement and to account for the
time period when sale areas are typically inaccessible (winter months).
Delayed project analyses affect other projects “in line” for
consideration, creating impacts to the entire sale program several years
into the future. Delayed project analyses also diminish the Forest
Service’s ability to respond to the on-going timber demand since the
analyses are time-consuming. The Kuiu project includes consideration
of an alternative that does not directly affect roadless areas. The Kuiu
FEIS will be reviewed for consistency with the Forest Plan
Amendment decision following the procedures in the Forest Service
Handbook FSH 1909.15 Section 18. Any portions of this project will
be adjusted as necessary to be consistent with the management
direction in the Forest Plan Amendment decision.
Project Area
The Kuiu Timber Sale Area (Project Area) is located on north Kuiu
Island, on the Petersburg Ranger District, 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).
Proposed Action
The Proposed Action for the Project Area (Alternative 4) is for the sale
and harvest of approximately 33.3 million board feet (mmbf) of
Kuiu Timber Sale Area
Summary • 1
FEIS Summary
sawlog and utility volume from 1,387 acres of National Forest System
land. This harvest would require about 3.9 miles of temporary road
construction, and 6.5 miles of NFS road construction. The logs would
be hauled by truck to existing log transfer facilities (LTFs) at Rowan
Bay or Saginaw Bay for shipment. Timber from this project would be
offered through the Tongass National Forest timber sale program.
The Proposed Action includes adjusting the boundary of three small
old-growth habitat reserves (OCRs) in or adjacent to the Project Area
to meet Forest Plan criteria. The proposed adjustments would result in
changes to the size of the OCRs (see Chapter 3, Wildlife). Any
proposed OGR adjustments would require a non-significant
amendment to the Forest Plan.
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 Project
Area in accordance with Forest Plan goals, objectives, and desired
conditions. The decision may include:
• The location, design, scheduling, amount, and method of timber
harvest, NFS and temporary road construction and closure, LTFs,
and silvicultural practices,
• Any necessary project-specific mitigation measures and
monitoring requirements,
• A determination of whether there may be a significant possibility
of a significant restriction on subsistence uses, and
• Whether any changes in the small OCRs in VCUs 398, 399, or 402
should be made and approved as a non-significant amendment to
the Forest Plan.
Purpose and Need
The project would achieve goals and objectives described in the Forest
Plan, and help realize desired conditions described in that plan. Forest-
wide goals and objectives (Forest Plan, pp. 2-3 and 2-4) that this
proposed action would achieve include the following;
• Provide for a vigorous and healthy forest environment, including
management of the timber resource for production of saw timber
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 • Summary
Kuiu Timber Sale FEIS
FEIS Summary
• Ensure that the small OGR system criteria meets the minimum
size, spacing, and composition,
• Provide diverse opportunities for resource uses that contribute to
the local and regional economies of Southeast Alaska, supporting a
wide range of natural-resource employment opportunities within
Southeast Alaska’s communities.
Public Involvement
The following is a summary of the public involvement activities for
the Kuiu Time Sale.
• The project has been included in the Tongass National Forest
Timber Sale Plan since 2004 and was first placed on the Spring
2004 Schedule of Proposed Actions (SOPA).
• Comments made during the 2005 Kuiu Landscape Assessment
scoping and open house events were considered.
• Public scoping began in February 2004.
• Open houses that included information about the Kuiu Timber Sale
were held in Petersburg in March 2004, December 2004, and June
2005. Open houses were held in Kake in June and November of
2004.
• A Notice of Intent to Prepare an Environmental Impact Statement
was published in the Federal Register on August 9, 2004. On
September 14, 2004, a revised Notice of Intent was published.
• A subsistence hearing for the Kuiu Timber Sale Area was held in
Petersburg, Alaska on March 16, 2006 at the Petersburg City
Council Chambers. Another subsistence hearing was held in Kake,
Alaska at the Organized Village of Kake office on March 21, 2006.
Changes Made Between the Draft EIS
and the Final EIS
• Reclassified up to 6.5 miles of temporary road construction as new
National Forest System (NFS) roads based on a re-evaluation of
the Project Area’s long-term management needs.
• Due to a calculation error in the DEIS, total miles of new NFS and
temporary road construction decreased from a maximum of 1 9
miles to a maximum of 10.4 miles in the FEIS.
• Due to soil stability analyses, unit boundaries were revised in Units
101, 207, 303 and 305 to avoid unstable slopes.
Kuiu Timber Sale FEIS
Summary • 3
FEIS Summary
• Acres were dropped in Units 204 and 208b to form a buffer
between these two units to ensure no opening would exceed 100
acres.
• Issue 2 was refined to be more responsive to public comments.
• Timber volume estimates were revised based on reduced acreage.
• The timber sale economics analysis was updated due to 1 ) the use
of NEAT_R (Version 2.10) which uses the residual value appraisal
method and 2) the allowance of interstate shipping.
• In response to the allowance of interstate shipping, helicopter
economic mitigations that left all trees less than 16 inches diameter
at breast height (DBH) and western hemlock greater than 36 inches
DBH were dropped.
• In accordance with the settlement agreement between NRDC vs
US Forest Service, the Crane and Rowan Mountain Timber Sales
ROD was withdrawn. This withdrawal occurred after the analysis
for the FEIS was complete; therefore, where appropriate, the
unharvested Crane and Rowan units are included as reasonably
foreseeable activities in the cumulative analyses.
• Additional information was added, where appropriate, as requested
through comments on the Draft FIS.
Significant Issues
Significant issues are used to formulate and design alternatives,
prescribe mitigation measures, and analyze significant effects.
Significant issues for the Kuiu Timber Sale have been identified
through public and internal scoping. Similar issues are combined
where appropriate.
The Forest Supervisor determined four significant issues within the
scope of the Kuiu Timber Sale decision. These issues are addressed
through the proposed action and the alternatives and are as follows:
• Issue 1- Inventoried Roadless Areas,
• Issue 2-Deer Habitat and Subsistence Use,
• Issue 3-Timber Harvest Economics, and
• Issue 4-Cumulative Watershed Effects.
Issue 1 relates to timber harvest and the related construction of new
roads to facilitate timber harvest in roadless areas or in the smaller
unroaded areas (Figure 3-1).
4 • Summary
Kuiu Timber Sale FEIS
FEIS Summary
Alternative 1
Issue 2 relates to cumulative effects on deer habitat and connectivity
from past, present, and proposed activities, and the resulting effects on
subsistence uses.
Issue 3 relates to the economic viability of the proposed timber sale or
sales. It also relates to the potential employment and the revenue
generated for communities in the area. If proposed timber harvest
alternatives are not designed to be economically viable across
fluctuating market conditions, there is concern that the forest products
industry in Southeast Alaska cannot remain viable.
Watersheds within the Project Area have high value for fisheries. Two
of the watersheds within the Project Area exceed 20 percent
cumulative harvest within the last 30 years.
Small OCRs
The small OCRs mapped in the Forest Plan FEIS have been evaluated
for size, spacing, and habitat composition. An interagency review by
biologists from the USDA Forest Service, Alaska Department of Fish
and Game (ADF&G), and the U.S. Fish and Wildlife Service
(USFWS) determined that alternative small OGRs within VCUs 398,
399, and 402 would better meet the requirements for size,
connectivity, and acres of productive old-growth habitat. The review
team recommended that the boundaries of the existing small OGRs be
adjusted. All action alternatives would require a non-significant Forest
Plan Amendment to adopt these recommendations.
The modified interagency OGR for VCU 398 would be approximately
2,305 acres, compared to 2,237 acres identified in the Forest Plan.
The modified interagency OGR for VCU 399 would be approximately
4,159 acres, compared to 2,628 acres identified in the Forest Plan.
The modified interagency OGR for VCU 402 would be approximately
5,273 acres, compared to 4,044 acres identified in the Forest Plan.
Alternatives Considered in Detail
The No- Action (Alternative 1), Proposed Action (Alternative 4) and
three other action alternatives were considered in detail. Figures 2-1
through 2-5 display the five alternatives. Tables 2-1 and 2-2 compare
the proposed activities and effects of the alternatives.
Alternative 1 proposes no timber harvest, road construction, changes
to road management objectives, changes to small Old-growth Reserves
(OGRs), or other activities within the Project Area at this time. It
represents the existing condition of the Project Area, and does not
preclude future timber harvest or other activities from this area.
Kuiu Timber Sale FEIS
Summary • 5
FEIS Summary
Alternative 2
Alternative 3
Alternative 2 was developed to minimize impacts to wildlife and
watersheds, and to have no direct effects to inventoried roadless areas
or unroaded areas. The proposed timber harvest would result in the
production of approximately 9.6 million board feet (mmbf) of timber
from approximately 477 acres. Only ground-based logging systems
would be used. The amount of trees remaining in a unit after harvest
would vary from zero to fifty percent of the stand’s pre-harvest basal
area.
To provide stand structure for wildlife habitat, approximately 50
percent of the stand basal area would be retained where operationally
feasible. Harvest units in the Recreational River Land Use Designation
(LUD) would retain 50 percent of the stand basal area to maintain
scenic values. Logs would be transported to an existing Logging
Transfer Facility (LTF) in either Saginaw Bay or Rowan Bay.
Approximately 1.8 miles of NFS road and 1.5 miles of temporary road
construction would be necessary for timber harvest. Road construction
would not cross any Class I or II fish streams in this alternative.
Additionally, approximately 4.1 miles of roads currently closed (Roads
6417, 6443, 46091, and 46094) would be opened and reconditioned to
access timber. This would require the installation of three crossing
structures on Class I streams, and three crossing structures on Class II
streams. Road construction and reconditioning would require
placement of one crossing structure on a Class III stream, and five
crossing structures on Class IV streams.
After timber harvest activities are complete, all new and reconditioned
NFS roads would be closed and all temporary roads would be
decommissioned. In addition, approximately 7.8 miles of currently
open roads that would be used to access timber for this project would
be closed to motorized traffic and placed in storage (Roads 6413,
46021, and 46096).
Included in Alternative 2, the boundaries of three small OCRs (in
VCUs 398, 399, and 402) were adjusted by an interagency group of
biologists to meet Forest Plan criteria.
Alternative 3 was developed by modifying Alternatives 2 and 4 to
reduce impacts to resources such as wildlife, hydrology, and fisheries
while providing a larger economic return. The proposed timber harvest
would result in the production of approximately 15.9 mmbf of timber
from approximately 786 acres. Only ground-based logging systems
would be used. The amount of trees remaining in a unit after harvest
would vary from zero to fifty percent of the stand’s pre-harvest basal
area.
To provide stand structure for wildlife habitat, approximately 50
percent of the stand basal area would be retained where operationally
6 • Summary
Kuiu Timber Sale FEIS
FEIS Summary
Alternative 4
Proposed
Action
feasible. Logs would be transported to existing LTFs in either
Saginaw Bay or Rowan Bay.
Approximately 5.4 miles of NFS road and 2.1 miles of temporary road
construction would be necessary for timber harvest. One bridge would
be placed across a Class II fish stream on NFS Road 46030 to reduce
potential impacts to fish. About 3.0 miles of roads currently in storage
would be reconditioned to access timber (Roads 6417, 46091, and
46094). The opening of these roads would require the installation of
two crossing structures on Class I streams and three crossing structures
on Class II streams. Road construction and reconditioning would
require placement of eight crossing structures on Class III streams, and
19 crossing structures on Class IV streams.
After timber harvest activities are complete, all new and reopened NFS
roads would be closed and all temporary roads would be
decommissioned In addition, approximately 8 miles of currently open
roads that would be used to access timber for this project would be
closed to motorized traffic (Roads 6413, 6418, and 46096).
Included in Alternative 3, the boundaries of three small OCRs (in
VCUs 398, 399, and 402) were adjusted by an interagency group of
biologists to meet Forest Plan criteria.
The Proposed Action for the Kuiu Timber Sale would result in the
production of approximately 33.3 mmbf of timber from approximately
1,387 acres. A mix of ground-based and helicopter logging systems
would be used. Helicopter logging would be used to access units on
steeper ground. Helicopter use reduces the need for road construction
and allows a more selective harvest on steeper slopes. The amount of
trees remaining in a unit after harvest would vary from zero to fifty
percent of the stand’s pre-harvest basal area.
To provide stand structure for wildlife habitat, approximately 50
percent of the stand basal area would be retained where operationally
feasible. Harvested units in the Recreational River LUD would retain
50 percent of the stand’s basal area for scenic values. Where helicopter
logging is specified, 50 percent of the stand basal area would be left to
improve economics. Logs would be transported to existing LTFs in
either Saginaw Bay or Rowan Bay.
Approximately 6.5 miles of NFS road and 3.9 miles of temporary road
construction would be necessary for timber harvest. Road construction
would require the installation of two crossing structures across Class II
fish streams. Additionally, 6. 1 miles of roads currently closed would
be reconditioned to access timber (Roads 6417, 6422, 6443, 46091,
and a portion of 6427). This would require the installation of three
crossing structures on Class I streams, and three crossing structures on
Class II streams. Road construction and reconditioning would require
Kuiu Timber Sale FEIS
Summary • 7
FEIS Summary
Alternative 5
placement of 14 crossing structures on Class III streams, and 19
crossing structures on Class IV streams.
After timber harvest activities are complete, all new and reconditioned
NFS roads would be closed and all temporary roads would be
decommissioned. In addition, after timber harvest is complete, 10.5
miles of roads that are currently open and would be used to access
timber for this project would be closed to motorized traffic (Roads
6413, 6418, 46021, 46096, and a portion of 6427).
Included in Alternative 4, the boundaries of three small OCRs (in
veils 398, 399, and 402) were adjusted by an interagency group of
biologists to meet Forest Plan criteria.
Alternative 5 proposes even-aged management with clearcut
harvesting of timber to increase the economic return. The proposed
timber harvest would result in the production of approximately 3 1 .4
mmbf of timber from approximately 1,208 acres. Only ground-based
logging systems would be used. Logs would be transported to existing
LTFs in either Saginaw Bay or Rowan Bay.
Approximately 6.5 miles of NFS road and 3.5 miles of temporary road
construction would be necessary for timber harvest. Road construction
would require the installation of two crossing structures across Class II
fish streams. Additionally, 6.1 miles of roads currently closed would
be reconditioned to access timber (Roads 6417, 6422, 6443, 46091,
46094, and a portion of 6427). This would require the installation of
three crossing structures on Class I streams, and three crossing
structures on Class II streams. Road construction and reconditioning
would require placement of 15 crossing structures on Class III streams,
and 19 crossing structures on Class IV streams.
After timber harvest activities are complete, all new and reconditioned
NFS roads would be closed and all temporary roads would be
decommissioned. In addition, after timber harvest is complete, 10.5
miles of currently open roads that would be used to access timber for
this project would be closed to motorized traffic (Roads 6413, 6418,
46021, 46096, and a portion of 6427).
Included in Alternative 5, the boundaries of three small OCRs (in
VeUs 398, 399, and 402) were adjusted by an interagency group of
biologists to meet Forest Plan criteria.
Design Criteria Common to All Action
Alternatives
All alternatives, including the Proposed Action, are consistent with the
Tongass Land and Resource Management Plan. All applicable Forest
8 • Summary
Kuiu Timber Sale FEIS
FEIS Summary
Plan Standards and Guidelines have been incorporated into the design
of the proposed units and alternatives. Additional direction comes
from applicable laws and Forest Service Manuals and Handbooks.
Site-specific descriptions and resource considerations for each
potential harvest unit are included as Unit Cards in Appendix B. These
Unit Cards serve as the prescription or design narrative for the project.
Design elements for NFS roads are also described in detail in
Appendix B.
Kuiu Timber Sale FEIS
Summary • 9
FEIS Summary
Table S-1 . Proposed activities by alternative for the Kuiu Timber Sale Area
Proposed Activity
Alternative
1
2
3
4
5
Acres of Timber Harvested by Treatment
Even-aged
Management
Clearcut
0
197
409
1,025
1,208
Uneven-aged
Management
Single tree selection - 50%
basal area retention
0
87
72
193
0
Group selection - 50% basal
area retention
0
19
19
41
0
Two-aged
Management
Clearcut with reserves - 50%
area retention
0
175
286
128
0
Total Acres
0
478
786
1,387
1,208
Acres of timber harvest by logging system
Cable
0
395
751
1,092
1,059
Shovel
0
83
35
147
149
Helicopter
0
0
0
148
0
Miles of road maintenance/reconditioning/construction
Maintenance: miles of open NFS roads after harvest
56.2
48.0
47.8
45.2
45.2
Reconditioned: existing NFS roads (closed after harvest)
0
4.1
3.0
6.1
6.8
New Construction: NFS road (closed after harvest)
0
1.8
5.4
6.5
6.5
New Construction: temporary roads (decommissioned
after harvest)
0
1.5
2.1
3.9
3.5
Miles of road closure
NFS Roads (Maintenance Level 2 or above)
0
7.8
8.0
10.5
10.5
10 • Summary
Kuiu Timber Sale FEIS
FEIS Summary
Table S-2. Comparison of alternatives by issue and effects
Units of Measure
Alt1
Alt 2
Alts
Alt 4
Alts
Issue 1 - Roadless Areas
Acres harvested within Inventoried
Roadless Area (IRA)
0
0
67
207
114
Miles of NFS roads constructed within
IRA
0
0
0.06
0.33
0.33
Miles of temporary roads constructed
within IRA
0
0
0.12
0.13
0.13
Percent of affected IRA including
zones of influence (600’ for harvest,
1,200’ for roads)
0
0
3%
6%
4%
Change in IRA roadless
characteristics?
No
No
No
No
No
IRA still eligible for Wilderness
designation?
Yes
Yes
Yes
Yes
Yes
Acres harvested within unroaded
areas
0
0
68
167
167
Miles of NFS roads constructed in
unroaded areas
0
0
0.55
0.55
0.55
Miles of temporary roads constructed
within unroaded areas
0
0
0.09
0.3
0.3
Issue 2 - Deer Habitat and Subsistence Use
Acres of POG maintained within the
WAA
90,586
90,379
89,800
89,199
89,648
Acres of important deer winter range
(HSI = 0.60 - 1 .0) remaining after
harvest in WAA 5012
21,971
21,843
21,841
21,660
21,725
Subsistence
Implementations of any action alternative for this project, in
combination with past and reasonably foreseeable future
timber harvest, will not likely result in a significant restriction
on subsistence use of resources. However the Forest Plan
predicts that by completing the harvest schedules at the end
of the rotation (2095) there may be possible future restrictions
for subsistence hunting for deer.
Kuiu Timber Sale FEIS
Summary • 1 1
FEIS Summary
Table S-2. Comparison of alternatives by issue and effects (continued)
Units of Measure
Altl
Alt 2
Alts
Alt 4 Alt 5
Issue 3 - Timber Harvest Economics
Amount of volume (mbf)
0
9,617
15,859 1 33,300
31,354
Indicated bid ($/mbf) to Rowan Bay LTF
0
($157.99)
($179.99)
($155.11)
($141.28)
Indicated bid ($/mbf) to Saginaw Bay LTF
0
($136.27)
($158.94)
($136.71)
(126.92)
Total Logging Costs per mbf (including
road costs) to Rowan Bay LTF
0
$397.10
$417.05
$393.10
$378.35
Total Logging Costs per mbf (including
road costs) to Saginaw Bay LTF
0
$375.38
$396.00
$374.70
$361.28
Road costs per mbf (construction and
reconstruction) to Rowan Bay LTF
0
$59.94
$79.52
$49.28
$54.09
Road costs per mbf (construction and
reconstruction) to Saginaw Bay LTF
0
$59.94
$79.52
$49.28
$54.09
Issue 4 - Cumulative Watershed Harvest Since 1977
Acres of extreme risk hazard (MMI-4) soils
in units
0
0
0
14
18
Cumulative timber harvest acres - % of
Dean Creek Watershed (WS)
24.0
24.0
24.0
26.7
26.7
Cumulative timber harvest acres - % of
Saginaw Creek Watershed (WS)
8.2
9.4
12.4
13.3
12.2
Cumulative timber harvest acres - % of WS
#109-45-10090
18.8
19.9
18.8
23.4
23.4
Cumulative timber harvest acres - % of WS
#109-44-10370
8.3
10.8
10.6
10.8
10.8
Cumulative timber harvest acres - % of
Security Creek
22.5
23.3
24.4
25.2
25.2
Cumulative timber harvest acres - % of
Kadake Creek Watershed
17.3
17.7
17.8
18.2
17.9
12 • Summary
Kuiu Timber Sale FEIS
FEIS Summary
Table S-2. Comparison of alternatives by issue and effects (continued)
Units of Measure
Alt 1
Alt 2
Alt 3
Alt 4
Alts
Other Environmental Considerations
Effects on TES Species
Activities may impact individual goshawks but would not result in
a trend toward listing. No effect for other species.
Effects on Wildlife
Project Area open road density (mi/mi^)
0.78
0.67
0.66
0.63
0.63
WAA 5012 open road density (mi/mi^)
0.46
0.42
0.42
0.41
0.41
Acres of high value marten habitat (HSI >
0.89) after harvest in WAA 5012
51,614
51,211
50,984
50,438
50,676
Acres of coarse canopy old-growth that
would remain after harvest in the WAA
22,956
22,738
22,629
22,172
22,415
Acres low elevation / high value wildlife
(POG below 800 feet) that would remain
after harvest in the WAA
22,956
22,637
22,547
21,913
22,259
Effects on Water Quality
Number of Class 1 stream crossings on
closed roads and proposed temporary
roads
0
3
2
3
3
Number of Class II stream crossings on
closed roads and proposed temporary
roads
0
3
4
5
5
Number of Class III stream crossings on
closed roads and proposed temporary
roads
0
1
8
14
15
Number of Class IV stream crossings on
closed roads and proposed temporary
roads
0
5
19
19
19
Miles of temporary road construction
0
1.5
2.1
3.9
3.5
Miles of currently open roads placed in
storage (structures removed and roads
waterbarred)
0
8.2
8.4
11.0
11.0
Effects on Recreation
None
Effects on Scenery
Acres harvested in Recreational River
LUD
0
18
0
49
0
Effects on Heritage Resources
None
Effects on Land Status
None
Kuiu Timber Sale FEIS
Summary • 13
FEIS Summary
This page left blank intentionally.
14 • Summary
Kuiu Timber Sale FEiS
Table of Contents
Chapter 1 Purpose and Need
1.1 Introduction 1-1
1.2 Proposed Action 1-1
1 .3 Purpose and Need 1-2
1.4 Decisions to be Made 1-2
1.5 Management Direction 1-4
1.6 Description of the Project Area 1-9
1.7 Public Involvement 1-9
1.8 Consultation 1-11
1.9 Significant Issues 1-13
1.10 Other Issues and Concerns 1-16
1.11 Federal and State Permits, Lieenses, and Certifications 1-18
1.12 Applicable Laws and Executive Orders 1-19
Chapter 2 Alternatives
2.1 Introduction 2-1
2.2 Changes Made Between the Draft EIS and Final EIS 2-2
2.3 Alternatives Considered In Detail 2-2
2.4 Design Criteria Common to All Action Alternatives 2-5
2.5 Comparison of Alternatives 2-10
2.6 Identification of the Preferred Alternative 2-14
2.7 Alternatives Considered but Eliminated From Detailed Study 2-17
2.8 Mitigation 2-17
2.9 Monitoring 2-17
Chapter 3 Environment and Effects
3.1 Introduction 3-1
3.2 Issue 1 - Roadless Areas 3-7
3.3 Issue 2 - Deer Habitat and Subsistence Use 3-24
3.4 Issue 3 - Timber Sale Economics 3-56
3.5 Issue 4 Cumulative Effects of Logging and Rd Construction on Watersheds 3-69
3.6 Alaska Region Threatened, Endangered, Candidate, and Sensitive Species 3-100
3.7 Wildlife 3-107
3.8 Timber and Vegetation Resources 3-138
3.9 Fisheries 3-151
3.10 Soils and Geology 3-164
3.11 Wetlands 3-176
3.12 Transportation 3-181
3.13 Scenery 3-194
3.14 Recreation 3-207
3.15 Socioeconomics 3-214
3.16 Heritage Resourees 3-219
Kuiu Timber Sale FEIS
Table of Contents • i
Contents
3. 17 Non-National Forest System Lands and Uses 3-224
3.18 Findings and Disclosures 3-223
Chapter 4 References and Lists
Glossary 4-1
References 4-19
List of Preparers 4-26
List of FEIS Recipients 4-28
Index for Chapter 1 4-33
Index for Chapter 2 4-35
Index for Chapter 3 4-37
Appendix A Reasons for Scheduling the Environmental Analysis of
the Kuiu Timber Sale Project Area
Introduction A-1
Why is Timber from the Tongass National Forest Being Offered for Sale? A-2
How Does the Forest Service Develop Forecasts about Future Timber Market Demand? A-6
What Steps Must Be Completed to Prepare a Sale for Offer? A-9
How Does the Forest Service Maintain an Orderly and Predictable Timber Sale Program? A- 10
How Does the Forest Service Decide Where Timber Harvest Projects should be Located? A- 14
Conclusion A- 19
References A-20
Appendix B Activity Cards
Introduction to Appendix B B-1
Unit Card Header Information B-1
Harvest Treatments B-2
Resource Concerns and Responses B-4
Unit Cards B-1 1
Road Cards B-95
Road Management Objectives B-97
Appendix C Agency Responses to Public Comments on the Kuiu
Timber Sale Area Draft Environmental Impact Statement
List of Tables
Chapter 1
Table 1-1. Forest Plan Land Use Designations on Kuiu Island 1-7
Chapter 2
Table 2-1. Proposed activities by Alternative for the Kuiu Timber Sale Area 2-9
Table 2-2. Comparison of alternatives by issue and effects 2-14
ii • Table of Contents
Kuiu Timber Sale FEIS
Contents
Chapter 3
Table 3-1. Kuiu Island Inventoried Roadless Areas 3-9
Table 3-2. Acres of Inventoried Roadless Area within the Project Area 3-9
Table 3-3. North Kuiu Roadless Area LUDs 3-10
Table 3-4. Effects on the North Kuiu Roadless Area by Alternative 3-12
Table 3-5. Indirect Effects on the North Kuiu Roadless Area by Alternative, including Zones of Influence
of harvest and road construction 3-13
Table 3-6. Roadless Area Values as identified in the Forest Plan SEIS (2003)... 3-14
Table 3-7. Direct Effects on Area 1 (Southern Unroaded Area 2,412 acres) by Alternative 3-20
Table 3-8. Direct Effects on Area 2 (Middle Unroaded Area 3,302 acres) by Alternative 3-21
Table 3-9. Indirect Effects on Area 1 (Southern Unroaded Area 2,412 acres) by Alternative 3-22
Table 3-10. Indirect Effects on Area 2 (Middle Unroaded Area 3,302 acres) by Alternative 3-22
Table 3-11. Historic and current POG acres within WAA 5012 and the Project Area 3-26
Table 3-12. Effects of the proposed alternatives on POG habitata within the Project Area (acres remaining
after harvest) 3-26
Table 3-13. Acres of High Volume POG below 800 feet Harvested within the Project Area 3-27
Table 3-14. WAA 5012 deer habitat suitability indices - historic (1954), current (2006), and future
(2046) condition 3-30
Table 3-15. Direct effects of harvest on important deer winter range in WAA 5012 by Alternative 3-31
Table 3-16. Subsistence harvest of important game species on Kuiu Island 3-48
Table 3-17. Deer habitat capability (deer/mi^) for WAA 5012 by Alternative 3-50
Table 3-18. Suitable and available productive forest land strata and volume estimates for the Kuiu Project
Area 3-59
Table 3-19. NEAT R logging costs by Alternative for haul to Rowan Bay LTF 3-60
Table 3-20. NEAT_R logging costs by Alternative for haul to Saginaw Bay LTF 3-60
Table 3-21. Volume by Alternative and expected bid to Rowan Bay and Saginaw Bay LTFs 3-61
Table 3-22. Acres of harvest prescriptions by Alternative 3-61
Table 3-23. Acres of proposed timber harvest by yarding system 3-62
Table 3-24. Logging and Milling Related Employment and Income 3-64
Table 3-25. Components of the Watershed Analysis 3-70
Table 3-26. Interpretation of the Sediment Risk Index (SRI) 3-72
Table 3-27. Interpretation of Percentile Ranking for Flood Plain (FP) Stream Channel Characteristics 3-73
Table 3-28. Watersheds within the Project Area, Cumulative Harvest since 1977 and Existing Roads
(National Forest System and Temporary Roads) 3-74
Table 3-29. Changes to the SRI in Watersheds in the Project Area 3-74
Table 3-30. Stream Channel Condition: Dean Creek 3-75
Table 3-31. Stream Channel Condition: East Fork Saginaw Creek 3-76
Table 3-32. Stream Channel Condition: West Fork Saginaw Creek 3-77
Table 3-33. Stream Channel Condition: ADF&G stream # 109-45-10090 3-78
Table 3-34. Stream Channel Condition: Security Creek 3-79
Table 3-35. Stream Channel Condition: Main Stem Kadake Creek 3-81
Table 3-36. Current Sediment Risk Index (SRI) in Project Area Watersheds, and SRI after Accounting for
Proposed Timber Harvest and Road Construction 3-86
Table 3-37. Summary of timber harvest and road building proposed in Alternative 2, and associated
changes in cumulative harvest levels 3-88
Table 3-38. Summary of timber harvest and road building proposed in Alternative 3, and associated
changes in cumulative harvest levels 3-91
Table 3-39. Summary of timber harvest and road building proposed in Alternative 4, and associated
changes in cumulative harvest levels 3-92
Kuiu Timber Sale FEIS
Table of Contents • iii
Contents
Tabic 3-40. Summary of timber harvest and road building proposed in Alternative 5, and associated
changes in cumulative harvest levels 3-94
Table 3-41. Federally listed threatened, endangered, and candidate wildlife species, and Alaska Region
sensitive wildlife species potential habitat within the Kuiu Timber Sale Project Area 3-101
Table 3-42. Current Alaska Region sensitive plant species known or suspected to occur on Petersburg
Ranger District 3-104
Table 3-43. Small old-growth habitat reserve options for VCU 398 3-109
Table 3-44. Small old-growth habitat reserve options for VCU 399 3-1 10
Table 3-45. Small old-growth habitat reserve options for VCU 402 3-1 15
Table 3-46. Management Indicator Species 3-117
Table 3-47. High value marten habitat (HSl > 0.89) in WAA 5012 remaining after harvest by
Alternative 3-118
Table 3-48. Open road density in WAA 5012 3-122
Table 3-49. Habitat Capability Changes for Sitka Black-tailed Deer 3-123
Table 3-50. Acres of coarse canopy (Volume Class 6 and 7) harvested by Alternative and proportions of
coarse canopy within the Project Area 3-132
Table 3-51. Species composition of forest lands in the Kuiu Timber Sale Area 3-139
Table 3-52. Timber volume (mbf) and species composition proposed for harvest by Alternative 3-139
Table 3-53. Volume strata in the Kuiu Timber Sale Area 3-141
Table 3-54. Volume strata acres harvested by Alternative 3-142
Table 3-55. Acres of silvicultural prescriptions by Alternative 3-145
Table 3-56. Cumulative acres of timber harvest by Alternative 3-150
Table 3-57. Existing and proposed stream crossings needing structures by stream class and
Alternative 3-155
Table 3-58. Proposed fish stream structure removal 3-156
Table 3-59. Landslide studies by Swanston and Marion (1991) and Landwehr ( 1998 unpub.) 3-166
Table 3-60. Acres previously harvested in the Kuiu Timber Sale Area by MMl Class 3-167
Table 3-61. Inventory of landslides within the Project Area 3-168
Table 3-62. Acres of detrimental soil disturbance from harvest and temporary road construction by
Alternative 3-172
Table 3-63. Acres of MMI in proposed units by Alternative 3-173
Table 3-64. Miles of NFS and temporary road by Alternative and MMI class 3-174
Table 3-65. Acres of wetlands previously harvested and proposed for harvest within the Kuiu Timber Sale
Area by Altemative 3-178
Table 3-66. Proposed temporary road miles crossing wetlands 3-179
Table 3-67. Existing National Forest System Roads in the Project Area 3-185
Table 3-68. Current and proposed open road density in the Project Area 3-186
Table 3-69. Existing and proposed miles of open and closed NFS road and miles of proposed temporary
road construction in the Project Area 3-187
Table 3-70. Existing NFS road miles that would closed after timber harvest 3-188
Table 3-71. Acres of harvest in distance zones by Alternative 3-196
Table 3-72. Project Area acres by Existing Visual Condition 3-197
Table 3-73. Project Area acres by Forest Plan adopted visual quality objective 3-198
Table 3-74. Percentage of Allowable Visual Disturbance by VCU and Altemative 3-206
Table 3-75. Existing Recreation Opportunity Spectmm (ROS) Classes within the Kuiu Timber Sale
Area 3-207
Table 3-76. Recreation Opportunity Spectmm (ROS) class acres in the Kuiu Timber Sale Area 3-208
Appendix A
Table A-1. Projected Tongass National Forest Timber Harvest - in Million Board Feet
(MMBF) A-8
iv • Table of Contents
Kuiu Timber Sale FEIS
Contents
Table A-2. Accomplishments in Gate System and Timber Pools (MMBF) A-13
Table A-3. Timber Volume Involved in Appeals and/or Litigation A- 14
Table A-4. Annual Distribution of Forest Plan Allowable Sale Quantity (mmbf) by
District A- 16
Appendix B
Table B-1. Channel Types in or adjacent to proposed harvest units B-8
Table B-2. Stream Value Classes B-8
Table B-3. Stream classes, species of concern, and construction timing windows for
stream crossings on designated roads proposed for reconstruction B-99
Appendix C
Table C-1. Letters received from Agencies, Organizations, and Individuals C-2
List of Figures
Figure 1-1. Vicinity Map of Kuiu Timber Sale 1-3
Figure 1-2. Land Use Designation Map of Kuiu Timber Sale 1-8
Figure 2-1. Alternative 1 No Action 2-19
Figure 2-2. Alternative 2 2-21
Figure 2-3. Alternative 3 2-23
Figure 2-4. Alternative 4 Proposed Action 2-25
Figure 2-5. Alternative 5 2-27
Figure 3- 1 . Roadless Areas and Unroaded Areas 3-16
Figure 3-2. Deer Winter Range (Current Condition) 3-36
Figure 3-3. Deer Winter Range for 2046 3-38
Figure 3-4. Coarse Canopy Forest 3-43
Figure 3-5. Watersheds and Streams 3-96
Figure 3-6. Managed Stands, Roads, Landslides 3-98
Figure 3-7. Kuiu Island Old-growth Habitat Reserves 3-112
Figure 3-8. Small Old-growth Habitat Reserve Options in VCUs 398, 399 and 402 3-114
Figure 3-9. High Value Marten Winter Habitat 3-120
Figure 3-10. MMI-3 and MMI-4 Soils within the Kuiu Timber Sale Area 3-171
Figure 3-11. Adopted Visual Quality Objectives 3-205
Figure 3-12. Area of Potential Effect for Heritage Resources 3-223
Figure A-1. Tongass Timber Harvest, 1998-2006 A-4
Figure A-2. 1997 Forest Plan Timber Resource Suitability Analysis A- 15
Figure B-1. Unit Pool B-9
Figure B-2. Proposed Road Maintenance Levels B-101
Kuiu Timber Sale FEIS
Table of Contents • v
Contents
List of Charts
Chart 3-1. Change of cumulative harvest levels in the Project Area over 30 years for
Alternative 1, the No-Action Alternative. This calculation accounts for unharvested units in
the Crane and Rowan Mountain Timber Sales ROD, but does not account for road
clearings 3-84
Chart 3-2. Change of cumulative harvest levels in the Project Area over 30 years for
Alternative 4, the alternative proposing the highest number of acres for harvest. This
calculation accounts for unharvested units in the Crane and Rowan Mountain Timber Sales
ROD, but does not account for road clearings 3-85
Chart 3-3. Forest Land Classification in the Kuiu Timber Sale Area 3-142
Chart 3-4. Kuiu Timber Sale Area landslide comparison 3-168
vi • Table of Contents
Kuiu Timber Sale FEIS
Chapter 1
Purpose and Need
Chapter 1
Table of Contents
Chapter 1 1
Purpose and Need 1
1.1 Introduction 1
1 .2 Proposed Action 1
1.3 Purpose and Need
1 .4 Decisions to be Made
1.5 Management Direction
1 .6 Description of the Project Area
1.7 Public Involvement
1 .8 Consultation 1 1
1.9 Significant Issues 13
1.10 Other Issues and Concerns 16
1.11 Federal and State Permits, Licenses, and Certifications 18
1.12 Applicable Laws and Executive Orders 19
CM CM ^ CD O)
Chapter 1
Purpose and Need
1.1 Introduction
The Kuiu Timber Sale Area (Project Area) is located on north Kuiu
Island, on the Petersburg Ranger District, 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 Kuiu Timber Sale project
and tiers to the Tongass National Forest Land and Resource
Management Plan (referred to as the Forest Plan in this document). It
includes the steps taken to identify environmental issues and public
concerns related to implementation of the project.
1.2 Proposed Action
A “proposed action” is defined early in the project-level planning
process to briefly describe the project’s actions and magnitude. This
serves as a starting point for the environmental analysis and gives the
public and other agencies specific information to focus comments
upon. Using these comments (see discussion of Significant Issues later
in this chapter), and information from preliminary analysis, the
interdisciplinary team develops alternatives to the proposed action.
These are discussed in detail in Chapter 2.
The Proposed Action for the Project Area (Alternative 4) is for the sale
and harvest of approximately 33.3 million board feet (mmbf) of
sawlog and utility volume from 1,387 acres of National Forest System
land. This harvest would require about 3.9 miles of temporary road
construction, and 6.5 miles of NFS road construction. The logs would
be hauled by truck to existing log transfer facilities (LTFs) at Rowan
Bay or Saginaw Bay for shipment. Timber from this project would be
offered through the Tongass National Forest timber sale program.
The Proposed Action includes adjusting the boundary of three small
old-growth habitat reserves (OCRs) in or adjacent to the Project Area
to meet Forest Plan criteria. The proposed adjustments would result in
changes to the size of the OCRs (see Chapter 3, Wildlife). Any
Kuiu Timber Sale FEIS
Chapter 1 • 1
Purpose and Need
proposed OGR adjustments would require a non-significant
amendment to the Forest Plan.
1.3 Purpose and Need
The project would achieve goals and objectives described in the Forest
Plan, and help realize desired conditions described in that plan. Forest-
wide goals and objectives (Forest Plan, pp. 2-3 and 2-4) that this
proposed action would achieve include the following:
• Provide for a vigorous and healthy forest environment, including
management of the timber resource for production of saw timber
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,
• Ensure that the small OGR system criteria meets the minimum
size, spacing, and composition,
• Provide diverse opportunities for resource uses that contribute to
the local and regional economies of Southeast Alaska, supporting a
wide range of natural-resource employment opportunities within
Southeast Alaska’s communities.
Appendix A provides information on how this project relates to the
overall Tongass timber sale program, and why the project is being
scheduled at this time.
1.4 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 Project
Area in accordance with Forest Plan goals, objectives, and desired
conditions. The decision may include:
• The location, design, scheduling, amount, and method of timber
harvest, NFS and temporary road construction and closure, LTFs,
and silvicultural practices,
• Any necessary project-specific mitigation measures and
monitoring requirements,
• A determination of whether there may be a significant possibility
of a significant restriction on subsistence uses, and
• Whether any changes in the small OGRs in VCUs 398, 399, or 402
should be made and approved as a non-significant amendment to
the Forest Plan.
2 • Chapter 1
Kuiu Timber Sale FEIS
Legend
Non-National Forest
Lakes/Salt Water
500ft Contour Interval
Figure 1-1
Vicinity Map of Kuiu Timber Sale
Petersburg Ranger District
Tongass National Forest
Area of Detail
Security
Bay
Washington
Bay
Kadake
Kake
Kuiu Project Area Boundary
Existing Roads
0
2.5
■ Miles
5
u;/workspace/kuiu_roaded/feis/plots/feis_plots/f1_1rightmargin.mxd 07-09-07 EP
Purpose and Need
1.5 Management Direction
1.5.1 Forest
Plan Land Use
Designations
The Kuiu Timber Sale EIS is a project-level analysis. The scope of the
analysis is confined to the Project Area, and when appropriate, areas
adjacent to the sale area. The analysis addresses the significant issues
and environmental consequences of the proposed action and its
alternatives. While it does not attempt to address decisions made at
higher levels of planning, it does implement direction provided at
those higher levels.
The Forest Plan embodies the provisions of the National Forest
Management Act (NFMA), its implementing regulations, and other
guiding documents. The Forest Plan sets forth in detail the direction
for managing the land and resources of the Tongass National Forest,
and this FIS tiers to the 1997 Forest Plan and 1993 Forest Plan SFIS.
The process of remedying the shortcomings identified by the Ninth
Circuit Court of Appeals is in progress with a Forest Plan Amendment
DFIS released in January 2007. The current revised Forest Plan allows
for the activities in the Kuiu Project Area to take place. Delaying
planning and analysis regarding road building and timber harvest, even
for a short time period, have a significant effect on the amount of
timber available for sale in the next year, due to the time needed for
sale preparation, appraisal and advertisement and to account for the
time period when sale areas are typically inaccessible (winter months).
Delayed project analyses affect other projects “in line” for
consideration, creating impacts to the entire sale program several years
into the future. Delayed project analyses also diminish the Forest
Service’s ability to respond to the on-going timber demand since the
analyses are time-consuming. The Kuiu project includes consideration
of an alternative that does not directly affect roadless areas. The Kuiu
FFIS will be reviewed for consistency with the Forest Plan
Amendment decision following the procedures in the Forest Service
Handbook FSH 1909.15 Section 18. Any portions of this project will
be adjusted as necessary to be consistent with the management
direction in the Forest Plan Amendment decision.
The Forest Plan uses Fand Use Designations (FUDs) to guide the
management of the National Forest System lands on the Tongass
National Forest. Chapter 3 of the Forest Plan contains a detailed
description of each land use designation. The Project Area includes
three of these FUDs - Timber Production, Recreational River, and
Old-growth Habitat Reserve (Table 1-1). Goals, objectives and desired
future conditions of each are summarized below. The locations of each
FUD on Kuiu Island, including the Project Area, are shown on Figure
1-2. Fess than one percent of the lands in the Project Area are non-
National Forest system lands.
4 • Chapter 1
Kuiu Timber Sale FEIS
Purpose and Need
1. 5.1.1 Timber Production LUD (42,905 acres)
Tongass-wide these lands are managed for the production of saw
timber and other wood products on an even-flow, long-term sustained
yield basis. The forested areas are healthy stands with a balanced mix
of age classes. An extensive road system is developed for accessing
timber and subsequently used for recreation, hunting, fishing, and
other public and administrative uses. Roads may be closed, either
seasonally or year-round, to address resource and other needs.
Management activities will generally dominate most seen areas. A
variety of wildlife habitats, predominately in the early and middle
successional stages, is present.
The Timber Production LUD includes areas of beach and estuary
fringe, riparian reserves, high-vulnerability karst. Riparian
Management Areas (RMAs), non-forested areas, and non-productive
forested areas totaling approximately 8,182 acres. These acres are
considered unsuitable for timber production and were removed from
the suitable’ timber base by the Forest Plan. Prior to the signing of the
Forest Plan Record of Decision, approximately 1,739 acres of what is
now considered unsuitable land for timber production had been
harvested. Most of this harvest took place in what are now recognized
as riparian areas, beach fringe areas, and non-development LUDs.
These acres are included in the total acres harvested discussion in the
“Prior Management of the Area” section in this chapter and throughout
the EIS.
Approximately 29,362 acres in the Timber Production LUD are
considered suitable for timber production, and 8,654 of these acres
have been previously harvested. Of the total acres harvested in the
Project Area (approximately 1,739 from unsuitable lands and 8,654
from suitable lands), 4,766 acres have been pre-commercially thinned.
The remaining 5,627 acres are too young and not large enough for
commercial thinning. The second-growth that is on suitable land is not
proposed for harvest at this time.
' Suitable Forest land - Forest land that is producing or is capable of producing crops
of industrial wood and; 1 ) has not been withdrawn by Congress, the Secretary of
Agriculture, or the Chief of the Forest Service; 2) existing technology and
knowledge is available to ensure timber production without irreversible damage to
soils productivity or watershed conditions; 3) existing technology and knowledge, as
reflected in current research and experience, provides reasonable assurance that it is
possible to restock adequately within five years after final harvest, 4) adequate
information is available to project responses to timber management activities, and 5)
where timber harvest is allowed under the Forest Plan.
Kuiu Timber Sale FEIS
Chapter 1 • 5
Purpose and Need
The remaining 20,708 acres of suitable timber in the Project Area
includes land with productive old-growth' timber and is available for
harvest at this time.
1.5.1. 2 Recreational River LUD (1,246 acres)
Recreational River segments are managed to maintain a free-flowing
river resource, while providing for access and use consistent with the
Wild and Scenic Rivers Act and the Alaska National Interest Lands
Conservation Act (ANILCA). Timber harvest is permitted on suitable
lands if adjacent lands are being managed for timber. These
Recreational River lands would also be managed for recreation use and
activities to meet the criteria for a number of social encounters, on-site
developments, methods of access and visitor impacts. Roads are
permitted to access, parallel or cross the river. Visual Quality
Objectives (VQOs) would be applied within the corridor.
In the Project Area approximately 1,246 acres are in the Recreational
River LUD. This LUD maintains the eligibility status of the Kadake
River corridor for the Wild and Scenic River designation.
1.5.1. 3 Old-growth Habitat LUD (1,595 acres)
In the Project Area, there are approximately 1,595 acres in the Old-
growth Habitat LUD. The LUD’s objectives are to provide forest
habitats to maintain viable populations of native and desired non-
native fish and wildlife species that may be closely associated with
old-growth forests. Other objectives are to contribute to the habitat
capability of fish and wildlife resources in order to support sustainable
human uses, and to maintain biological diversity components and
ecological processes associated with old-growth forests.
' Productive Old-growth - old-growth stands capable of producing 20 cubic feet per
acre per year with 8,000 or more board feet of timber per acre
6 • Chapter 1
Kuiu Timber Sale FEIS
Purpose and Need
Table 1- 1. Forest Plan Land Use Designations on Kuiu
Island
Land Use
Designation
(acres)
Kuiu Island
Kuiu Project
Area (acres)
% of project
area in LUD
Non-development LUDs
Wilderness
124,576
0
0
Special
Interest Area
1,094
0
0
Remote
Recreation
42,347
0
0
Old-growth
Habitat
25,171
1,595
3%
Semi-remote
Recreation
106,149
0
0
Wild River
1,807
0
0
Recreational
River
6,585
1,246
3%
Development LUDs
Recreational
River^
6,585
1,246
3%
Modified
Landscape
29,444
0
0
Timber
Production
141,141
42,905
93%
Other
Non-National
Forest System
Land
3,787
356
<1%
1
Recreation LUDs may be considered for development LUDs based on the adjacent lands.
Kuiu Timber Sale FEIS
Chapter 1 • 7
Saginaw
Bay ^
Security
Bay'^-
Legend
“ Kuiu Project Area Boundary
“ “ “ ' WAA 501 2 Boundary
Modified Landscape
I I Non-National Forest
Old-growth Reserve
Remote Recreation
Recreation River
Special Interest Area
Semi-Remote Recreation
Scenic Viewshed
Timber
Wild River
Wilderness
Figure 1-2
Land Use Designation Map of Kuiu Timber Sale
Petersburg Ranger District
Tongass National Forest
I Miles
Washington
Bay
Kake
Kadake ^
Bay .
TV*?
Rowan
Bay
I
Purpose and Need
1.5.2
Non-National
Forest
System
Lands
There are 356 acres of non-National Forest System lands within the
Project Area: two acres of private land, seven acres of Bureau of Land
Management land, and 347 acres of State of Alaska land. Although the
Forest Service does not have authority over these non-national Forest
Service lands, for purposes of this EIS they are considered when
analyzing cumulative effects.
1.6.1
Geographic
Location and
Boundaries
1.6 Description of the Project Area
The Project Area is located on north Kuiu Island, on the Petersburg
Ranger District of the Tongass National Forest in Southeast Alaska,
Townships 57, 58, and 59 South, Ranges 71 and 72 East, Copper River
Meridian. The Project Area includes lands within Value Comparison
Units (VCUs) 399, 400, 402, and 421, an area approximately 46,102
acres (Figure 1-2). VCUs are comparable to large watersheds and
generally follow major topographic divides. The Project Area is
encompassed by National Forest System (NFS) Roads 6402 and 6415
and the peninsula between Security Bay and Saginaw Bay.
The Project Area is located approximately 12 air-miles southwest of
the city of Kake, which is located on Kupreanof Island. Approximately
356 acres of non-national forest system lands are included in the
Project Area. Access to the area is by boat or floatplane.
1.7 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.
The project has been ineluded in the Tongass National Forest Timber
Sale Plan since 2004 and was first placed on the Spring 2004 Schedule
of Proposed Actions (SOPA). This schedule is updated quarterly and
mailed to everyone who requests it, and is available at Ranger District
Kuiu Timber Sale FEIS
Chapter 1 • 9
1
Purpose and Need
1.7.1
Kuiu Island
Landscape
Assessment
Scoping
offices and on the Tongass National Forest website
( www.fs. fed, us/rl OAonsass).
Comments made during the 2005 Kuiu Landseape Assessment seoping
and open house events parallel the Forest Plan’s desired condition for
the Tongass. People want to see a healthy deer population maintained
on the island in perpetuity to meet the needs of subsistenee hunters.
They are concerned about the fragmentation of old-growth habitat and
supportive of the old-growth habitat eonservation strategy.
Publie eomments support a sustainable timber harvest, although
opinions differ on what level of harvest is aeceptable. Publie
eomments eoneerning reereation emphasize maintaining a wide
speetrum of reereation opportunities, from developed to non-
developed. Publie eomments strongly favor proteetion of water quality
as it relates to fish and shellfish habitat beeause of the importance of
aquatie speeies for subsistenee and eommercial uses. Publie opinions
regarding National Forest System roads vary widely, but most people
agree that all open roads should be well maintained to minimize their
environmental effeets and to provide for the eomfort and safety of
users.
Nearby residents in Kake, Point Baker, and Port Proteetion emphasize
the importanee of eonsidering traditional eommunity values and
customs when proposing management aetivities. They express a desire
for balanee between meeting the eeonomie needs of a eommunity and
meeting the eeologieal needs of the landseape.
1.7.2
Project Area
Scoping
1.7.2. 1 Public Mailing
Publie seoping began in February 2004. A newsletter identifying the
Project Area and requesting information on site-specifie eoneems was
mailed to approximately 270 people who: requested to be on projeet
mailing lists, previously expressed interest in timber sale proposals,
and either own property or eonduet business near the Projeet Area. In
addition, the newsletter was mailed to loeal, state, and federal agencies
and federally reeognized tribal governments.
The projeet mailing list is frequently updated to aeeommodate requests
for additions, deletions, and address ehanges.
The Forest Serviee reeeived 28 responses to this mailing. While some
eomments supported the proposed timber sale, most expressed
concerns about additional road construction, uneconomic timber
harvest, disturbanee to wildlife, cleareutting as a harvest method, and
the eumulative effeets of additional harvest on previously harvested
watersheds.
10 • Chapter 1
Kuiu Timber Sale FEIS
Purpose and Need
1.7.3
Notice of
Intent
1. 7.2.2 Open Houses
Open houses that ineluded information about the Kuiu Timber Sale
were held in Petersburg in Mareh 2004, December 2004, and June
2005. Open houses were held in Kake in June and November of 2004.
These open houses were 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. In Kake, flyers were sent to the City Council for posting
prior to the meetings. There is no local paper or radio station in Kake.
A Notice of Intent to Prepare an Environmental Impact Statement was
published in the Federal Register on August 9, 2004. On September
14, 2004, a revised Notice of Intent was published. This Notice briefly
described the proposed action and the purpose and need for the project.
Estimated timelines for the project were given, along with the project
background summary and contact infonnation for those interested in
participating in the planning process.
1.8.1
Consultation
with Other
Government
Agencies
1.8 Consultation
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 agencies 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
Kuiu Timber Sale FEIS
Chapter 1*11
1
Purpose and Need
1.8.2
Consultation
with Federally
Recognized
Tribal
Governments
1.8.3
Availability of
Draft EIS and
Comments to
DEIS
In 1998, in a collaborative process, a Forest Service wildlife biologist
worked with biologists from the U.S. Fish and Wildlife Service
(USFWS), the Alaska Department of Fish and Game (ADF&G), and
the Alaska Department of Environmental Conservation (DEC) to
develop a biologists’ recommended design for placement of the small
old-growth habitat reserves for all of Kuiu Island. In June 2004,
representatives from ADF&G, USFWS, and DEC met with the Kuiu
Interdisciplinary Team (IDT) to further discuss options for
reconfiguring the small OGRs in northern Kuiu Island, including those
in or near the Projeet Area. The following day, the IDT coordinated an
interageney field trip to the Project Area with representatives of
ADF&G, USFWS, and DEC. There was agreement to submit the
proposed small OGR recommendations for VCUs 398, 399, and 402
for analysis in this doeument.
Consultation with federally reeognized tribal governments included
govemment-to-govemment and staff level communications. On
November 22, 2004, several members of the Kuiu Timber Sale
planning team accompanied Patrieia Grantham, Petersburg District
Ranger, to Kake. They met with Henrieh Kadake, Sr., Organized
Village of Kake (OVK) President, and other OVK members, where the
Kuiu Timber Sale was discussed. The Kuiu Timber Sale Heritage
Resourees report was given to the OVK eouneil for review and
comment. The Forest Service also sent letters of consultation and
copies of our heritage resouree report to the Petersburg Indian
Association, Sealaska Corporation, and Tlingit/Haida Central Couneil.
After the Draft EIS was made available to the publie, the
Environmental Protection Agency published the Notice of Availability
of the Draft EIS in the Federal Register on February 2, 2006. Notices
were also published in the Juneau Empire, the official newspaper of
record, and in the Petersburg Pilot. The 45-day public comment period
for the Draft EIS ended on Mareh 20, 2006. Eighteen individual
comment letters were received during the comment period, and are
included in Appendix D. We also received two eleetronie form letters
from two special interest groups, the Wilderness Soeiety (WS) and the
Natural Resouree Defense Council (NRDC). The WS form letter was
received from approximately 12,000 individuals and the NRDC was
received from approximately 64,000 individuals. Responses to these
form letters are ineluded in Appendix D. Key issues from the DEIS
comments inelude: water quality and fish habitat; timber economics;
Forest Plan and legislation regarding NRDC vs U.S. Forest Service;
effects on deer populations and subsistenee users; and soil stability and
the risk of landslides.
12 • Chapter 1
Kuiu Timber Sale FEIS
1.8.4
Comments
Received
During
Subsistence
Hearings
1.8.5
Availability of
the Final EIS
1.8.6
Availability of
the Planning
Record
Purpose and Need I
In accordance with Section 810 of the Alaska National Interest Lands
Conservation Act (ANILCA), a subsistence hearing for the Kuiu
Timber Sale Area was held in Petersburg, Alaska on March 16, 2006
at the Petersburg City Council Chambers. The date, time, and location
of the subsistence hearing were publicized in the local media. Three
people testified at the hearing. Their general concerns focused on the
cumulative effects the proposed project would have on wildlife,
subsistence and watersheds.
Another subsistence hearing was held in Kake, Alaska at the
Organized Village of Kake office on March 21, 2006. This hearing
was delayed about a week due to weather conditions. The date, time,
and location of this hearing were publicized in the local media and
with flyers posted throughout town. One person testified at this
hearing. The testifier’s concerns were about the negative effects the
project could have on subsistence use by Kake residents (specifically
on fish and waterfowl). He was also concerned about increased road
use by hunters and declining bear populations.
The Kuiu Timber Sale Area Final EIS Notice of Availability will be
published in the Federal Register. A public notice will also appear in
the Juneau Empire, the official newspaper of record, and the
Petersburg Pilot.
The planning record for this project includes the Draft EIS, Final EIS,
material incorporated by reference, and all materials produced during
the environmental analysis of this project. The planning record is
available for public review at the Petersburg Ranger District in
Petersburg, Alaska during normal business hours.
1.9 Significant Issues
Significant issues are used to formulate and design alternatives,
prescribe mitigation measures, and analyze significant effects.
Significant issues for the Kuiu Timber Sale 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.
Kuiu Timber Sale FEIS
Chapter 1*13
Purpose and Need
Measures of the signifieance 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.
The Forest Supervisor detemiined four significant issues within the
scope of the Kuiu Timber Sale decision. These issues are addressed
through the proposed action and the alternatives and are as follows:
• Issue 1- Inventoried Roadless Areas,
• Issue 2-Deer Habitat and Subsistence Use,
• Issue 3-Timber Harvest Economics, and
• Issue 4-Cumulative Watershed Effects.
1.9.1
Issue 1 -
Inventoried
Roadless
Areas
Some concerns will be addressed in the same way in all alternatives.
For example, riparian and beach buffer strips will protect fish habitat
from some of the effects of timber harvest in all alternatives. These
measures are described in Chapter 2 in the section titled, “Design
Criteria Common to All Action Alternatives.” They are also discussed
in Chapter 3, Section 3.9 Fisheries.
Issue 1 relates to timber harvest and the related construction of new
roads to facilitate timber harvest in roadless areas or in the smaller
unroaded areas (Figure 3-1). Additional roads and harvest could result
in reducing acres of roadless area in the Project Area, and could affect
roadless values as identified in the 2003 Tongass Land Management
Plan Revision Final Supplemental Environmental Impact Statement -
Roadless Area Evaluation for Wilderness Recommendations (Forest
Plan SEIS).
Nationally, roadless areas are considered to have valuable qualities.
Several comments were received from the public concerning
management of roadless in the Project Area. This analysis examines
the values of two Inventoried Roadless Areas and three smaller
unroaded areas that may be affected by this proposed project.
14 • Chapter 1
Kuiu Timber Sale FEIS
Purpose and Need
1.9.2
Issue 2 - Deer
Habitat and
Subsistence
Use
Units of Measure
To respond to this issue, alternatives will be compared according to
how they affect acres and values of the two inventoried roadless areas
and the three smaller unroaded areas within the Project Area. This
evaluation will display the number of acres of proposed harvest and
miles of road construction within Inventoried Roadless Areas and
unroaded areas. Inventoried Roadless Areas will also be analyzed by
their potential for Wilderness recommendation, and the changes to
existing values as identified in the Forest Plan SEIS.
Issue 2 relates to cumulative effects on deer habitat and connectivity
from past, present, and proposed activities, and the resulting effects on
subsistence uses.
The cumulative reduction of important deer winter range for Sitka
black-tailed deer from past, present, and proposed timber harvest may
have adverse effects on the availability of deer for subsistence and
may result in a significant possibility of a significant restriction to
subsistence hunting. Sitka black-tailed deer are also a Forest Plan
Management Indicator Species (MIS) which represents the habitat
needs of several old-growth wildlife species that require low elevation,
high volume habitat (see Issue 2: Deer Habitat and Subsistence Use, in
Chapter 3).
Most impacts from timber harvest activities occur in Productive Old-
growth Habitats (POG). Timber harvest and road construction could
affect corridors connecting old-growth habitat. Specifically, travel
corridors from low to high elevation habitat could be affected by
proposed activities.
Units of Measure
Effects of timber harvest on Sitka black-tailed deer habitat will be
evaluated by using the deer habitat capability model to measure the
effects of the alternatives on acres of important deer winter range and
potential deer carrying capacity of Wildlife Analysis Area (WAA)
5012, and by comparing model results to historic and current hunting
effort data from ADF&G.
POG and low elevation/high volume POG will be analyzed by
comparing changes in acres between current, proposed, and reasonably
foreseeable future activities in the WAA.
Connectivity will be discussed by looking at the removal of existing
corridors by proposed harvest units and, in particular, corridors linking
high and low elevation habitat.
Kuiu Timber Sale FEIS
Chapter 1*15
1
Purpose and Need
1.9.3
Issue 3 -
Timber
Harvest
Economics
Issue 3 relates to the economic viability of the proposed timber sale or
sales. It also relates to the potential employment and the revenue
generated for communities in the area. If proposed timber harvest
alternatives are not designed to be economically viable across
fluctuating market conditions, there is concern that the forest products
industry in Southeast Alaska cannot remain viable.
1.9.4
Issue 4 -
Cumulative
Watershed
Effects
Units of Measure
Comparison of alternatives for this issue will include the amount
(volume) of timber harvested, the value of the timber to be removed
(stumpage values), the number of direct jobs and estimated direct
income generated (present net value), the logging costs, and the
anticipated contributions to the regional economy.
Watersheds within the Project Area have high value for fisheries. Two
of the watersheds within the Project Area exceed 20 percent
cumulative harvest within the last 30 years. The cumulative effects of
harvest and road construction within the Project Area may affect the
condition of stream channels that drain these watersheds.
Units of Measure
To respond to this issue, alternatives will be compared according to:
acres of proposed cumulative timber harvest within each major
watershed; miles of new NFS and temporary road construction; and
miles of NFS roads to be closed.
The analysis of cumulative watershed effects will also make use of:
the Sediment Risk Index, a tool that integrates stream, soil and
watershed characteristics to facilitate a comparison of the relative
potential for sediment-related changes in stream channels to occur
among a group of watersheds; an analysis of current stream channel
conditions compared to the Tongass Fish Flabitat Objectives; and
projections of watershed recovery rates based on calculations of future
cumulative harvest levels using a 30-year window.
1.10 other Issues and Concerns
Many comments received during the public scoping process concerned
issues that are not considered significant because they are already
addressed through other processes or in the Forest Plan (see Design
Criteria Common to All Action Alternatives, Section 2.4 in Chapter 2),
or their resolution is beyond the scope of this project. As needed,
resource effects related to these concerns are discussed in Chapter 3.
16 • Chapter 1
Kuiu Timber Sale FEIS
1.10.1
Issues Beyond
the Scope of
this EIS
Purpose and Need I
Some comments received during scoping are not specific to the project
or concern decisions that are made at a higher level of planning. These
comments are paraphrased and addressed below.
1.10.1.1 No more logging or road building on National
Forest Lands, the Tongass National Forest and/or Kuiu
Island
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 National Forest Organic
Act provides that National Forests may be established “to improve and
protect the forest within the boundaries of, or for the purposes 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 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.”
This was one of the significant issues raised during the development of
the Forest Plan. During that forest planning process, a wide array of
alternatives was developed and analyses were conducted to estimate
the effects of those alternatives. The selected alternative documented
in the Forest Plan Record of Decision permitted timber harvest to
occur in certain areas on the forest. The majority of the Project Area is
allocated to the Timber Production LUD, where timber harvest is
permitted.
The No-Action Alternative for this EIS responds to this issue by not
proposing timber harvest in the Project Area.
1.10.1.2 Protect all old-growth forests
The guidelines for management of old-growth forests are developed at
the Forest Plan level. During the Forest Plan analysis, various
strategies were analyzed for the protection of old-growth. This resulted
in the forest-wide old-growth habitat reserve system. Other old-growth
forests are protected by riparian, beach, and estuary fringe standards
and guidelines and non-development land use designations. Some old-
growth is designated as available for timber harvest by development
Kuiu Timber Sale FEIS
Chapter 1*17
Purpose and Need
LUDs, such as Timber Production, Scenic Viewshed, and Modified
Landscape.
1.10.1.3 Analyze the impacts of the project on carbon
sequestering
It is cun'ently being addressed with the Forest Plan Amendment.
1.10.1.4 Identify the number of logging Jobs that would be
filled by seasonal, nonresident workers
While this document provides an estimate of the number of jobs
created by each alternative (Issue 3; Timbei Sale Economics in
Chapter 3), it is not possible to prediet with any degree of reliability
the residency of those who would fill the jobs that might be supported
by a particular timber sale.
1.11 Federal and State Permits,
Licenses, and Certifications
To proceed with the activities proposed in this EIS, various permits
from other federal and state agencies may be required. The following
permits have been or will be obtained.
U.S. Army Corps of Engineers
Section 404 of the Clean Water Act (1977, as amended) requires a
permit from the Corps of Engineers before filling or dredging in
wetlands and tidelands. Section 10 of the Rivers and Harbors Act of
1899 requires Corps of Engineers approval for the eonstruction of
structures or work in navigable waters of the United States. This
applies to the existing Rowan Bay and Saginaw Bay LTFs, for which
any reconstruction at Saginaw Bay LTF would require an amendment
to the existing permit. All roads proposed for this project meet the
criteria for a silvicultural exemption from permits required by Section
404.
U.S. Environmental Protection Agency
A Storm Water Discharge Permit and a permit for discharge of bark
and wood debris (Section 402 of the Clean Water Act) has been
obtained. Both of these permits are required for the Rowan Bay and
Saginaw Bay LTFs. The contractor will be responsible for obtaining
the necessary stormwater diseharge permits for log storage and
handling at the LTFs, and for ground disturbing activities on more than
one acre.
18 • Chapter 1
Kuiu Timber Sale FEIS
Purpose and Need
State of Alaska, Department of Natural Resources
Use of the Rowan Bay and Saginaw Bay LTFs requires authorization
for occupancy and use of tidelands and submerged lands from the
Alaska Department of Natural Resources. This pennit has been
obtained.
State of Alaska, Department of Environmental Conservation
A Certification of Compliance with Alaska Water Quality Standards
(Section 401 Certification) has been obtained for the Rowan Bay and
Saginaw Bay LTFs.
1.12 Applicable Laws and Executive
Orders
This section includes a partial list of federal laws and executive orders
pertaining to project-specific planning and environmental analysis on
federal lands. Disclosures and findings required by these laws and
orders are found at the end of Chapter 3.
• Organic Administration Act of 1897 (as amended)
• Rivers and Harbors Act of 1 899
• Migratory Bird Treaty Act of 1 9 1 8 (as amended)
• Bald and Golden Eagle Protection Act of 1940 (as amended)
• Multiple-Use Sustained-Yield Act of 1960
• National Historic Preservation Act of 1966 (as amended)
• Wild and Scenic Rivers Act of 1968, amended 1986
• National Environmental Policy Act (NEPA) of 1969 (as amended)
• Clean Air Act of 1 970 (as amended)
• Alaska Native Claims Settlement Act (ANCSA) of 1971
• Coastal Zone Management Act (CZMA) of 1972 (as amended)
• Marine Mammal Protection Act of 1972
• Endangered Species Act (ESA) of 1973 (as amended)
• Forest and Rangeland Renewable Resources Planning Act (RPA)
of 1974 (as amended)
• National Forest Management Act (NFMA) of 1976 (as amended)
• Clean Water Act of 1977 (as amended)
Kuiu Timber Sale FEIS
Chapter 1*19
Purpose and Need
• American Indian Religious Freedom Act of 1 978
• Alaska National Interest Lands Conservation Act (ANILCA) of
1980
• Archeological Resource Protection Act of 1 980
• Cave Resource Protection Act of 1988
• Native American Graves Protection and Repatriation Act (1990)
• Tongass Timber Reform Act (TTRA) of 1 990
• Magnuson-Stevens Fishery Conservation and Management Act of
1996
• Executive Order 1 1593 (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 (American Indian Sacred Sites)
• Executive Order 13186 (Migratory Bird Treaty)
20 • Chapter 1
Kuiu Timber Sale FEIS
Chapter 2
Alternatives
Chapter 2
Table of Contents
Chapter 2 1
Alternatives 1
2.1 Introduction 1
2.2 Changes Made Between the Draft EIS and Final EIS
2.3 Alternatives Considered In Detail
2.4 Design Criteria Common to All Action Alternatives
2.5 Comparison of Alternatives 10
2.6 Identification of the Preferred Alternative 14
2.7 Alternatives Considered but Eliminated From Detailed Study 17
2.8 Mitigation 17
2.9 Monitoring 17
CM CN LO
Chapter 2
Alternatives
2.1 Introduction
2.1.1
Proposed
Action and
Alternative
Development
This chapter describes and compares the alternatives considered by the
Forest Service for the Kuiu Timber Sale to meet the Purpose and Need and
responds to the significant issues as described in Chapter 1 . 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 and monitoring.
Chapter 2 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 more complete discussion of
the effects used to compare alternatives in Chapter 2 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, three alternatives to the Proposed Action were developed, in
addition to a No- Action Alternative. Other alternatives were considered
but dropped from detailed analysis. The development of the alternatives
led to deferring many potential timber harvest units from further
consideration at this time.
Kuiu Timber Sale FEIS
Chapter 2 • 1
2 Alternatives
2.2 Changes Made Between the Draft EIS
and Final EIS
• Reclassified up to 6.5 miles of temporary road construction as new
National Forest System (NFS) roads based on a re-evaluation of the
Project Area’s long-term management needs.
• Due to a calculation error in the DEIS, total miles of new NFS and
temporary road construction decreased from a maximum of 1 9 miles to
a maximum of 10.4 miles in the FEIS.
• Due to soil stability analyses, unit boundaries were revised in Units
101, 207, 303 and 305 to avoid unstable slopes.
• Acres were dropped in Units 204 and 208b to form a buffer between
these two units to ensure no opening would exceed 100 acres.
• Issue 2 was refined to be more responsive to public comments.
• Timber volume estimates were revised based on reduced acreage.
• The timber sale economics analysis was updated due to 1 ) the use of
NEAT R (Version 2.10) which uses the residual value appraisal
method and 2) the allowance of interstate shipping.
• In response to the allowance of interstate shipping, helicopter
economic mitigations that left all trees less than 1 6 inches diameter at
breast height (DBH) and western hemlock greater than 36 inches DBH
were dropped.
• In accordance with the settlement agreement between NRDC vs US
Forest Service, the Crane and Rowan Mountain Timber Sales ROD
was withdrawn. This withdrawal occurred after the analysis for the
FEIS was complete; therefore, where appropriate, the unharvested
Crane and Rowan units are included as reasonably foreseeable
activities in the cumulative analyses.
• Additional information was added, where appropriate, as requested
through comments on the Draft EIS.
2.3 Alternatives Considered In Detail
2.3.1
Alternative 1
(Figure 2-1)
The No-Action (Alternative 1), Proposed Action (Alternative 4) and three
other action alternatives were considered in detail. Figures 2-1 through 2-5
display the five alternatives. Tables 2-1 and 2-2 compare the proposed
activities and effects of the alternatives.
Alternative 1 proposes no timber harvest, road construction, changes to
road management objectives, changes to small Old-growth Reserves
(OCRs), or other activities within the Project Area at this time. It
2 • Chapter 2
Kuiu Timber Sale FEIS
2.3.2
Alternative 2
(Figure 2-2)
2.3.3
Alternative 3
(Figure 2-3)
Alternatives
represents the existing condition of the Project Area, and does not
preclude future timber harvest or other activities from this area.
Alternative 2 was developed to minimize impacts to wildlife and
watersheds, and to have no direct effects to inventoried roadless areas or
unroaded areas. The proposed timber harvest would result in the
production of approximately 9.6 million board feet (mmbf) of timber from
approximately 477 acres. Only ground-based logging systems would be
used. The amount of trees remaining in a unit after harvest would vary
from zero to fifty percent of the stand’s pre-harvest basal area.
To provide stand structure for wildlife habitat, approximately 50 percent
of the stand basal area would be retained where operationally feasible.
Harvest units in the Recreational River Land Use Designation (LUD)
would retain 50 percent of the stand basal area to maintain scenic values.
Logs would be transported to an existing Logging Transfer Facility (LTF)
in either Saginaw Bay or Rowan Bay.
Approximately 1.8 miles of NFS road and 1.5 miles of temporary road
construction would be necessary for timber harvest. Road construction
would not cross any Class I or II fish streams in this alternative.
Additionally, approximately 4. 1 miles of roads currently closed (Roads
6417, 6443, 46091, and 46094) would be opened and reconditioned to
access timber. This would require the installation of three crossing
structures on Class I streams, and three crossing structures on Class II
streams. Road construction and reconditioning would require placement of
one crossing structure on a Class III stream, and five crossing structures
on Class IV streams.
After timber harvest activities are complete, all new and reconditioned
NFS roads would be closed and all temporary roads would be
decommissioned. In addition, approximately 7.8 miles of currently open
roads that would be used to access timber for this project would be closed
to motorized traffic and placed in storage (Roads 6413, 46021, and
46096).
Included in Alternative 2, the boundaries of three small OCRs (in VCUs
398, 399, and 402) were adjusted by an interageney group of biologists to
meet Forest Plan criteria.
Alternative 3 was developed by modifying Alternatives 2 and 4 to reduce
impacts to resources such as wildlife, hydrology, and fisheries while
providing a larger economic return. The proposed timber harvest would
result in the production of approximately 15.9 mmbf of timber from
approximately 786 acres. Only ground-based logging systems would be
used. The amount of trees remaining in a unit after harvest would vary
from zero to fifty percent of the stand’s pre-harvest basal area.
To provide stand strueture for wildlife habitat, approximately 50 percent
of the stand basal area would be retained where operationally feasible.
Kuiu Timber Sale FEIS
Chapter 2*3
2 Alternatives
Logs would be transported to existing LTFs in either Saginaw Bay or
Rowan Bay.
Approximately 5.4 miles of NFS road and 2.1 miles of temporary road
construetion would be necessary for timber harvest. One bridge would be
placed across a Class II fish stream on NFS Road 46030 to reduce
potential impacts to fish. About 3.0 miles of roads currently in storage
would be reconditioned to access timber (Roads 6417, 46091, and 46094).
The opening of these roads would require the installation of two crossing
structures on Class 1 streams and three crossing structures on Class II
streams. Road construction and reconditioning would require placement of
eight crossing structures on Class III streams, and 19 crossing structures
on Class IV streams.
After timber harvest activities are complete, all new and reopened NFS
roads would be closed and all temporary roads would be decommissioned
In addition, approximately 8 miles of currently open roads that would be
used to access timber for this project would be closed to motorized traffic
(Roads 6413, 6418, and 46096).
Included in Alternative 3, the boundaries of three small OCRs (in VCUs
398, 399, and 402) were adjusted by an interagency group of biologists to
meet Forest Plan criteria.
The Proposed Action for the Kuiu Timber Sale would result in the
production of approximately 33.3 mmbf of timber from approximately
1,387 acres. A mix of ground-based and helicopter logging systems would
be used. Helicopter logging would be used to access units on steeper
ground. Helicopter use reduces the need for road construction and allows a
more selective harvest on steeper slopes. The amount of trees remaining in
a unit after harvest would vary from zero to fifty percent of the stand’s
pre-harvest basal area.
To provide stand structure for wildlife habitat, approximately 50 percent
of the stand basal area would be retained where operationally feasible.
Harvested units in the Recreational River LUD would retain 50 percent of
the stand’s basal area for scenic values. Where helicopter logging is
specified, 50 percent of the stand basal area would be left to improve
economics. Logs would be transported to existing LTFs in either Saginaw
Bay or Rowan Bay.
Approximately 6.5 miles of NFS road and 3.9 miles of temporary road
construction would be necessary for timber harvest. Road construction
would require the installation of two crossing structures across Class II
fish streams. Additionally, 6.1 miles of roads currently closed would be
reconditioned to access timber (Roads 6417, 6422, 6443, 46091, and a
portion of 6427). This would require the installation of three crossing
structures on Class I streams, and three crossing structures on Class II
streams. Road construction and reconditioning would require placement of
Kuiu Timber Sale FEIS
2.3.4
Alternative 4
Proposed
Action
(Figure 2-4)
4 • Chapter 2
2.3.5
Alternative 5
(Figure 2-5)
Alternatives
14 crossing structures on Class III streams, and 19 crossing structures on
Class IV streams.
After timber harvest activities are complete, all new and reconditioned
NFS roads would be closed and all temporary roads would be
decommissioned. In addition, after timber harvest is complete, 10.5 miles
of roads that are currently open and would be used to access timber for
this project would be elosed to motorized traffic (Roads 6413, 6418,
46021, 46096, and a portion of 6427).
Included in Alternative 4, the boundaries of three small OCRs (in VCUs
398, 399, and 402) were adjusted by an interagency group of biologists to
meet Forest Plan criteria.
Alternative 5 proposes even-aged management with clearcut harvesting of
timber to increase the economic return. The proposed timber harvest
would result in the production of approximately 3 1 .4 mmbf of timber from
approximately 1 ,208 acres. Only ground-based logging systems would be
used. Logs would be transported to existing LTFs in either Saginaw Bay
or Rowan Bay.
Approximately 6.5 miles of NFS road and 3.5 miles of temporary road
construction would be necessary for timber harvest. Road construction
would require the installation of two crossing structures across Class II
fish streams. Additionally, 6. 1 miles of roads currently closed would be
reconditioned to access timber (Roads 6417, 6422, 6443, 46091, 46094,
and a portion of 6427). This would require the installation of three
crossing structures on Class I streams, and three crossing structures on
Class II streams. Road construction and reconditioning would require
placement of 15 crossing structures on Class III streams, and 19 crossing
structures on Class IV streams.
After timber harvest aetivities are complete, all new and reconditioned
NFS roads would be elosed and all temporary roads would be
decommissioned. In addition, after timber harvest is complete, 10.5 miles
of currently open roads that would be used to access timber for this project
would be closed to motorized traffic (Roads 6413, 6418, 46021, 46096,
and a portion of 6427).
Included in Alternative 5, the boundaries of three small OCRs (in VCUs
398, 399, and 402) were adjusted by an interagency group of biologists to
meet Forest Plan criteria.
2.4 Design Criteria Common to All Action
Alternatives
All alternatives, including the Proposed Action, are consistent with the
Tongass Land and Resource Management Plan. All applieable Forest Plan
Standards and Guidelines have been incorporated into the design of the
Kuiu Timber Sale FEIS
Chapter 2*5
2 Alternatives
2.4.1
Small Old-
growth
Reserves
2.4.2
Beach and
Estuary Fringe
2.4.3
Fish Habitat
and Water
Quality
proposed units and alternatives. Additional direction comes from
applicable laws and Forest Service Manuals and Handbooks. Site-specific
descriptions and resource considerations for each potential harvest unit are
included as Unit Cards in Appendix B. These Unit Cards serve as the
prescription or design narrative for the project. Design elements for NFS
roads are also described in detail in Appendix B.
The small OCRs mapped in the Forest Plan FEIS have been evaluated for
size, spacing, and habitat composition. An interagency review by
biologists from the USDA Forest Service, Alaska Department of Fish and
Game (ADF&G), and the U.S. Fish and Wildlife Service (USFWS)
determined that alternative small OGRs within VCUs 398, 399, and 402
would better meet the requirements for size, connectivity, and acres of
productive old-growth habitat. The review team recommended that the
boundaries of the existing small OGRs be adjusted. All action alternatives
would require a non-significant Forest Plan Amendment to adopt these
recommendations.
The modified interagency OGR for VCU 398 would be approximately
2,305 acres, compared to 2,237 acres identified in the Forest Plan.
The modified interagency OGR for VCU 399 would be approximately
4,159 acres, compared to 2,628 acres identified in the Forest Plan.
The modified interagency OGR for VCU 402 would be approximately
5,273 acres, compared to 4,044 acres identified in the Forest Plan.
The beach fringe extends 1 ,000 feet inland from mean high tide along all
marine coastlines. The estuary fringe is an area of approximately 1,000
feet slope distance around all identified estuaries. The Forest Plan
classifies the beach and estuary fringe as unsuitable for timber harvest
(Forest Plan p. 4-5). No timber harvest or new roads are proposed at
Saginaw Bay or Security Bay, which are the only beach and estuary
fringes in the Project Area.
Forest Plan Standards and Guidelines for riparian areas are applied to all
fish streams (Class I and II streams) and to non-fish-bearing streams
(Class III and IV streams) within the Project Area. These areas are
delineated according to the process group direction in the Forest-wide
riparian standards and guidelines. This protection exceeds the
requirements of the Tongass Timber Reform Act (TTRA), which
mandates at least a 100-foot buffer zone where no commercial timber
harvest can occur on either side of all Class I streams and on Class II
streams that flow directly into Class I streams. No Riparian Management
Area (RMA) buffers were adjusted for this project, and no timber harvest
is proposed within any RMA for this project. Best Management Practices
(BMPs) would be implemented to minimize the risk of land management
activities impairing water quality on streams that are likely to require
specific protection measures during implementation. Protection measures
may include timing restrictions for in-stream activities, or site-specific
6 • Chapter 2
Kuiu Timber Sale FEIS
2.4.4
Soils
2.4.5
Wetlands
2.4.6
Scenet7
2.4.7
Windthrow
Alternatives
design of stream crossing structures. Any activities that occur on NSF
roads are addressed on the Road Cards in Appendix B.
Site-specific design criteria for road management objectives show the
timing restrictions for in-stream activities such as the replacement of
bridges (see Table B-3 in Appendix B). Timing windows for in-stream
work for roads and/or replacement of bridges would be coordinated with
the Alaska Department of Fish and Game.
All BMPs would be incorporated during sale design and harvest
administration. A National Pollutant Discharge Elimination System permit
has been obtained for the Rowan Bay and Saginaw Bay LTFs. This permit
provides for protection of water quality by eliminating discharge of
surface water directly from the working area to the environment through
the use of settling ponds and a drainage system.
Operators who maintain storage facilities for oil or oil products would take
appropriate preventive measures to ensure that spills do not occur. If a
spill did occur, action would be taken using emergency response materials
to prevent petroleum products from entering any stream or other waters. A
Spill Prevention Control and Countermeasures (SPCC) Plan that meets
applicable EPA requirements would be prepared and maintained. Timber
sale administrators would inspect petroleum storage facilities and the
Purchaser’s plan for spill prevention would ensure prepared emergency
response plans are in place.
Field inspections located a few areas inside proposed timber harvest units
that had slope gradients greater than 72 percent. On-site stability analyses,
documented in the planning record and on Unit Cards, showed which
areas are stable enough for timber harvest to occur. Harvest settings would
be designed to achieve partial or full suspension where needed to
minimize soil disturbance.
New NFS and temporary roads would be located and designed to avoid or
minimize effects to wetlands where possible. Where roads would cross
wetlands, shot rock would be used, and drainage structures would be
designed to ensure that subsurface flow is not restricted.
Proposed harvest units and treatments have been designed and prescribed
to meet Forest Plan adopted visual quality objectives for the applicable
land use designation.
Windthrow concerns within riparian buffers are addressed in the unit card
narratives. Riparian buffers on south facing slopes in units with a
prescription other than uneven-aged management by single tree selection
would be protected by retaining additional trees adjacent to the buffers. In
units with a two-aged, clearcut with reserves or uneven-aged, group
selection prescription, some of the retention would be along the riparian
buffers. In units with uneven-aged, single tree selection prescriptions, the
distribution of trees across the unit would help protect the buffers. In units
Kuiu Timber Sale FEIS
Chapter 2*7
2 Alternatives
2.4.8
Transportation
2.4.8
Rock Quarries
2.4.9
Log Transfer
Facility (LTF)
and Sort Yard
2.4.10
Logging
Camps
with an even-aged preseription, the windthrow prone buffers would be
proteeted by feathering the edge for a distance of 50 horizontal feet where
trees are less than 16 inches DBH. Those trees than cannot be felled away
from the buffer, would be retained.
Roads placed in Maintenance Level 1 (ML 1) for this project would be
open only for authorized activities and would not be open at any time for
public use. A range of options exist to closing roads and meeting ML 1
standards following the timber sale activities. However, the
implementation of BMPs and motorized closure is required for proper
storage with all ML 1 roads to insure appropriate resource protection,
regardless of the methods used to close the road. Given this, the actions
taken to most effectively and efficiently meet BMPs and close roads to
motorized use can vary depending on individual road characteristics. In
limited situations, effectively closing roads to motorized use may require
only a pennanent gate. Most ML 1 road closures, however, will require at
least an adequately sized tank-trap somewhere near the road’s beginning.
Commonly roads require additional deterrents for the first quarter to a half
mile, depending on circumstances. These deterrents are usually provided
by, but not limited to, removing drainage structures such as culverts. Each
road is evaluated for the most effective and efficient closure prior to
project implementation.
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 II stream buffers, old-growth habitat reserves,
eagle and goshawk nest tree buffers and non-developmental LUDs. With
either the expansion of an existing quarry or the development of a new
site, the area footprint would not exceed five acres.
The existing pemiitted LTFs at Rowan Bay and Saginaw Bay may be
used. In addition, an existing sort yard located near the LTF on the
uplands would be used if necessary.
The Saginaw Bay LTF would require reconstruction, but the “footprinf ’ of
the LTF would not change. An existing sort yard located near the LTF on
the uplands would be used if necessary. In addition to the storage area, a
sort yard at the end of Road 6448, approximately one mile from the
Saginaw LTF site is proposed for log sorting prior to storage at the LTF
site. This site would be located at the old logging camp site.
An area for a land-based logging camp at Rowan Bay, about five miles
south of the Project Area, has been in use intennittently since the 1970s
and could be used with the appropriate permits. A floating logging camp
would also require permits. No camp is planned at Saginaw Bay.
8 • Chapter 2
Kuiu Timber Sale FEIS
Alternatives
Table 2-1. Proposed activities by alternative for the Kuiu Timber Sale Area
Proposed Activity
Alternative
1
2
3
4
5
Acres of Timber Harvested by Treatment
Even-aged
Management
Clearcut
0
197
409
1,025
1,208
Uneven-aged
Management
Single tree selection - 50% basal
area retention
0
87
72
193
0
Group selection - 50% basal area
retention
0
19
19
41
0
Two-aged
Management
Clearcut with reserves - 50% area
retention
0
175
286
128
0
Total Acres
0
478
786
1,387
1,208
Acres of timber harvest by logging system
Cable
0
395
751
1,092
1,059
Shovel
0
83
35
147
149
Helicopter
0
0
0
148
0
Miles of road maintenance/reconditioning/construction
Maintenance: miles of open NFS roads after harvest
56.2
48.0
47.8
45.2
45.2
Reconditioned: existing NFS roads (closed after harvest)
0
4.1
3.0
6.1
6.8
New Construction: NFS road (closed after harvest)
0
1.8
5.4
6.5
6.5
New Construction: temporary roads (decommissioned after
harvest)
0
1.5
2.1
3.9
3.5
Miles of road closure
NFS Roads (Maintenance Level 2 or above)
0
7.8
8.0
10.5
10.5
Kuiu Timber Sale FEIS
Chapter 2*9
2 Alternatives
2.5 Comparison of Alternatives
The following discussion focuses on how each alternative responds to
each significant issue. The existing condition will change over time for
some resources even if no proposed activities are implemented. Table 2-2
at the end of this section compares alternatives in tenns of their effects on
each resource analyzed. For a complete discussion of the significant issues
and other environmental considerations, refer to Chapter 3.
This issue relates to timber harvest and the construction of new roads to
facilitate timber harvest in roadless areas or in the smaller unroaded areas
(Figure 3-1). Additional roads and timber harvest could result in reducing
the amount of roadless acreage within the Project Area, and could affect
roadless area values as identified in the Forest Plan SEIS. No alternative
proposes timber harvest or road building in the Security Inventoried
Roadless Area or would indirectly affect this IRA.
Alternatives 1 and 2 are the only alternatives with no proposed timber
harvest or road construction within the North Kuiu Roadless Area.
Alternative 1 does not propose any harvest or road construction within 600
feet of, or roads within 1 ,200 feet of, the edge of the roadless area, referred
to as the zone of influence (refer to the discussion under Issue 1 -
Roadless Areas, Chapter 3). Timber harvest and road construction in
Alternative 2 would slightly affect the zone of influence, extending it into
the roadless area.
Alternatives 3, 4, and 5 propose timber harvest and road construction
within the North Kuiu Roadless Area.
In Alternative 3, approximately 67 acres (8 percent) of the 786 acres
proposed for harvest are in the North Kuiu Roadless Area. About 0.06
mile of new NFS road and 0. 1 3 mile of temporary road construction is
proposed in the roadless area. Alternative 3 would also result in a total of
257 acres removed from the roadless area, including the 600-foot and
1,200-foot buffers.
In Alternative 4, approximately 205 acres (15 percent) of the 1,387 acres
proposed for harvest are in the North Kuiu Roadless Area. About 0.33
mile of new NFS and 0.13 mile of temporary road construction is
proposed in the roadless area. Alternative 4 would result in the greatest
number of acres (551) removed from the roadless area, including the 600-
foot and 1,200-foot buffers.
In Alternative 5, approximately 1 12 acres (9 percent) of the 1,208 acres
proposed for harvest are in the North Kuiu Roadless Area. About 0.33
mile of new NFS and 0. 13 mile of temporary road construction is
proposed in the roadless area. Alternative 5 would also result in a total of
397 acres removed from the roadless area, including the 600-foot and
1,200-foot buffers.
2.6.1
Issue 1 -
Roadless
Areas
10 • Chapter 2
Kuiu Timber Sale FEIS
Alternatives
2.6.2
Issue 2 - Deer
Habitat and
Subsistence
Use
For Alternatives 3, 4, and 5 the overall size of the North Kuiu Roadless
Area would be reduced. However, the area would still be eligible for
inclusion in the National Wilderness Preservation System and the values
identified in the Forest Plan SEIS for roadless areas would be retained.
There are three smaller unroaded areas between 1,000 and 5,000 acres
within the Project Area, totaling approximately 8,723 acres. Alternatives 1
and 2 would not harvest timber or build any roads within these unroaded
areas. Alternative 3 proposes harvest of 68 acres within these areas and
construction of 0.55 mile of new NFS road and 0.09 mile of temporary
road. Alternatives 4 and 5 propose harvest of 1 67 acres and construction
of 0.55 mile of new NFS road and 0.3 mile of temporary road within the
unroaded areas. No timber harvest would occur in unroaded areas less than
1,000 acres in any of the alternatives.
This issue relates to cumulative effects on deer habitat from past, present,
and proposed activities and the potential corresponding effect to
subsistence hunting. It considers the affects on productive old-growth
(POG), on low elevation, high volume POG and travel corridors,
particularly those between high and low elevation habitat.
Alternative 2 would harvest 477 acres of POG, with 280 acres retaining 50
percent of the stand’s pre-harvest basal area. Alternative 3 would harvest
786 acres of POG, with 377 acres retaining 50 percent of the stand’s pre-
harvest basal area. Alternative 4 would harvest 1,402 acres of POG, with
399 acres retaining 50 percent basal area. Alternative 5 would harvest
1,206 acres of POG, clearcutting 100 percent of the acres harvested.
Low elevation productive old-growth has a high value for many wildlife
species. Alternative 2 would harvest 101 acres of low elevation, high
volume POG of which 60 acres would retain 50 percent of the stand’s pre-
harvest basal area. Alternative 3 would harvest 82 acres of low elevation,
high volume POG, of which 57 acres would retain 50 percent of the
stand’s pre-harvest basal area. Alternative 4 would harvest 259 acres of
low elevation, high volume habitat, of which 112 acres would retain 50
percent of the stand’s pre-harvest basal area. Alternative 5 would harvest
156 acres of low elevation, high volume habitat, all of which would be
clearcut.
Subsistence, an Alaska concern and a right protected by law, is a
significant issue. Since 1954, there has been a 39 percent reduction in
important deer winter range (HSI 0.6- 1.0) within WAA 5012. The Project
Area makes up approximately 32 percent of the WAA. At most, the action
alternatives would reduce the important deer winter range within the
WAA from the current condition by one percent. Considering reasonably
foreseeable future harvest, cumulative habitat reductions within the WAA
would still fall between 39 and 40 percent from historic condition. At
present the deer population on Kuiu Island is below carrying capacity. A
Kuiu Timber Sale FEIS
Chapter 2*11
2 Alternatives
slight reduction in habitat should have little impact on deer populations
because there is more habitat available than is currently utilized.
Among the action alternatives, Alternative 2 responds best to meeting
wildlife and subsistence needs because it would retain the most winter
habitat, and affects the fewest wildlife travel corridors. Alternative 5
proposes clearcut harvest and would affect the greatest number of wildlife
travel corridors. Alternatives 4 and 5 would retain the least amount of
winter habitat. Alternative 4, however, would retain more stand structure
with several units retaining 50 percent of the basal stand area, which
would allow more functional habitat and corridors than Alternative 5.
This issue relates to the economic viability of the proposed timber sale or
sales. It also relates to the potential local employment and revenues
generated for local communities. If proposed timber harvest alternatives
are not designed to be economically viable across fluctuating market
conditions, there is a concern that the forest products industry in Southeast
Alaska cannot remain viable.
Timber economics depends on several factors. These factors include:
• The amount of timber harvested,
• The value of the timber harvested, and
• The cost of harvesting the timber.
More timber generally means a higher economic return and more jobs, or
jobs over a longer period of time.
The value of the timber is determined by species composition, the amount
of defect in the wood, and the value of the products that can be obtained
from the wood. Road construction and helicopter logging increase the cost
of timber harvest.
The amount of timber that would be harvested varies from none in
Alternative 1 to 33.3 mmbf in Alternative 4, the Proposed Action.
Alternative 5 proposes the next highest volume with 3 1 .4 mmbf.
Alternatives 2 and 3 propose the lowest volumes for harvest, 9.6 mmbf
and 15.6 mmbf, respectively.
A financial analysis was done using the NEPA Economic Analysis Tool
Residual Value (NEAT_R) developed by the Alaska Region. For this
analysis, it was assumed that all timber volume would be sold at one time.
The analysis showed that all of the action alternatives have a negative
expected bid value. This reflects current economics and may change by
the time the timber sale goes to bid.
All alternatives show a less negative expected bid when the Saginaw Bay
LTF is used rather than the Rowan Bay LTF. This is due to a shorter tow
distance from the Saginaw Bay FTF to the nearest mill.
2.6.3
Issue 3 -
Timber
Harvest
Economics
12 • Chapter 2
Kuiu Timber Sale FEIS
2.6.4
Issue 4 -
Cumulative
Watershed
Effects
Alternatives
If the Rowan Bay LTF is used, Alternative 5 would have the highest
expected bid value of $-14 1.28/mb f. Alternative 4 has the second highest
value at $-155.1 1/mbf, and Alternative 2 is next with $-1 5 7. 99/mb f.
Alternative 3 has the lowest expected bid value of $-179. 99/mb f, due to
the high ratio of partial harvest acres to the miles of temporary and NFS
road construction.
If timber is hauled to the Saginaw Bay LTF, Alternative 5 would have the
highest value of $-126.92/mbf, followed by Alternative 2 with an expected
bid value of $-136.27/mbf. Alternative 4 would have the second lowest
bid of $-136.7 1/mbf and Alternative 3 would have the lowest expected bid
value of $-158.94/mbf.
Direct employment would be the same for all alternatives with 128
expected full time jobs. In March 2007 the Regional Forester approved a
limited interstate shipping policy which authorizes shipment of specified
unprocessed spruce and western hemlock sawlogs to the lower 48 States.
This issue relates to the cumulative effects of timber harvest and
construction of roads in watersheds with previous management,
particularly those watersheds in which over 20 percent of the watershed
area has been harvested within the last 30 years.
Two watersheds are in excess of 20 percent harvested within a 30-year
period, initiating a more intensive analysis in these watersheds.
Alternative 1 would have the least effect on all watersheds in the Project
Area, with no timber harvest or road construction proposed. If Alternative
1 were implemented, the 30-year cumulative harvest levels would be less
than 15 percent in all Project Area watersheds by the year 2010.
Alternatives 2 and 3 would have the same two watersheds as Alternative 1
in excess of 20 percent harvested within a 30-year period. Alternatives 4
and 5 would have three watersheds in excess of 20 percent harvested
within a 30-year period. However, by the year 2010, the cumulative
harvest in all watersheds in all action alternatives would be less than 16
percent.
A sharp decline in the 30-year cumulative harvest levels between years
2001 and 2010 reflects a sharp decline in harvest rates within the Project
Area since the 1960s and 1970s. Therefore, the cumulative watershed
effect shows a general trend toward recovery of slope stability, pre-harvest
rates of canopy interception, and evapotranspiration. Under the action
alternatives the proposed harvest would eause small inereases in the 30-
year harvest levels. However, the overall trend in 30-year cumulative
harvest levels is decreasing.
Kuiu Timber Sale FEIS
Chapter 2*13
2 Alternatives
2.6 Identification of the Preferred
Alternative
In the DEIS, Alternative 4 was identified by the interdisciplinary team as
the PrefeiTed Alternative and approved by the Forest Supervisor. This was
based on the environmental analysis and public and agency comments
received to date. The Forest Supervisor may select this alternative, another
alternative, or a modification of one of the alternatives. The Forest
Supervisor may also select another OGR option from the small OGR
options discussed in the Wildlife section in Chapter 3.
Table 2-2. Comparison of alternatives by issue and effects
Units of Measure
Alt1
Alt 2
Alts
Alt 4
Alts
Issue 1 - Roadless Areas
Acres harvested within Inventoried
Roadless Area (IRA)
0
0
67
207
114
Miles of NFS roads constructed within
IRA
0
0
0.06
0.33
0.33
Miles of temporary roads constructed
within IRA
0
0
0.12
0.13
0.13
Percent of affected IRA including zones of
influence (600’ for harvest, 1 ,200’ for
roads)
0
0
3%
6%
4%
Change in IRA roadless characteristics?
No
No
No
No
No
IRA still eligible for Wilderness
designation?
Yes
Yes
Yes
Yes
Yes
Acres harvested within unroaded areas
0
0
68
167
167
Miles of NFS roads constructed in
unroaded areas
0
0
0.55
0.55
0.55
Miles of temporary roads constructed
within unroaded areas
0
0
0.09
0.3
0.3
Issue 2 - Deer Habitat and Subsistence Use
Acres of POG maintained within the WAA
90,586
90,379
89,800
89,199
89,648
Acres of important deer winter range (HSI
= 0.60 - 1 .0) remaining after harvest in
WAA 5012
21,971
21,843
21,841
21,660
21,725
14 • Chapter 2
Kuiu Timber Sale FEIS
Alternatives
Table 2-2. Comparison of alternatives by issue and effects (continued)
Units of Measure
Altl
Alt 2
Alt 3
Alt 4 Alt 5
Issue 2 - Deer Habitat and Subsistence Use (continued)
Subsistence
Implementations of any action alternative for this project, in
combination with past and reasonably foreseeable future
timber harvest, will not likely result in a significant restriction on
subsistence use of resources. However the Forest Plan
predicts that by completing the harvest schedules at the end of
the rotation (2095) there may be possible future restrictions for
subsistence hunting for deer.
Issue 3 - Timber Harvest Economics
Amount of volume (mbf)
0
9,617
15,859
33,300
31,354
Indicated bid ($/mbf) to Rowan Bay LTF
0
($157.99)
($179.99)
($155.11)
($141.28)
Indicated bid ($/mbf) to Saginaw Bay LTF
0
($136.27)
($158.94)
($136.71)
(126.92)
Total Logging Costs per mbf (including
road costs) to Rowan Bay LTF
0
$397.10
$417.05
$393.10
$378.35
Total Logging Costs per mbf (including
road costs) to Saginaw Bay LTF
0
$375.38
$396.00
$374.70
$361.28
Road costs per mbf (construction and
reconstruction) to Rowan Bay LTF
0
$59.94
$79.52
$49.28
$54.09
Road costs per mbf (construction and
reconstruction) to Saginaw Bay LTF
0
$59.94
$79.52
$49.28
$54.09
Issue 4 - Cumulative Watershed Harvest Since 1977
Acres of extreme risk hazard (MMI-4) soils
in units
0
0
0
14
18
Cumulative timber harvest acres - % of
Dean Creek Watershed (WS)
24.0
24.0
24.0
26.7
26.7
Cumulative timber harvest acres - % of
Saginaw Creek Watershed (WS)
8.2
9.4
12.4
13.3
12.2
Cumulative timber harvest acres - % of WS
#109-45-10090
18.8
19.9
18.8
23.4
23.4
Cumulative timber harvest acres - % of WS
#109-44-10370
8.3
10.8
10.6
10.8
10.8
Cumulative timber harvest acres - % of
Security Creek
22.5
23.3
24.4
25.2
25.2
Kuiu Timber Sale FEIS
Chapter 2*15
2 Alternatives
Table 2-2. Comparison of alternatives by issue and effects (continued)
Units of Measure
Alt 1
Alt 2
Alt 3
Alt 4
Alts
Cumulative timber harvest acres - % of
Rowan Creek Watershed
8.0
9.0
8.8
9.8
10.0
Cumulative timber harvest acres - % of
Kadake Creek Watershed
17.3
17.7
17.8
18.2
17.9
Other Environmental Considerations
Effects on TES Species
Activities may impact individual goshawks but would not result in
a trend toward listing. No effect for other species.
Effects on Wildlife
Project Area open road density (mi/mi^)
0.78
0.67
0.66
0.63
0.63
WAA 5012 open road density (mi/mi^)
0.46
0.42
0.42
0.41
0.41
Acres of high value marten habitat (HSI >
0.89) after harvest in WAA 5012
51,614
51,211
50,984
50,438
50,676
Acres of coarse canopy old-growth that
would remain after harvest in the WAA
22,956
22,738
22,629
22,172
22,415
Acres low elevation / high value wildlife
(POG below 800 feet) that would remain
after harvest in the WAA
22,956
22,637
22,547
21,913
22,259
Effects on Water Quality
Number of Class 1 stream crossings on
closed roads and proposed temporary
roads
0
3
2
3
3
Number of Class II stream crossings on
closed roads and proposed temporary
roads
0
3
4
5
5
Number of Class III stream crossings on
closed roads and proposed temporary
roads
0
1
8
14
15
Number of Class IV stream crossings on
closed roads and proposed temporary
roads
0
5
19
19
19
Miles of temporary road construction
0
1.5
2.1
3.9
3.5
Miles of currently open roads placed in
storage (structures removed and roads
waterbarred)
0
8.2
8.4
11.0
11.0
Effects on Wetlands
Miles of temporary road on wetlands
0
0.01
0.1
0.6
0.6
Effects on Recreation
None
16 • Chapter 2
Kuiu Timber Sale FEIS
Alternatives
Table 2-2. Comparison of alternatives by issue and effects (continued)
Units of Measure
Alt1
Alt 2
Alts
Alt 4
Alts
Effects on Scenery
Acres harvested in Recreational River
LUD
0
18
0
49
0
Effects on Heritage Resources
None
Effects on Land Status
None
2.7.1
Helicopter
logging only
2.7.2
Microsales
2.7 Alternatives Considered but
Eliminated From Detailed Study
Not all alternatives considered during the planning were included in the
EIS for detailed study. The alternative dropped from detailed analysis is
described briefly below with the rationale for not considering it further.
The possibility of developing a helicopter logging only alternative, which
would eliminate the need for additional road construction, was considered
at the request of U.S. Fish and Wildlife Service and other commenters.
Helicopter logging is the most expensive yarding method, and using this
method solely would not allow the cost to be offset by more cost-effective
conventional ground-based systems. Forest Service handbook direction
requires that the least cost methods be used to meet objectives and
mitigate resource concerns. No resource concerns were identified that
precluded road construction activities. Using the NEAT R economic
model and given present market conditions, preliminary economics of
helicopter logging showed that the alternative was cost prohibitive,
therefore was eliminate from detailed study.
Microsales were considered but were dropped because no communities
exist on the island.
2.8 Mitigation
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.
2.9 Monitoring
Monitoring is a tool which involves gathering data and information and
observing the results of management activities as a basis for evaluation.
Kuiu Timber Sale FEIS
Chapter 2 • 17
Alternatives
2.9.1
Forest Plan
Monitoring
2.9.2
Project-
Specific
Monitoring
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
219.1 10). 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 eonsists of annually surveying a
representative sample of harvest units or roads. Any implemented
activities in the Project Area could be incorporated as deseribed in the
Monitoring and Evaluation Guidebook for the Tongass Land and Resource
Management Plan (USDA Forest Service 2000).
Implementation monitoring is conducted at the project level. The selected
management aetivities need to be consistent with the design criteria used
to analyze the environmental effects during the planning stage. This
ensures that the effeets would not change from what was predicted.
2.9.2.1 Implementation Monitoring
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 certifieation verifies that items such as maps, number of acres,
location of units, harvest methods, and stand numbers are consistent. The
certifieation also ensures that all mitigation measures identified in the EIS
relating to timber sale contract requirements are ineluded in the contraet.
Implementation monitoring continues through harvest and contract
inspections. As a routine part of project implementation, sale
administrators and road inspectors monitor harvest and construetion
activities. Through provisions contained in the timber sale contraet or
other contracts, contract administrators and inspectors ensure that the
prescriptions contained on the unit and road eards are implemented. Sale
administrators and road contract inspectors have the authority to initiate
action to repair resouree 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 Contraet
Administrators monitor all units and roads for implementation of the
appropriate BMPs.
18 • Chapter 2
Kuiu Timber Sale FEIS
Purpose and Need
1. 5.1.1 Timber Production LUD (42,905 acres)
Tongass-wide these lands are managed for the production of saw
timber and other wood products on an even-flow, long-term sustained
yield basis. The forested areas are healthy stands with a balanced mix
of age classes. An extensive road system is developed for accessing
timber and subsequently used for recreation, hunting, fishing, and
other public and administrative uses. Roads may be closed, either
seasonally or year-round, to address resource and other needs.
Management activities will generally dominate most seen areas. A
variety of wildlife habitats, predominately in the early and middle
successional stages, is present.
The Timber Production LUD includes areas of beach and estuary
fringe, riparian reserves, high-vulnerability karst. Riparian
Management Areas (RMAs), non-forested areas, and non-productive
forested areas totaling approximately 8,182 acres. These acres are
considered unsuitable for timber production and were removed from
the suitable' timber base by the Forest Plan. Prior to the signing of the
Forest Plan Record of Decision, approximately 1,739 acres of what is
now considered unsuitable land for timber production had been
harvested. Most of this harvest took place in what are now recognized
as riparian areas, beach fringe areas, and non-development LUDs.
These acres are included in the total acres harvested discussion in the
“Prior Management of the Area” section in this chapter and throughout
the EIS.
Approximately 29,362 acres in the Timber Production LUD are
considered suitable for timber production, and 8,654 of these acres
have been previously harvested. Of the total acres harvested in the
Project Area (approximately 1,739 from unsuitable lands and 8,654
from suitable lands), 4,766 acres have been pre-commercially thinned.
The remaining 5,627 acres are too young and not large enough for
commercial thinning. The second-growth that is on suitable land is not
proposed for harvest at this time.
' Suitable Forest land - Forest land that is producing or is capable of producing crops
of industrial wood and; 1) has not been withdrawn by Congress, the Secretary of
Agriculture, or the Chief of the Forest Service; 2) existing technology and
knowledge is available to ensure timber production without irreversible damage to
soils productivity or watershed conditions; 3) existing technology and knowledge, as
reflected in current research and experience, provides reasonable assurance that it is
possible to restock adequately within five years after final harvest, 4) adequate
information is available to project responses to timber management activities, and 5)
where timber harvest is allowed under the Forest Plan.
Kuiu Timber Sale FEIS
Chapter 1*5
Kuiu Timber Sale
Figure 2-1
Alternative 1 No Action
Legend
Productive Old-Growth
Non-National Forest
Managed Stands
Forest Plan OGR
Lakes/Saltwater
Roads in Storage (Closed)
Decommissioned Roads
Existing Open Roads
Project Area Boundary
500ft Contour Interval
Watershed Boundary
Stream Value Class I & II
N
A
0 0.25 0.5 1 1-5 2
M M Miles
Kuiu Timber Sale
Keku Roadless'Area
KeanlKre^
tWatersfieSt
ISaaina wiSr.e'ekM
^Water^hed
,109-45; loom
m^4£imm
lONoftlr KuiulC
s' , I : ' V
’Roadless Area
K^alielSrBeki
BwfeifersfiecfH
S^uritvlKre'eki
k l/l'afe"fteoH
Security Roadless Area,
IhlowanKireeki
MWatersdedM
HUTA
xWV
' jul
pn
1
iM hhi. H/ ' '
\ !
207
Figure 2-2
Alternative 2
Legend
••*••••••••
Clearcut (0% Retention)
50% Retention-Clearcut with Reserves
50% Retention-Group Selection
50% Retention-Single Tree Selection
Productive Old-Growth
OGR Option 2
Managed Stands
Non-National Forest
Roadless Areas
Lakes/Saltwater
500ft Contour Interval
Project Area Boundary
Decommissioned Roads
Roads in Storage (Closed)
Existing Open Roads
Reconditioned Roads
Proposed Temporary Roads
- Proposed System Roads
-- Watershed Boundary
- Stream Value Class I & II
A
0 0.25 0.5 1
Kuiu Timber Sale
Figure 2-3
Alternative 3
Legend
Clearcut (0% Retention)
50% Retention-Clearcut with Reserves
50% Retention-Group Selection
50% Retention-Single Tree Selection
Productive Old-Growth
OGR Option 2
Managed Stands
Non-National Forest
Roadless Areas
Lakes/Saltwater
500ft Contour Interval
Project Area Boundary
- Decommissioned Roads
Roads in Storage (Closed)
— Existing Open Roads
Reconditioned Roads
Proposed Temporary Roads
Proposed System Roads
Watershed Boundary
Stream Value Class I & II
A
2
Miles
0 0.25 0.5
1.5
[B^n Creek
^^tersfied/.
Keki^Roadless Ar^,
ISaaihawidreeki
' ; WatersHedM
i09-45itffcim
?'maTO^-i?0370j
'Rdadless'Area'
KaclakelSreeki
^WatersHedM
WiWate“nedM
S^urity Roadless Area
■RowanWnaei^
-WatershedM
mit^*
Kuiu Timber Sale
Figure 2-4
Alternative 4 Proposed Action
Legend
Clearcut (0% Retention)
50% Retention-Clearcut with Reserves
50% Retention-Group Selection
50% Retention-Single Tree Selection
Productive Old-Growth
OGR Option 2
Managed Stands
Non-National Forest
Roadless Areas
Lakes/Saltwater
500ft Contour Interval
Project Area Boundary
Decommissioned Roads
Roads in Storage (Closed)
Existing Open Roads
Reconditioned Roads
Proposed Temporary Roads
Proposed System Roads
Stream Value Class I & II
Watershed Boundary
A
0 0.25 0.5 1
1.5 2
Miles
I
iWat^sheSm
Keku Roadless Area
■pinawieree
&atersneai
■iVatershed
10945^100901
GWatecshe^
^ North Kuiu^
Ro'^less'Area'
*SeconfCTfc'ree/(j
jKadake^r^eM
Security^ Roadless Ar^
feowan|£ree/ci
BViiaterslTeaM
Kuiu Timber Sale
Figure 2-5
Alternative 5
Legend
Clearcut (0% Retention)
Productive Old-Growth
OGR Option 2
Managed Stands
Non-National Forest
Lakes/Saltwater
Roadless Areas
Proposed System Roads
Proposed Temporary Roads
— Project Area Boundary
Reconditioned Roads
Existing Open Roads
Roads in Storage (Closed)
Decommissioned Roads
500ft Contour Interval
Stream Value Class I & II
- Watershed Boundary
0 0.25 0.5 1 1.5
Miles
Chapter 3
Affected
Environment and
Environmental
Consequences
Chapter 3
Table of Contents
Chapter 3 1
Affected Environment and Environmental Consequences 1
3.1 Introduction 1
3.2 Issue 1 - Roadless Areas 7
3.3 Issue 2 - Deer Habitat and Subsistence Use 24
3.4 Issue 3 - Timber Sale Economics 56
3.5 Issue 4 - Cumulative Effects of Logging and Road Construction on
Watersheds 69
3.6 Alaska Region Threatened, Endangered, Candidate, and Sensitive
Species 100
3.7 Wildlife 107
3.8 Timber and Vegetation Resources 138
3.9 Fisheries 151
3.10 Soils and Geology 164
3.11 Wetlands 176
3.12 Transportation 181
3.13 Scenery 194
3.14 Recreation 207
3.15 Socioeconomics 214
3.16 Heritage Resources 219
3.17 Non-National Forest System Lands and Uses 224
3.18 Findings and Disclosures 225
Chapter 3
Affected
Environment and
Environmental
Consequences
3.1 Introduction
This chapter provides information concerning the existing
environment of the Kuiu Timber Sale Area (Project Area), and
potential consequences to that environment as a result of this project. It
also presents the scientifie and analytical basis for the comparison of
alternatives presented in Chapter 2. Each resource potentially affected
by the Proposed Action or other alternatives is described by its current
condition and uses. Findings and disclosures required by policy and
law are included at the end of the chapter.
The chapter begins with a description of the environmental effects on
resources associated with the four significant issues in the Project
Area. Other coneems raised during scoping that are not significant
issues are discussed in sections 3.6 to 3.15 of this chapter. These
include potential effeets (environmental consequences) that are
mitigated in the same way in all alternatives, or resources that are not
significantly affected by any alternative. All effects, including direct,
indirect, and cumulative effects, are disclosed. Effects are quantified
where possible, and qualitative discussions are included. The means by
which potential adverse effects would be reduced or mitigated are
deseribed (Chapter 2 and Appendix B).
The discussions of resources and potential effects use existing
infomiation included in the Forest Plan, other projeet environmental
analyses, project-specific resource reports, agency and scientific
studies, and related information. Where applicable, such information is
briefly summarized and referenced to minimize duplication. The
planning record for the Project Area includes all project-specifie
Kuiu Timber Sale FEIS
Chapter 3 • 1
Environment and Effects
3.1.1
Administrative
and Ecological
Land Divisions
informalion, including resource reports, documentation of field
investigations, and information resulting from publie involvement
efforts. The planning reeord is loeated at the Petersburg Ranger
District Office in Petersburg, Alaska, and is available for review
during regular business hours. Information from the record is available
upon request.
The land area of the Tongass National Forest has been divided in
several different ways to deseribe the different resourees and faeilitate
systematie and eonsistent analysis. These divisions vary by resouree as
the relationship of eaeh resouree to geographie eonditions and zones
varies.
3. 1.1.1 Land Use Designations (LUDs)
The alloeation of land use designations (LUDs), as discussed in
Chapter 1, was aeeomplished with the Forest Plan. Each LUD provides
for a eombination of aetivities, goals and objectives, and uses. There
are three LUDs within the Projeet Area. These are Timber Produetion,
Reereational River, and Old-growth Habitat. The standards and
guidelines for these LUDs were used for unit design and to analyze
effeets on seenery. The LUDs within the Projeet Area are discussed
and displayed in Chapter 1 .
3. 1.1. 2 Watersheds
The spatial analysis area for the assessment of all direet, indirect, and
cumulative effeets to watershed resources in the Projeet Area ineludes
the entire Dean Creek, Saginaw Creek, Security Creek, Rowan Creek
and Kadake Creek watersheds, and unnamed watersheds #109-45-
10090 and #109-44-10370. Other watersheds and portions of
watersheds where no timber harvest is proposed oeeur within the
Project Area. Cumulative effects were also eonsidered for these
watersheds. The watershed boundaries eorrespond to the 6th level
Hydrologie Unit Code (HUC), and all are true watersheds, meaning
that eaeh watershed is well defined by topographie boundaries and all
surfaee water within the watershed drains to a single stream or river.
The watershed boundaries are large enough to allow a eomprehensive
aeeounting of all activities that affeet eurrent and future watershed
conditions, yet small enough to allow the analysis to be sensitive to the
potential effects of the proposed activities (Regional Interageney
Exeeutive Committee 1995).
3. 1.1. 3 Heritage (Area of Potential Effect)
The project’s Area of Potential Effeet (APE) is the geographie area
where timber harvest and road eonstruetion may cause ehanges in the
charaeter or use of historie properties, if any sueh properties exist [36
CFR 800.2(e)]. The APE is defined early in the planning proeess
before identifieation of historic properties actually begins so it may not
2 • Chapter 3
Kuiu Timber Sale FEIS
Introduction
be known whether any historic properties exist within it. The APE
includes all areas where the undertaking may cause changes to land or
structures, or to their uses, whether the changes would be direct or
indirect, beneficial or adverse. A combination of landscape features.
Project Area boundaries, and areas where timber harvest and road
building are proposed were used to help define the APE boundaries
(see Figure 3-12).
3. 1.1. 4 Inventoried Roadless Areas
Inventoried Roadless Areas are undeveloped areas typically exceed
5,000 acres and meet the minimum criteria for Wilderness
consideration under the Wilderness Act. The Project Area includes the
entire North Kuiu Roadless Area and a portion of the Security
Roadless Area.
3.1. 1.5 Value Comparison Units (VCUs)
For the purposes of project-level analysis, the Tongass National Forest
is divided into Value Comparison Units (VCUs). These are distinct
geographic areas, each encompassing a drainage basin containing one
or more large stream systems. The boundaries usually follow major
watersheds. The Project Area includes lands within VCUs 399, 400,
402 and 42 1 on the northern portion of Kuiu Island. VCUs are used to
analyze the size of small OCRs, and scenery, as VCUs are similar in
land area to viewsheds.
3. 1.1. 6 Project Area
The Project Area is located on the Petersburg Ranger District of the
Tongass National Forest in Southeast Alaska, on north Kuiu Island,
approximately 12 air miles southwest of the city of Kake (Kupreanof
Island). More specifically, the Project Area is within Townships 57,
58, and 59 South, Ranges 71 and 72 East, Copper River Meridian and
includes lands within Value Comparison Units (VCUs) 399, 400, 402,
and 421. It is encompassed by National Forest System (NFS) Roads
6402 and 6415 and the peninsula between Security Bay and Saginaw
Bay.
The size of the Project Area is approximately 46,102 acres (Figure 1-
2), 356 acres of which are non-national forest system lands. Access to
the area is by boat or floatplane.
3. 1.1. 7 Wildlife Analysis Areas (WAAs)
Wildlife Analysis Areas (WAAs) are land divisions used by the Alaska
Department of Fish and Game to report community harvests of
selected wildlife species. The Project Area makes up approximately 32
percent of WAA 5012. Some of the wildlife and subsistence analyses
for the Project Area are reported by WAA.
Kuiu Timber Sale FEIS
Chapter 3*3
Environment and Effects
3.1.2
Analyzing
Effects
3. 1.1. 8 Biogeographic Province
Twenty-one ecological subdivisions of Southeast Alaska are identified
by distinct ecological, physiogeographic, 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 and the barriers that distinguish each province.
Effects to wolves were analyzed at this landscape scale.
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), include a number of specific categories 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. They are explained briefly here.
3. 1.2.1 Direct, Indirect, and Cumulative Effects
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, but could have
some effect in the foreseeable future. Cumulative effects result from
incremental effects of actions when added to other past, present, and
reasonably foreseeable future actions, regardless of which agency or
person undertakes such other actions. Cumulative effects can result
from individually minor but collectively significant actions over time.
The Catalog of Events for Kuiu Island lists all past, present, and
foreseeable future activities. It includes known private, federal and
state projects as well as Forest Service activities. Foreseeable future
activities include those projects that have a developed proposed action,
been funded and/or has been cleared through NEPA. Each resource
specialist considered the catalog and included events that were
included in the cumulative effects analysis. These activities are
identified in the cumulative effects section for each resource in this
chapter. The catalog is located in the project planning record at the
Petersburg Ranger District.
3. 1.2.2 Unavoidable Adverse Effects
Implementation of any action alternative may 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 other resources. Many adverse effects
can be reduced, mitigated, or avoided by limiting their extent or
duration. The interdisciplinary procedure used to identify specific
harvest units and roads was designed to eliminate or lessen the
4 • Chapter 3
Kuiu Timber Sale FEIS
Introduction
significant adverse consequences. The application of Forest Plan
Standards and Guidelines, BMPs, project-specific mitigation
measures, and monitoring are intended to limit the extent, severity, and
duration of potential effects. The purpose of this chapter is to discuss
such measures and fully disclose any adverse effects.
3. 1.2.3 Short-term Use and Long-term Productivity
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 (NFMA), all renewable resources
are to be managed in such a way that they are available for future
generations. Timber harvest can be considered a short-term use of a
renewable resource. As a renewable resource, trees can be
reestablished if the long-tenn productivity of the land is maintained.
This long-term productivity is maintained through the application of
the resource protection measures described in Chapter 2, in particular
those applying to the soil and water resources. These protection
measures are also discussed throughout this chapter, in particular for
soils, water quality, biodiversity, and economics.
3. 1.2.4 Irreversible and Irretrievable Commitments
Irreversible commitments are decisions affecting non-renewable
resources such as soils, wetlands, and heritage resources. Such
commitments are considered irreversible because the resource has
deteriorated to the point that renewal can occur only over a geologic
time period, at a great expense, or not at all. The destruction of an
archaeological site is an example of an irreversible commitment. The
implementation of this project is not expected to result in irreversible
effects.
Irretrievable commitments represent opportunities foregone for the
period during which resource use or production cannot be realized.
Such decisions are reversible, but the production opportunities
foregone are irretrievable. For example, the construction of a NFS road
for long-term management is an irretrievable action. The commitment
is irretrievable rather than irreversible, because trees could be
reestablished in this area, but the amount of timber production during
the period of time when the land was used as a road could not be
regained.
Kuiu Timber Sale FEIS
Chapter 3*5
Environment and Effects
3.1.3
Resource
Information on
Geographic
Information
System
3.1.4
Available
Resource
Information
Much of the Tongass National Forest resource data resides in an
eleetronie database formatted for a geographic information system
(GIS). The Forest uses GIS software to assist in the analysis of this
data. GIS data is available in tabular (numerical) format, and as plots
displaying data in map format. For this EIS, all of the maps and most
of the numerical analyses are based on GIS resource data.
GIS data does have limitations. This is especially true when comparing
data layers used for the Forest Plan with project-specific data layers.
The GIS data uses data collected during field reviews. Initially, the
GIS data is obtained by aerial photo interpretation, then areas that
projeet aetivities may affect were field inventoried and the GIS data is
updated where the information is available. GIS data and layers
become part of the project planning record.
There is incomplete knowledge about many of the conditions and
relationships of forest resources and social needs. Forest management
is a complex and developing science. Wildlife population dynamics
and habitat relationships are not completely understood. The
interaction of forest resouree supply with economic and social
conditions and communities is an inexaet science. However, the basic
data and central relationships are suffieiently established in the
respeetive sciences to adequately assess and disclose the possible
adverse environmental consequenees.
6 • Chapter 3
Kuiu Timber Sale FEIS
3.2 Issue 1 - Roadless Areas
3.2.1
Introduction
3.2.2
Background
Inventoried Roadless Areas (roadless areas) were originally identified
during the Roadless Area Review and Evaluation studies (RARE I and
RARE II) conducted in the 1970s. Roadless areas refer to undeveloped
areas typically exceeding 5,000 acres that meet the minimum criteria
for Wilderness consideration under the Wilderness Act.
Roadless areas and their values are issues of national importance.
Many of the comment letters received for the DEIS expressed concern
for harvest and road construction in roadless areas. Most of the letters
were from out of state and were from people who have never visited
the Tongass.
On the Tongass National Forest, many of the biological and social
values of roadless areas were taken into consideration when
determining the LUDs for the Forest Plan. The Project Area includes
all of the North Kuiu Roadless Area and a small portion of the
Security Roadless Area.
Areas meeting the roadless criteria were inventoried during the Forest
Service’s RARE II process, subsequent assessments, or forest
planning. The inventory conducted by the Tongass National Forest and
published in the Tongass Forest Plan Supplemental Environmental
Impact Statement 2003, (Forest Plan SEIS) represents the best and
most recent inventory on the Tongass.
In the evaluation of roadless areas, all Tongass National Forest lands
were assessed to determine if they were suitable for Wilderness as
based on the Wilderness Act and the procedures in the Forest Service
planning directives. Appendix C (SEIS Volumes II and III) includes
documentation of the analysis and evaluation for each Inventoried
Roadless Area and describes the relative contribution each roadless
area would make to the National Wilderness Preservation System. The
Forest Plan SEIS identified and evaluated roadless areas that met
minimum criteria for potential inclusion in the National Wilderness
Preservation System using the Wilderness Attribute Rating System
(WARS). This system was used to inventory the wilderness
characteristics of Inventoried Roadless Areas. The purpose of WARS
was to provide a measure of an area’s wilderness quality, based on the
key attributes of wilderness as defined in the Wilderness Act.
3.2.2. 1 Roadless Analysis in the Forest Plan
During the revision of the Forest Plan, all areas, including roaded and
roadless, were analyzed. The Forest Plan allocates some portions of
roadless areas to Timber Production, Modified Landscape, and Scenic
Viewshed LUDs, all of which allow roads, road construction, and
Kuiu Timber Sale FEIS
Chapter 3*7
Environment and Effects
3.2.3
Current
Condition
timber harvest. Other portions of roadless areas are alloeated to non-
development LUDs. These allocations include Old-growth Habitat,
Remote Recreation, Semi-remote Recreation, Special Interest Areas,
and Recreational River LUDs. About 74 percent of the roadless area in
the Tongass National Forest are included in non-development LUDs.
3.2.2. 2 Roadless Area Conservation Rule
The Roadless Area Conservation Rule (January 12, 2001) has been the
subject of several lawsuits. In the most recent ruling (September 20,
2006), the court re-instituted the rule as it appears in the July 1, 2004
edition of 36 CFR Chapter II, Parts 200 to 299, and includes the text:
"this subpart does not apply to road construction, road reconstruction,
or the cutting, sale or removal of timber in inventoried roadless areas
on the Tongass National Foresf’ (294.14(d)).
3.2. 3.1 Introduction
Most of Southeast Alaska is currently unroaded. About 74 percent of
the roadless areas are within LUDs that would retain their unroaded
condition through the life of the Forest Plan (Forest Plan SEIS Record
of Decision p. 12). There are eight roadless areas on Kuiu Island.
Table 3-1 lists the size of each roadless area along with acres in
Development and Non-development LUDs.
The Forest Plan 2003 inventory identified two roadless areas that
overlap the Project Area (North Kuiu #241 and Security #240). These
two roadless areas are included in the area of analysis along with the
entire sale area. All other roadless areas are outside the area of analysis
because the integrity of those areas would not be affected by any of the
proposed activities. Figure 3-1 shows the location of the roadless areas
on the northern portion of Kuiu Island. The proposed action
alternatives would not make any roadless areas ineligible for
Wilderness designation. However, the size of North Kuiu Roadless
Area may be reduced, as described later in this analysis.
8 • Chapter 3
Kuiu Timber Sale FEIS
Issue 1: Roadless Areas
Table 3-1. Kuiu Island Inventoried Roadless Areas
Roadless Area
Roadless
Area
number
Non-
development
acres^
Acres in
Development
LUDs
Total acres
in Roadless
Area
Keku
239
3,062
8,108
11,170
Security
240
26,104
9,393
35,497
North Kuiu
241
734
8,810
9,544
Camden
242
8,095
32,300
40,395
Rocky Pass’’
243
73,961
5,142
79,103
Bay of Pillars
244
27,782
946
28,728
East Kuiu’’
245
16,711
29,684
46,395
South Kuiu
246
63,063
0
63,063
Total Acres
219,512
94,383
313,895
Forest Plan allocation
Includes acres on both Kuiu Island and Kupreanof Island
Q
Includes some small islands off the coast of Kuiu Island
3. 2. 3. 2 Roadless Areas
All of the North Kuiu Roadless Area, a portion of the Security
Roadless Area, and three smaller unroaded areas lie within the Project
Area (Table 3-2 and Figure 3-1). The Inventoried Roadless Areas are
North Kuiu (#241) and Security (#240). They lie near the existing road
system. Although infrequent, sights and sounds of vehicles traveling
the road system may occur. These noises are temporary and of short
duration.
Table 3-2. Acres of Inventoried Roadless Area within the Project
Area
Roadless Area
Total acres
Roadless Area acres
within Project Area
North Kuiu (#241)
9,544
9,544
Security (#240)
35,497
134
Kuiu Timber Sale FEIS
Chapter 3*9
3 Environment and Effects
3.2. 3.3 Security Roadless Area #240
The Security Roadless Area is located on the northwest side of Kuiu
Island, approximately 15 air miles southwest of Kake and about 50 air
miles west of Petersburg. Chatham Strait lies to the west, Security Bay
to the northeast, and Frederick Sound to the north.
Approximately 134 acres of the Security Roadless Area are within the
Project Area boundary, but there are no proposed or reasonably
foreseeable future activities within this roadless area. Therefore, this
roadless area will not be discussed further. Additional information on
the Security Roadless Area is available in the Roadless Area Analysis
located in the planning record.
3.2. 3.4 North Kuiu Roadless Area #241
The North Kuiu Roadless Area is located near the center of the
northern portion of Kuiu Island. Roads surround the area and provide
access to Rowan Bay (Figure 3-1). Petersburg is approximately 40 air
miles from the roadless area. Kake, the nearest town, is located
approximately 10 air miles away on Kupreanof Island.
Management Direction and Current uses
The majority of this roadless area, 92 percent, was allocated to the
Timber Production LUD. Approximately eight percent of the roadless
area was allocated to non-development LUDs (Table 3-3).
There are no developed recreation sites in the roadless area. Deer
hunting is the primary recreational use. There is some subsistence use
in the area but most is concentrated along the road-accessible areas
outside of the roadless area.
Table 3-3. North Kuiu Roadless Area LUDs
LUD
Acres of LUD in
roadless area
Percent roadless area
Timber Production
8,810
92%
Old-growth Habitat
385
4%
Recreational River
349
4%
Total
9,544
100%
10 * Chapter 3
Kuiu Timber Sale FEIS
Issue 1: Roadless Areas
3.2. 3. 5 Unroaded Areas
In addition to analyzing roadless areas, the Forest Plan SEIS also
identified unroaded areas with fewer than 5,000 acres, but of a size and
configuration sufficient to protect the inherent characteristics
associated with their roadless condition. Unroaded areas do not
overlap with roadless areas and do not meet the minimum size
requirement of 5,000 acres for potential Wilderness consideration.
Unroaded areas are divided into two categories: areas greater than
1,000 acres but less than 5,000 acres in size, and areas less than 1,000
acres in size.
3.2.4
Effects on the
North Kuiu
Roadless Area
The Project Area has three unroaded areas between 1,000 acres and
5,000 acres in size (Figure 3-1).
There are no proposed timber harvest units or roads in any of the
unroaded areas less than 1,000 acres in size within the Project Area;
therefore, these areas will not be analyzed further for this project.
3.2.4.1 Introduction
The Forest Plan SEIS GIS layer reflects the best and most current
information on the Tongass roadless areas and was used for
summarizing the information required for the following analysis.
The units of measure used are a comparison of acres lost by alternative
for the direct effect of harvest or road construction and indirect effects
of incorporating the “zones of influence” to the units and roads (Table
3-4 and 3-5) and the changes in rating to the values as identified in the
Tongass Forest Plan (SEIS 2003) (Table 3-6).
The inventory criteria used for this project is the same used to
delineate roadless areas in the Forest Plan and the Forest Plan SEIS.
The zone of influence includes all areas within 1,200 feet of an
existing road, and 600 feet of an existing harvest unit, and are
considered developed for the purpose of this analysis. Small areas
surrounded by development and long narrow strips of unroaded areas
are also considered developed and are not included in the roadless area
acres. Helicopter units do not receive the 600-foot zone of influence
buffer according to the Forest Plan SEIS (p. 2-5).
Some of the timber harvest units are proposed for partial harvest,
which produces fewer effects than clearcutting. Helicopter logging
further reduces effects because it does not require as much road
building, thereby limiting access to the roadless area.
There are no reasonably foreseeable future activities planned within
the North Kuiu Roadless Area.
Kuiu Timber Sale FEIS
Chapter 3*11
3 Environment and Effects
3.2.4.2 Effects Common to all Alternatives
In all alternatives, the North Kuiu Roadless Area would remain greater
than 9,000 acres in size and would remain eligible for Wilderness
consideration in subsequent forest planning (Tables 3-4 and 3-5).
The values shown in Table 3-6 have been identified as key
characteristics of roadless areas in the National Forest System (Forest
Plan SEIS 2003). The North Kuiu Roadless Area is evaluated using
these national criteria.
Most of the North Kuiu Roadless Area is within one mile of a road.
Logging activities and traffic may be heard from the existing logging
roads surrounding the roadless area and from the eastern boundary of
the Security Roadless Area. These logging roads were present when
roadless areas were analyzed for the Forest Plan Final LIS. Additional
miles of NFS and temporary roads proposed in the action alternatives
would be extensions of the existing road system.
Table 3-4. Effects on the North Kuiu Roadless Area® by alternative
Measure of Effect
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Harvest unit acres in Roadless Area
0
0
67
205
112
Percent of Roadless Area affected
0
0
<1%
2%
1%
Acres'^ of temporary roads in Roadless Area (all would be
closed after harvest)
0
0
0.92
2.23
2.23
North Kuiu Roadless Area acres after harvest
9,544
9,544
9,476
9,337
9,430
This table uses the Forest Plan SEIS Roadless acres.
One mile of road construction (NFS or temporary) equals 4.85 acres.
Timber management activities have occurred on all sides of the North
Kuiu Roadless Area. Total acres of the area would be reduced by
timber harvest and road building in Alternatives 3 through 5; however,
the area is currently influenced by roads and managed stands, therefore
the effect on the overall characteristics and values would be minimal.
The irregular shape of the roadless area, patterns of adjacent timber
management, and roads affect its natural integrity, making it poorly
suited for wilderness classification. There are no special attractions,
features or unique values in this roadless area. It received a Wilderness
Attribute Rating score of 15 out of 28 points (USDA 2003c).
12 • Chapter 3
Kuiu Timber Sale FEIS
Issue 1 : Roadless Areas
Table 3-5. Indirect Effects on the North Kuiu Roadless Area® by alternative, including
Zones of Influence of harvest and road construction
Measure of Effect
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Acres of Roadless Area affected‘s
0
11
257
551
397
Percent of Roadless Area affected
0
0
3%
6%
4%
North Kuiu Roadless Area acres after harvest‘s
9,544
9,533
9,287
8,993
9,147
® This table uses the Forest Plan SEIS Roadless acres.
Total includes 600-foot buffers around proposed timber harvest units and 1,200-foot buffers along proposed NFS and temporary
roads within the roadless areas.
3.2.4.S Comparison of Alternatives
Alternatives 1 and 2 would not directly affect the North Kuiu Roadless
Area. These alternatives do not propose any timber harvest units or
roads within the roadless area. Alternative 1 would not affect the zone
of influence; however, Alternative 2 would affect 1 1 acres due to roads
or timber harvest extending the zone of influence into the roadless
area.
Alternatives 3, 4, and 5 include portions of timber harvest units within
the boundary of the North Kuiu Roadless Area. The direct reduction of
acres due to harvest and road building would vary between 67 acres in
Alternative 3, to 205 acres in Alternative 4. These alternatives include
units that would be located within 600 feet of the roadless area;
therefore, their zones of influence would extend into the edge of the
roadless area. This would indirectly reduce the overall size of the
roadless area by a maximum of 551 acres (Alternative 4).
Of the four action alternatives. Alternative 4 would have the greatest
direct effect on the North Kuiu Roadless Area, with up to 205 acres
harvested from eight units within the roadless area and two units
whose zones of influence would extend into the roadless area. In
addition, 0.33 mile of NFS road and 0.13 mile of temporary road are
proposed within this roadless area. The affected acres represent about
two percent of the North Kuiu Roadless Area.
Kuiu Timber Sale FEIS
Chapter 3*13
Environment and Effects
Table 3-6. Roadless Area Values as identified in the Forest Plan SEIS (2003)
Value
Status Identified in Forest Plan SEIS (2003)
Cumulative Effects after
harvest
Wilderness
Potential
The relative contribution of this area to the National
Wilderness Preservation System would be very low
because it is relatively small and is heavily
influenced by development and activities on
adjacent lands.
Unchanged after harvest of
action alternatives.
Opportunity for
Solitude and
Serenity
The opportunity for solitude is low and the
opportunity for primitive recreation is moderate in
this roadless area.
Unchanged after harvest of
action alternatives.
Scenic Values
The area is unmodified; however, its overall integrity
in not pristine. The roadless area contains no
landscapes considered distinctive for the character
type from scenery perspective.
Unchanged after harvest of
action alternatives.
Recreational
Values
A very small portion of Kadake Creek, a
Recreational River, lies in the northeast portion of
the North Kuiu Roadless Area. There is little
potential for outfitter and guide permits given the
difficulty in accessing the area and the habitat
conditions.
There are no designated recreation areas in the
North Kuiu Roadless Area.
Unchanged after harvest of
action alternatives.
Biological Values
The vegetation within the North Kuiu Roadless Area
is typical of Southeast Alaska. Most of the area is
covered with a mosaic pattern of temperate
rainforest and muskeg.
There are 9,456 acres of mapped forest lands in the
roadless area, approximately 90 percent of which is
productive old-growth. Of the productive old-growth
acres, approximately 5,932 acres, or 63 percent, are
mapped as high-volume old-growth forest.
Forested old-growth stands
would change to forested
young stands. Amount would
vary by alternative.
Reduced acres of productive
old-growth. Varies by
alternative.
Cultural or
Historical Values
The North Kuiu Roadless Area lies within the
traditional territory of the Kake TIingit. There are no
known cultural resource sites in the roadless area,
although some subsistence use probably occurs in
the area via access by existing roads that surround
the Project Area.
Unchanged after harvest of
action alternatives.
Research Values
The area contains no known features of special
interest other than two bands of karst. The mapped
karst resources encompass approximately 2,270
acres or 24 percent of the roadless area. The area
does not include any Potential Research Natural
Areas and has not been identified for any other
scientific purpose.
Unchanged after harvest of
action alternatives.
14 • Chapter 3
Kuiu Timber Sale FEIS
f
Kuiu Timber Sale
Figure 3-1
Roadless Areas and
Unroaded Areas
Legend
Roadless Areas
Unroaded Areas > 1000 Acres and < 5000 Acres
Unroaded Areas < 1000 Acres
Unit Pool
Non-National Forest
Managed Stands
Lakes/Saltwater
Project Area Boundary
Existing Open Roads
Stream Value Class I & II
= Proposed Temporary Roads
A
0 0.5 1
3 4
Miles
Issue 1 : Roadless Areas
3.2.4.4 Alternative 1
This alternative does not propose road constmction or timber harvest
nor does it propose to reduce the miles of open drivable roads. In all of
the action alternatives a minimum of 8.2 miles of open road are
proposed for closure. However, in Alternative 1 those roads would
remain open and would continue to influence the quality of the
roadless area through the sights and sounds of vehicle traffic at current
levels.
3.2.4.5 Alternative 2
Direct and Indirect Effects
There would be no direct effects on the North Kuiu Roadless Area in
Alternative 2. This alternative does not propose any timber harvest or
road construction in the North Kuiu Roadless Area.
A total of 1 1 acres in the roadless area would be affected from the 600-
foot zone of influence around harvest units and the 1,200-foot zone of
influence around proposed roads.
Indirect beneficial effects could occur through the closure of
approximately 7.8 miles of roads that are currently open. Closure of
these roads may reduce the influence of sights and sounds from
vehicle use within the roadless area. These remote roads, however, are
not used much beyond logging and hunting therefore the overall
integrity of the roadless area would not change.
3.2.4.G Alternative 3
A total loss of 67 acres due to timber harvest and 1 acre from
construction of 0.06 mile of NFS road and 0.13 mile of temporary road
is proposed within the North Kuiu Roadless Area in Alternative 3.
Portions of Units 109, 210, and 308 would be within the roadless area.
The proposed harvest is clearcut for all three units and would be highly
visible from areas within the roadless area. Due to the spacing of the
units only one harvest unit would be visible at a time from within the
roadless area. All effects would occur along the edge of the roadless
area.
With the harvest of Unit 308, the roadless area would be narrowed to
an approximately 1,518-foot strip between harvest units at its
narrowest point; a corridor of this width would not be expected to
restrict wildlife movement. Approximately 9,476 acres would be
maintained in a roadless condition.
Unit 307 would be within 600 feet of the roadless area, and its zone of
influence would extend into the edge of the area.
Kuiu Timber Sale FEIS
Chapter 3*17
3 Environment and Effects
Direct and Indirect Effects
By building roads and harvesting in the roadless area this portion
would no longer be roadless.
With the ongoing influenee from roads and managed stands, the
effects to the overall roadless area characteristics and values would be
minimal. Opportunities for solitude would remain low, and the
opportunity for primitive recreation would remain moderate.
A total of 257 acres in the roadless area would be affected, including
the 600-foot zone of influence around harvest units and the 1 ,200-foot
zone of influence around proposed roads.
Indirect beneficial effects could occur through the closure of
approximately 8.0 miles of roads that are currently open. Closure of
these roads may reduce the influence of sights and sounds from
vehicle use within the roadless area. These remote roads, however, are
not used much beyond logging and hunting therefore the overall
integrity of the roadless area would not change.
3.2.4.7 Alternative 4
Approximately 207 acres of roadless area would be removed due to
timber harvest and 0.46 mile of road construction with this alternative.
Approximately 0.33 mile of NFS road and 0.13 mile of temporary road
would be built.
Portions of Units 101, 109, 210, 21 1, and 308 would be located within
the edges of the roadless area; these acres would be clearcut harvested
which would be highly visible from within the roadless area for
several years. Units 305, 302, and 303 are helicopter units located
almost entirely within the roadless boundary; however, they are
scheduled for partial harvest and would not be as noticeable as the
clearcut units. This alternative has 4 units (302, 303, 305, and 308)
along the same drainage and it may be possible to see more than one
harvest unit from a single position within the roadless area.
With the harvest of Unit 308, the roadless area between harvest units
would be narrowed to a strip approximately 1,5 18 feet wide at its
narrowest point; a corridor of this width would not be expected to
restrict wildlife movement. Approximately 9,337 acres would be
maintained in a roadless condition.
A total of 551 acres in the roadless area would be affected when the
600-foot zone of influence around harvest units and the 1,200-foot
zone of influence around roads are applied around the proposed
activities. Helicopter units do not receive the 600-foot zone of
influence buffer according to the Forest Plan SEIS (p. 2-5).
18 a Chapter 3
Kuiu Timber Sale FEIS
Issue 1: Roadless Areas
Units 212 and 307 would be within 600 feet of the roadless area,
extending their zones of influence into the edge of the roadless area.
Direct and Indirect Effects
The reduction of two percent of the roadless area is not expected to
change the integrity of the North Kuiu Roadless Area.
The units are spread along more of the roadless area than in
Alternatives 3 or 5, and this alternative has the greatest reduction in
the total acres from the roadless area; therefore, this alternative would
have the most effect on the roadless area. However, all the effects
would occur along the edge and with the ongoing influence from
existing roads and managed stands, the effects to the overall
characteristics and values would be minimal. The opportunity for
solitude would remain low, and the opportunity for primitive
recreation would remain moderate.
Beneficial effects may result from the closure of approximately 10.5
miles of roads currently open around the roadless area. Closure of
these roads may reduce the influence of sights and sounds from
vehicle use within the roadless area. These remote roads, however, are
not used much beyond logging and hunting therefore the overall
integrity of the roadless area would not change.
3.2.4.S Alternative 5
Approximately 1 14 acres of roadless area would be removed due to
timber harvest and 0.46 mile of road construction (approximately 0.33
mile of NFS road and 0. 13 mile of temporary road) in the North Kuiu
Roadless Area with this alternative.
Units 101, 109, 210, 211, and 308 would be located within the roadless
area and would be clearcut. The harvested units would be highly
visible from within the roadless area; however, because of the distance
between the proposed units, only one harvest unit would be visible at a
time.
About 9,430 acres would be maintained in a roadless condition.
A total of 397 acres of roadless area would be affected when the 600-
foot zone of influence around harvest units and the 1 ,200-foot zone of
influence around roads are applied around the proposed activities.
With the harvest of Unit 308, the roadless area would be narrowed to
an approximately 1,518-foot strip between harvest units at its
narrowest point; a corridor of this width would not be expected to
restrict wildlife movement.
Units 212 and 307 would be within 600 feet of the roadless area,
extending their zones of influence into the edge of the roadless area.
Kuiu Timber Sale FEIS
Chapter 3*19
Environment and Effects
3.2.5
Effects on
Unroaded
Areas
Direct and Indirect Effects
The reduction of one percent of the roadless area is not expected to
change the integrity of the North Kuiu Roadless Area.
All effects would occur along the edge of the roadless area. With the
ongoing influence from roads and managed stands, the effects to the
overall characteristics and values would be minimal. Opportunities for
solitude would remain low, and the opportunity for primitive
recreation moderate.
Beneficial effects could result from the closure of about 10.5 miles of
roads that are currently open around the roadless area. Closure of these
roads may reduce the influence of sights and sounds from vehicle use
within the roadless area. These remote roads, however, are not used
much beyond logging and hunting therefore the overall integrity of the
roadless area would not change.
Tables 3-7 to 3-10 list the direct and indirect effects of the proposed
harvest by alternative on the two unroaded areas in which timber
harvest or temporary road building is proposed. No table is shown for
the third unroaded area with no proposed timber harvest or road
construction in any action alternative. Locations of these unroaded
areas are shown in Figure 3-1.
Table 3-7. Direct Effects on Area 1 (Southern Unroaded Area 2,412 acres) by
alternative
Measure of Effects
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Acres harvested within units
0
0
68
149
149
Percent of unroaded area affected by units
0
0
3%
6%
6%
Acres^ of temporary roads in unroaded areas
0
0
3.1
3.8
3.8
Unroaded Area 1 acres after harvest
2,412
2,412
2,341
2,259
2,259
One mile of road eonstruction (NFS or temporary) equals 4.85 acres.
20 • Chapter 3
Kuiu Timber Sale FEIS
Issue 1 : Roadless Areas
Table 3-8. Direct Effects on Area 2 (Middle Unroaded Area 3,302 acres) by
alternative
Measure of Effect
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Acres harvested within units
0
0
0
18
18
Percent of unroaded area affected by units
0
0
0
<1%
<1%
Acres of NFS and temporary roads in unroaded
areas®
0
0
0
0.3
0.3
Unroaded Area 2 - acres after harvest
3,302
3,302
3,302
3,284
3,284
One mile of road construction equals 4.85 acres.
Direct and Indirect Effects
Alternatives 1 would not affect unroaded areas less than 5,000 acres.
Alternative 2 does not propose any timber harvest units or roads within
unroaded areas and would not have any direct effects.
Alternative 3 proposes harvest of 68 acres (portions of Units 403, 409,
and 410), and construction of 0.55 mile of NFS and 0.09 mile of
temporary road within Unroaded Area 1 . This area would be reduced
by approximately three percent to 2,341 acres. No timber harvest is
proposed within Unroaded Area 2 in Alternative 3.
Alternatives 4 and 5 propose harvest of 167 acres from Unroaded
Areas 1 and 2 (Units 402, 403, 409, 410, 412, and 503) and
construction of 0.55 mile of NFS road and 0.3 mile of temporary road
within the unroaded areas.
Logging activities and traffic may be heard from Unroaded Area 1 .
These logging roads existed before this project was planned. The
proposed activities would not change the integrity of the unroaded
areas.
When the zones of influence from roads and timber harvest are
considered, 6 acres of unroaded area in Alternative 2 and 292 acres of
unroaded area in Alternative 3 would be affected. In Alternative 4, a
total of 497 acres and in Alternative 5 a total of 498 acres of unroaded
area would be affected.
Unroaded Area 1 would be reduced by approximately nineteen percent
to 1,960 acres and Unroaded Area 2 would be reduced approximately
one percent to 3,256 acres.
Kuiu Timber Sale FEIS
Chapter 3*21
Environment and Effects
Table 3-9. Indirect Effects on Area 1 (Southern Unroaded Area 2,412 acres) by
alternative
Measure of Effects
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Acres of unroaded area affected^
0
0
292
451
452
Percent of unroaded area affected by units
0
<1%
12%
19%
19%
Acres in Unroaded Area 1 after harvest*’
2,412
2,406
2,120
1,961
1,960
^ Total includes 600-foot buffers around proposed timber harvest units and 1,200-foot buffers along proposed NFS and
temporary roads within the roadless areas.
^ All new NFS and temporary roads in roadless areas would be closed after harvest.
Table 3-10. Indirect Effects on Area 2 (Middle Unroaded Area 3,302 acres) by
alternative
Measure of Effect
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Acres of unroaded area affected^
0
0
0
46
46
Percent of unroaded area affected by units
0
0
0
1%
1%
Acres in Unroaded Area 2 after harvest
3,302
3,302
3,302
3,256
3,256
^ Total includes 600-foot buffers around proposed timber harvest units and 1,200-foot buffers along proposed NFS and
temporary roads within the roadless areas.
All new NFS and temporary roads in roadless areas would be closed after harvest.
3.2.6 Iri Alternatives 1 the roadless areas and unroaded areas would be
Conclusion unehanged. Alternative 2 would only affeet the zone of influence,
extending it slightly into the North Kuiu Roadless Area and one
unroaded area. In Alternatives 3-5, the North Kuiu Roadless Area and
two of the three unroaded areas would be reduced in size as shown in
Tables 3-4 to 3-10. The North Kuiu Roadless Area would remain
eligible for inclusion in the National Wilderness Preservation System,
the unroaded area would still be over 1,000 acres, and values identified
for the roadless areas within the Project Area would be retained.
3.2.6. 1 Cumulative Effects
Cumulative effects on roadless areas were analyzed at the Forest Plan
level. The decision was made to allocate roadless areas to either
development or non-development LUDs. During the analysis for the
Forest Plan the values of the roadless areas, their location, and their
proximity to other roadless areas, especially Congressionally-
designated Wilderness Areas, were used to determine which roadless
areas would be allocated for development.
22 ® Chapter 3
Kuiu Timber Sale FEIS
Issue 1 : Roadless Areas
There are currently 9.6 million acres of land that are unroaded on the
Tongass National Forest. Even with full implementation of activities
allowed by the Forest Plan and no further Wilderness designation, 90
percent would remain roadless after 10 years, and 87 percent would
remain roadless after 50 years (2003 Forest Plan SEIS ROD p. 12).
The North Kuiu Roadless Area has been designated as a Timber LUD.
None of the alternatives for the Kuiu Timber Sale project would affect
the Wilderness eligibility of any roadless area.
It is reasonable to assume that timber harvest and associated road
management will continue on Kuiu Island. Although in all action
alternatives for the Kuiu project all new NFS roads would be closed
after the completion of timber harvest activities, it is intended these
roads would be used again in the future to access additional timber
lands within the North Kuiu Roadless Area and in Unroaded Area #1.
Cumulative effects for roadless areas include reasonable foreseeable
future activities that overlap in the Project Area. Harvest of the
remaining units from the Crane and Rowan Mountain Timber Sales
EIS may affect approximately 284 acres of the Security Roadless
Area. If harvest occurs this roadless area would still be eligible for
Wilderness designation.
In addition, there are four units from the Crane Rowan Mountain
Timber Sales EIS and 0.32 mile of proposed road constmction in
Unroaded Area 1. If harvested, it would remove 209 acres from the
unroaded area . There is also 0.53 mile of proposed road construction
in Unroaded Area 2. If this area were harvested, it would remove 100
acres from the unroaded area.
The current five-year plan and the events listed in the Catalog of
Events for Kuiu Island are not expected to reduce the size of any of the
roadless areas on Kuiu Island to less than 5,000 acres or make them
ineligibile for Wilderness consideration.
Since timber harvest and associated road building and major facilities
are not allowed within non-development LUDs, at least 219,512 acres
of these roadless areas on Kuiu Island would remain in a natural state
for the life of the Forest Plan.
Kuiu Timber Sale FEIS
Chapter 3 • 23
3.3.1
Introduction
3.3 Issue 2 - Deer Habitat and
Subsistence Use
This issue relates to changes in deer habitat including wildlife travel
corridors and deer winter range. It also includes the availability of deer
for subsistence. Subsistence is an Alaska concern and a right protected
by law. This evaluation addresses the potential effects of harvesting
timber from the northern portion of Kuiu Island on the subsistence use
of Sitka black-tailed deer.
3.3.1 .1 Units of Measure and Areas of Analysis
Deer Habitat
The effects of timber harvest on Sitka black-tailed deer habitat are
analyzed by comparing changes in deer winter range (using the Forest
Plan deer model) and by comparing the changes in POG and low
elevation, high volume habitat by alternative.
Analysis for acres of deer winter range will include comparisons of
changes between past, present and reasonably foreseeable future deer
winter range by alternative. Important deer winter range is derived
from quartiles which are based on the total acres of Habitat Suitability
Indices (HSI) within the area of analysis, as directed in the May 25,
2005 Forest Supervisor’s letter (Cole 2005). The WAA is the
appropriate scale of analysis to develop HSI values for this project in
order to compare the quartile analysis with the Forest Plan analysis.
Analysis for low elevation, high volume habitat will include
comparisons of changes in acres of habitat between past, present and
reasonably foreseeable future activities within WAA 5012 as this will
allow a comprehensive accounting of all activities that may affect this
habitat and yet be sensitive to potential effects of the proposed
activities.
Connectivity
The removal of existing corridors due to proposed harvest have been
analyzed. Harvest prescriptions that retain 50 percent or more of the
original stand were developed to maintain wildlife habitat and travel
corridors in several alternatives.
3.3.1. 2 Sitka Black-tailed Deer
The Sitka black-tailed deer was chosen as an MIS because it is an
important game and subsistence species and is associated with old-
growth forests. Deer habitat effects were calculated at the WAA level
following Forest Supervisor direction (Cole 2005). Research
24 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
conducted in Southeast Alaska indieates that high-volume, mature
forests at lower elevations (800 feet or less) are needed to sustain deer
populations during winters with deep snowfall (Schoen et al. 1985;
Hanley and Rose 1987; Yeo and Peek 1992).
Recent work in Southeast Alaska by Doerr et al. (2005) reconfirmed
deer were selecting high volstrata, low-elevation stands on south
aspects during periods of heavy snowfall. Large, strong branches of
mature stands intercept snow and maintain available forage.
Productive, high volume stands of old-growth forests support the
largest biomass of herb and shrub forage (Alaback 1982). Deer
populations are impacted by the combination of deep snow winters and
large amounts of winter range converted to second growth. Snow
reduces or eliminates forage availability in young clearcuts. Closed
canopy, young growth stands provide little forage in all seasons.
The Sitka black-tailed deer receives the highest sport hunting and
subsistence use of all terrestrial species in Southeast Alaska. In
ADF&G’s Game Management Unit (GMU) 3, where Kuiu Island is
located, deer are extremely important, as all of the communities in this
region utilize this resource. Maintaining sufficient habitat to ensure the
continued existenee of this species is a priority for the Forest Service.
Early successional stands provide forage for deer during mild winters
and the remaining seasons. Sitka black-tailed deer disperse (travel)
through and use a variety of vegetation communities throughout the
year, and no specific corridor requirements have been identified.
Every 20 to 40 years severe winters kill large numbers of deer. On the
Petersburg Ranger District, this last occurred during the winters of
1969-72 (Brainard 1996). Cold weather with higher than normal
persistent snowfall covered forage and eaused deer populations to
deeline rapidly.
The era of heaviest logging occurred between 1970 and 1989 after the
deer crash. Following these two decades, deer populations continued
to climb and hunting was reopened in 1992. Deer herds, which crashed
at the same time on the more heavily logged, roaded, and populated
Prince of Wales Island, have returned in greater numbers than on
Kuiu. We therefore assume that factors other than timber harvest alone
are restricting the deer population on Kuiu from reaching historic
levels. These additional factors include large populations of black bear
and wolves.
3. 3.1. 3 Productive Old-growth (POG)
The trees growing in productive old-growth exhibit a wide range of
diameters, heights, and stand structure characteristics. This habitat
supports high biological diversity. Table 3-12 displays total acres of
POG harvested by alternative.
Kuiu Timber Sale FEIS
Chapter 3 • 25
Environment and Effects
Table 3-11. Historic and current POG acres within WAA 5012 and
the Project Area
1954 (historic
condition)
2006 (existing
condition)
Percent change
from historic to
existing
condition
WAA 5012
(145,634 acres)
112,677
90,856
-19%
Project Area
(46,102 acres)
40,978
30,586
-25%
Table 3-12. Effects of the proposed alternatives on POG habitat^ within the
Project Area (acres remaining after harvest)
Productive
Old -growth
Historical
Condition
(1954)
Alt 1
(Current)
Alt 2
Alts
Alt 4
Alt 5
Acres
40,978
30,586
30,109
29,800
29,199
29,378
High volume strata
21,251
20,863
20,631
20,099
20,322
Medium volume strata
5,211
5,147
5,078
5,028
4,987
Low volume strata
650
632
629
620
620
Percent current POG
remaining after harvest
100%
98%
97%
95%
96%
Percent historic POG
remaining after harvest
75%
73%
73%
71%
72%
Note: Acres of volume strata harvested in each alternative does not equal the total unit size due to some “non”
POG acres identified in GIS. These acres may be “holes” of unidentified volume in the GIS layer, or MMI-4 Soils
(see the Soils and Geology section in this chapter).
3.3.1. 4 Low Elevation/High Volume POG
As discussed above, productive old-growth has different values based
on volume and location. Low elevation/high volume old-growth is
some of the most limited and important habitat for several old-growth
dependent species including marten and goshawk and can serve as
some of the best deer winter range.
Table 3-13 displays the total acres of POG below 800 feet harvested
by alternative and harvest retention.
26 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
Table 3-13. Acres of High Volume POG below 800 feet Harvested within the
Project Area
Alt 1
Alt 2
Alt 3
Alt 4
Alt 5
Total acres planned
for harvest
0
478
786
1,387
1,208
Acres of high volume
harvested below 800’
0
101
82
259
156
Acres of high volume
harvested with 50%
basal area retention
below 800’
0
60
57
112
0
Acres of high volume
clearcut below 800’
0
41
25
147
156
Percent of total acres
of high volume
harvested below 800’
0
21%
10%
19%
13%
Project Area
Current Condition: 14,481 acres of POG below 800 feet
Alt 2
Alt 3
Alt 4
Alt 5
Acres of Low Elevation/High Volume
POG remaining in Project Area after
harvest
14,380
14,399
14,222
14,325
Percent acres of high volume
remaining in Project Area after harvest
99%
99%
98%
99%
WAA 5012
Current Condition: 22,956 acres of POG below 800 feet
Alt 2
Alt 3
Alt 4
Alt 5
Acres of Low Elevation/High Volume
POG remaining in WAA after harvest
22,637
22,547
21,913
22,259
Percent acres of high volume
remaining in WAA after harvest
99%
98%
95%
97%
3. 3.1. 5 Effects of silvicultural treatments on deer habitat
Changes in deer habitat from timber harvest may increase populations
in the short-run (20-30 years). However, as stands mature, habitat will
decrease in value over time as a result of plant succession. Several
Kuiu Timber Sale FEIS
Chapter 3 • 27
3 Environment and Effects
silvicultural treatments are available to maintain the habitat value for
deer and other species over time. Pre-commereial thinning,
commercial thinning, girdling, and pruning may help maintain the
understory in these stands for a longer period of time.
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 eleareut
treatments. The light (1-25 percent basal area) and medium (26-50
pereent basal area) cutting intensity plots did not differ significantly in
community structure from the uneut plots. Partial harvest stands do not
show the dramatic rise and fall of blueberry abundance in stands 20 to
80 years after cleareutting. Deal also noted that the deerease in
blueberry abundanee following partial harvest was small when
compared to that of cleareutting. Community plant structures in the
forests 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 eommunities typieally found in old-growth
stands (Deal 2001).
The aetion alternatives that prescribe uneven-aged silvicultural
systems would retain a minimum of 50 percent of the basal area.
These units would retain structure of the existing tree stand and help
maintain wildlife values including travel corridors. Within the next 50
years, it is predieted that the deer habitat values in these stands would
return to what they are presently (Deal and Tappeiner 2000, Deal
2001).
3.3.1. 6 Deer Habitat Capability Model
An interagency deer habitat capability model (DeGayner 1996) was
developed for the Forest Plan to evaluate the potential quality of
winter habitat for Sitka blaek-tailed deer. The model was developed as
a tool to compare the effeets of action alternatives to no action, and
assess future habitat suitability and eapability of the WAA (Cole
2005). The model is a good tool to compare the ehanges in habitat
between historic, current, and proposed actions and will be used as
such in this report.
The model was updated to use an HSI of 1.0 = 100 deer/mi^ as a
multiplier based on work by Person et al. (1997). The model ealculates
habitat suitability indices (HSI) based on timber volume strata, aspect,
elevation, and typical snowfall. High volstrata productive old-growth
(POG) with south aspects, at lower elevation (below 800 ft.), and in
low snowfall areas are assumed to provide the best deer winter range.
This corresponds with recent findings in Doerr et al. (2005).
28 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
For a more in-depth discussion on FISI calculations see the Wildlife
Resource Report available in the planning record. For a discussion of
the reliability of habitat capability models please refer to “The Role
and Reliability of Habitat Capability Models” (DeGayner 1992,
available in the Kuiu project planning record).
The interagency deer habitat capability model was run for WAA 5012
using the 100 deer/mi^= HSI 1 .0 with no predation, as directed by the
Forest Supervisor’s May 25, 2005 letter, the Annual Monitoring &
Evaluation Report for FY 2000, and the MOU Agreement No.
OOMOU-1 11001-026. The model does not differentiate between
harvest prescriptions, treating all harvest as clearcut. Harvest
conditions present in 1954 were used to give a general indication of
the overall habitat quality within the WAA.
While all HSI values have the capability to support deer to some level,
the HSI values are generally grouped into four levels or quartiles with
the highest level (4) having the greatest ability to support deer. This
quartile is referred to as important deer winter range in this report.
HSI numbers represent the best available information on deer habitat
values and were compiled over the years (since deer modeling started
on the Tongass in 1985) by deer specialists from the Alaska
Department of Fish and Game, USDA Forest Service, US Fish and
Wildlife Service and a panel of experts for the Forest Plan working
cooperatively.
When habitat in the high quartile is harvested, it moves into a lower
value, however, it may still be in the high quartile following harvest.
Low elevation (below 800 feet) on south- and west-facing aspects with
low snow levels will have an HSI of above 0.60 following harvest.
That means that this habitat type will be available to deer during
normal winter snowfall and produces a relatively high food nutritive
value for deer. During winters with higher than normal snowfall these
habitat types would not be expected to be available to deer, therefore,
the model runs will overestimate the effects to deer during those high
snowfall years. However, at the end of the stem exclusion stage
(Oliver and Larson 1996) these values drop to 0.02 HSI (pole timber
clearcuts 26-200 years old), which has a very low food nutritive value
for deer.
Table 3-14 shows the HSI values as they are grouped within the
quartiles for the historic condition, the current condition, and future
(2046) condition of WAA 5012. The future condition in Table 3-14 is
the current condition grown out 30 years and does not include
proposed or reasonably foreseeable future activities.
Kuiu Timber Sale FEIS
Chapter 3 • 29
3 Environment and Effects
Table 3-14. WAA 5012 deer habitat suitability indices - historic
(1954), current (2006), and future (2046) condition
Quartile
HSI
values
1954
acres
2006
acres
Percent
change
2046
acres'^
Percent
change
from
1954
1
0.01 -
0.20
30,536
50,023
+39%
51,778
+41%
2
0.23-
0.36
32,929
33,393
+ 1%
31,638
-4%
3
0.40-
0.50
27,798
21,643
-22%
21,643
-22%
a
4
0.60-
1.0
35,766
21,971
-39%
21,744
-40%
a
The 4* quartile is considered important deer winter range.
2046 numbers are based on the current condition with no additional harvests.
3. 3.1. 7 Important Deer Winter Range
As Table 3-15 shows, the acres of important deer winter range have
been reduced approximately 39 percent (approximately 21,971 acres)
as a result of previous timber harvest. Important deer winter range is
defined as the HSI values in the highest quartile as determined from
the historic (1954) condition. As the stands reach the stem exclusion
age, which the interagency deer habitat capability model (DeGayner
1996) assumes will occur 26 years after harvest, deer habitat is
reduced with the loss of browse. Many of the existing managed stands
in the Project Area are over 30 years of age, so the modeled decline is
assumed to have begun to occur. Those stands under 30 years of age
will show a decline in deer habitat capability within a few years,
according to the model. In this analysis the year 2046 is used to
represent the future condition and includes the effects of the proposed
timber harvest on future deer habitat capability in the WAA. Figure 3-
2 displays the current deer HSI values by quartile in WAA 5012.
Future declines in deer HSI values from the current condition
predicted by the Forest Plan deer model are shown for the year 2046 in
Figure 3-3.
Table 3-15 displays the direct effects of harvest by alternative on
important deer winter range for WAA 5012. The results indicate that
the decrease in current deer habitat capability in the WAA would
range from less than one percent to approximately one percent,
depending on the alternative selected. Habitat is relatively uniform
across WAA 5012 and changes at the project level would be very
30 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
similar to changes at the WAA level. When all existing and proposed
managed stands have reached the stem exclusion stage by the year
2046, the model predicts that the cumulative decline in the WAA of
important deer winter range would be 40 percent for all alternatives.
This analysis does not include the potential benefits from thinning or
partial harvest.
Table 3-15. Direct effects of harvest on important deer winter range in WAA
5012 by alternative
HSI value 0.6 -1.0
Alternative
(Historic acres 35,766)
1
2
3
4
5
Acres of important deer
winter range
21,971
21,843
21,841
21,660
21,725
Percent change from present condition
<1%
<1%
1%
1%
Percent change from historic
to current condition
39%
39%
39%
39%
39%
3.3.1. 8 Hunting
As discussed earlier, Sitka black-tailed deer inhabit the Kuiu Island
portion of GMU 3 in low numbers. Severe back-to-back winters in the
early 1970s reduced the herd numbers drastically and high black bear
and wolf predation are likely keeping the deer herds from rebounding.
The deer harvest from Kuiu Island constitutes only three percent of the
total harvest for GMU 3, with an average of 18 animals harvested
yearly on an island of approximately 482,102 acres (ADF&G hunter
surveys).
On average, 36 percent of the deer were harvested in GMU 3 by
hunters using the road system, while 47 percent of the deer harvested
were taken by hunters using a boat for access. The harvest method for
the remaining 17 percent is unknown (ADF&G hunter surveys). The
majority of animals taken from the road system were on the Mitkof,
Zarembo, and Kupreanof (Portage Bay, Kake, and Lindenberg
Peninsula) road systems.
On Kuiu Island the majority of boat-based hunting occurs in Port
Camden, Kadake, and Rocky Pass. The majority road-based hunting
occurs around Rowan Bay and the inland areas of the island. For more
information on Sitka black-tailed deer hunting see the Subsistence
portion of this section and the Subsistence Specialist Report available
in the Kuiu Project planning record.
Kuiu Timber Sale FEIS
Chapter 3 • 31
3 Environment and Effects
3. 3. 1.9 Productive Old-growth and Connectivity
Landscape connectivity is the degree to which the landscape facilitates
or impedes movement among habitat patches or the functional
relationship among habitat patches (Tischendorf and Fahrig 2000).
Connectivity does not necessarily mean that old-growth habitat areas
need to be physically joined for all species, since many old-growth
associated species across the Tongass can move or be carried across
areas not in old-growth conditions (Forest Plan FEIS Part 1, p. 3-33).
However, the Forest Plan also recognizes that for species with limited
dispersal capabilities, such as lichens, fungi, bryophytes, plants, and
small-bodied animals, the corridors may be the only linkage between
habitats and need to function as breeding habitat. In these instances the
habitat quality of these corridors is of utmost importance. Wider
corridors are considered to be more effective at facilitating species’
movements. A functioning corridor should be continuous, maintaining
a minimum width along its entire length, and it must also contain
suitable habitat for the species that are expected to move within it.
The definition of a corridor and its function can vary according to the
species that use it. Forested muskeg may act as a corridor for mobile
species with less affinity to old-growth forest, whereas roads may act
as corridors for wolves during winter. Productive old-growth stands
provide corridors for species, such as marten, that avoid open
landscapes (Suring et al. 1992), and small-bodied animals that are not
highly mobile (Pardini et al. 2005).
Old-growth forest habitat within the Project Area occurs in landscape
patterns of naturally fragmented old-growth forest, muskeg, and
forested wetlands. The majority of forest types in Southeast Alaska are
not a continuous sea of “old growth”; many are in different stages of
stand development and are unaffected by management activities
(Oliver and Larson 1996, Kramer 1997).
Past timber harvest activities have resulted in additional fragmentation
within some of the old-growth habitat areas. In eontrast to
fragmentation from natural disturbance events where broken or fallen
trees remain to contribute to the overall functioning of the old-growth
habitat, timber harvest removes much of the wood biomass from an
area. This old-growth habitat fragmentation, combined with the
proposed harvest for this project, may have adverse effects on some
old-growth associated wildlife species. Too much fragmentation could
make an area unsuitable for some old-growth associated species for
several decades, and could affect the ability of some species to
effectively travel between the remaining areas of old-growth habitat.
Although there are published studies that question the utility of
corridors for species conservation, a review of these studies suggests
32 • Chapter 3
Kuiu Timber Sale FEIS
3.3.3
Direct and
Indirect
Effects by
Alternative
Issue 2: Deer Habitat and Subsistence Use
that corridors can be effective, and proposes that inconclusive studies
have turned out so because of design flaws (Beier and Noss 1998). The
Forest Plan addresses landscape patterns including connectivity of old-
growth patches by corridors (Forest Plan Final EIS Part 1, p. 3-20).
Two important landscape elements, beach and estuary fringe and
riparian areas, have special importance as components of old-growth
forest and provide unique wildlife habitats as well as serving as
wildlife travel corridors. The Tongass has established 1,000-foot
buffers along beach and estuary fringes and 1 00-foot minimum buffers
for fish streams (buffer widths vary on riparian areas by stream
process groups) where no programmed timber harvest is allowed.
Travel corridors exist between proposed timber harvest units for this
project. Depending upon the alternative selected by the Forest
Supervisor, some corridors would remain following harvest and others
would be removed. In the units where silviculture prescriptions
prescribe 50 percent basal area retention, usable corridors would be
maintained (See Unit Cards in Appendix B).
3.3. 3.1 Alternative 1
This alternative proposes no new activities in the Project Area.
Wildlife habitat may decline in current second-growth stands as they
develop and the understory forage becomes shaded. There would be no
change in the current road network.
No POG would be reduced. Old-growth stands would continue to
support wildlife at their current capability at least until the next
planning cycle. This area is within a Timber Production LUD and it is
assumed that it will be harvested at some future time.
Important deer winter range has been reduced by 39 percent since
1954 in WAA 5012. No additional acres of deer habitat would be
harvested with the implementation of this alternative. When previously
harvested areas develop to the point of stem exclusion, thinning or
pruning could be applied to increase forage productivity.
3.3.3.2 Alternative 2
Alternative 2 proposes harvest on 478 acres. Harvest prescriptions
include 280 acres of partial harvest with 50 percent basal area
retention and 197 acres of clearcut.
Alternative 2 would harvest 388 acres of high volume POG, 64 acres
of medium volume, and 18 acres of low volume. Of this harvested
volume, approximately 280 acres would retain 50 percent of the basal
Kuiu Timber Sale FEIS
Chapter 3 • 33
3 Environment and Effects
area. This would provide habitat forage habitat for deer.
Approximately 197 acres would be clearcut.
Alternative 2 and Alternative 3 would retain the most low elevation,
high volume habitat.
Partial harvest of 60 acres of low elevation, high volume forest would
retain valuable habitat structures within the harvested areas, including
some canopy cover and increased forage value for deer habitat.
The clearcut harvest of 41 acres of low elevation, high volume forest
would remove the coarse structure from the stands that may take in
excess of 100-150 years to develop.
According to deer model predictions, a reduction of less than one
percent (128 acres) of the historic important deer winter range may
occur with the implementation of this alternative. The high number of
acres of important deer winter range remaining after implementation
(21,843) and the low hunting success on Kuiu (average 18 deer/year)
indicates that WAA 5012 could support more deer than are currently
present and that the proposed reduction in habitat should not affect
deer populations.
Clearcutting Units 103, 208a, 208b and part of 207 will not remove the
travel corridors that exist from high to low elevation; however, it will
reduce the corridor width. Clearcutting Units 416 and 417 will remove
possible eorridor between existing units but will not have an affect on
corridors from high to low elevation. The remaining proposed units
(109b, 111, 207, 209, 404, 405 and 415) are located in travel corridors
where deer travel from high to lower elevations. Within these stands,
three harvest prescriptions, leaving a minimum of 50 percent of the
basal area following harvest, will help maintain the travel corridors.
Deer would unlikely be adversely affected by this alternative since 280
acres (59 percent of the acres harvested) are in partial harvest
prescriptions that retain 50 percent of the basal area, which would help
maintain a natural forest mosaic and retain habitat. Road closures
would reduce hunter accessibility. The Forest Plan deer model reports
all units as harvested by an even-aged prescription, so the model
would overestimate the number of acres of high value habitat removed
using partial harvest.
3. 3. 3.3 Alternative 3
Alternative 3 proposes harvest on 786 acres. Harvest prescriptions
include 377 acres of partial harvest with 50 percent basal area
retention and 409 acres of clearcut harvest.
Alternative 3 would harvest 620 acres of high volume, 133 acres of
medium volume, and 2 1 acres of the low volume. Of this harvested
34 • Chapter 3
Kuiu Timber Sale FEIS
mi
^KsV V V' jft 1
Kuiu Timber Sale
Figure 3-2
Winter Range Current Condition
.egend
HSI .01-.2
HSI ,23-.36
HSI .4-.5
High Value HSI .6-1
Non-National Forest
Lakes/Saltwater
Existing Open Roads
Project Area Boundary
500ft Contour Interval
Stream Value Class I & II
Kuiu Timber Sale
Figure 3-3
Deer Winter Range for 2046
Legend
HSI .01-.2
HI HSI .2S-.36
■I HSI .4-.5
IB High Value HSI .6-1
Non-National Forest
Lakes/Saltwater
Project Area Boundary
500ft Contour Interval
— Existing Open Roads
Watershed Boundary
Stream Value Class I & II
Issue 2: Deer Habitat and Subsistence Use
volume approximately 377 acres would retain 50 percent of the basal
area. This would provide forage habitat for deer. Approximately 409
acres would be clearcut.
Alternative 3 would be similar to Alternative 2 in that both alternatives
would retain the most low elevation, high volume habitat.
Partial harvest of 57 acres of low elevation, high volume forest would
retain valuable habitat structures within the harvested areas, such as
canopy cover and forage value for deer habitat.
The clearcut harvest of 25 acres of low elevation, high volume forest
would remove the coarse structure from the stands and may take in
excess of 100-150 years to reestablish.
According to deer model predictions, a reduction of less than 1 percent
(130 acres) of the historic important deer winter range would occur
with the implementation of this alternative. These reductions in habitat
are not expected to affect deer populations within WAA 5012. The
high number of acres of important deer winter range remaining after
implementation (21,841) and the low hunting success on Kuiu
(average 1 8 deer/year) indicates that the WAA could support more
deer than are currently present, and a reduction in habitat should not
reduce deer populations.
This alternative proposes the harvest of a portion of Units 109 and
207, and all of Units 205, 208, 210, 307, 308, 403, 410 and 416 using
even-aged prescription. The harvest of these units will not remove
wildlife travel corridors between high and low elevation. As in
Alternative 2, Unit 416 will remove a corridor between existing units
but it maintains the corridor between high and low elevation.
The remaining units will be harvested using three different
prescriptions, all leaving 50 percent of the basal area following harvest
to help mediate this concern. Units 109, 1 12, 207, 209, 404 and 405
will occur within the travel corridors between high and low elevation.
Unit 417, like 416, removes a corridor between existing units but
maintains the high to low elevation travel corridor.
Approximately 377 acres (48 percent of the acres harvested) are in
partial harvest prescriptions that would retain 50 percent of the basal
area, which would help maintain a natural forest mosaic and retain
habitat for all the above species. Road closures would reduce hunter
accessibility. The deer model reports all units as harvested by an even-
aged prescription so the results would be even less with a 50 percent
retention prescription.
Kuiu Timber Sale FEIS
Chapter 3 • 39
3 Environment and Effects
3.3. 3.4 Alternative 4
Alternative 4 proposes harvest on 1,387 acres. Harvest prescriptions
include 399 acres of partial harvest with 50 percent basal area
retention and 1,026 acres of clearcut.
Alternative 4 would harvest 1,152 acres of high volume, 183 acres of
medium volume, and 30 acres of low volume. Of this harvested
volume approximately 362 acres would retain 50 percent of the basal
area. This would provide forage habitat for deer. Approximately 1,025
acres would be clearcut.
Alternative 4 would harvest the most acres of low elevation, high
volume POG habitat (259 acres).
Partial harvest of 1 12 acres of low elevation, high volume forest would
retain valuable habitat structures within the harvested areas, such as
some canopy cover and forage value for deer habitat.
The clearcut harvest of 147 acres of low elevation, high volume forest
would remove the coarse structure from the stands and may take in
excess of 100-150 years to reestablish.
According to deer model predictions, a reduction of approximately one
percent (311 acres) of the important deer winter range would occur
with the implementation of this alternative. This reduction in habitat is
not expected to affect deer populations within WAA 5012. The high
number of acres of important deer winter range remaining after
implementation (21,660) and the low hunting success on Kuiu
(average 18 deer/year) indicate that the WAA could support more deer
than currently present and a reduction in habitat should not reduce deer
populations.
The clearcut harvest of 1,387 acres in Units 101, 109, 1 12, 208, 210,
21 1, 212, 307, 308, 401, 402, 403, 404, 405, 409, 410, 412, 416, 418,
503 and 504 will partially remove travel corridors between high and
low elevation. The harvest of Units 109, 111, 1 12, 401, 404 and 405
will completely remove travel corridors between high and low
elevation while harvest of Units 416, 418, 503 and 504 will remove
corridors between existing units.
The remaining units will be harvested using three different
prescriptions, all leaving 50 percent basal area to help mediate this
concern. The partial harvest of Units 207, 209, 414 and 415 will help
maintain these areas as a viable corridor.
Of the action alternatives, this one would impact deer habitat the
greatest since it would harvest the most forest and remove the most
habitat. However, while there may be some local impacts to
40 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
individuals within the population, the population would not be
adversely affected.
3.3.3.5 Alternative 5
Alternative 5 proposes harvest of 1,208 acres, all of which would be
clearcut harvested.
Alternative 5 would harvest 929 acres of high volume, 224 acres of
medium volume, and 30 acres of low volume. Of this harvested
volume none would retain 50 percent of the basal area. All 1,208 acres
would be clearcut.
Alternative 5 would clearcut harvest the most low elevation, high
volume POG habitat (156 acres) and would not partially harvest any
units. The coarse structure removed from the stands may take in excess
of 100-150 years to reestablish.
According to deer model predictions, a reduction of approximately one
percent (246 acres) of the important deer winter range would occur
with the implementation of this alternative. These reductions in habitat
are not expected to affect deer populations within WAA 5012. The
high number of acres of important deer winter range remaining after
implementation (21,725) and the low hunting success on Kuiu
(average 1 8 deer/year) indicate that the WAA could support more deer
than are currently present and a reduction to habitat should not reduce
deer populations.
Harvesting Units 109, 111, 112, 207, 209, 401, 404 and 405 would
remove travel corridors between high and low elevation, including
Units 207 and 209 which are identified as important travel corridors in
Alternative 4. Harvesting Unit 208, 412, 418 and 503 will reduce the
travel corridors between high and low elevation while the harvest of
Units 1 12, 416, 417 and 504 will remove corridors between existing
units.
3. 3.3. 6 Past, Present, and Reasonably Foreseeable Future
Timber harvest has occurred on much of the northern portion of Kuiu
Island. This harvest was mostly to fill the needs of the long-term sale
program starting in 1968. Kuiu Island was an alternate area for the
Alaska Pulp Corporation long-term sale. The Kuiu Catalog of Events
is located in the planning record and was consulted for determining
cumulative effects. All timber harvest in WAA 5012 from the four
acres harvested in 1931 to the planned, but unharvested units from
Crane and Rowan Mountain Timber Sales and Threemile Timber Sale
EISs have been accounted for in this analysis. All non-harvest
activities were reviewed for possible impacts to wildlife species as
well.
Kuiu Timber Sale FEIS
Chapter 3 • 41
3 Environment and Effects
Most of the previously harvested units have been treated once with
silvicultural thinning. Wildlife would benefit from the thinning,
girdling and/or pruning treatment to approximately 1,475 acres of 39-
year-old second-growth stands within the Saginaw watershed. The
IDT has visited these units and has determined that it would be
beneficial to prescribe treatments to extend the usefulness of the deer
and bear habitat. The judicious use of silvicultural treatments can
extend productive time that harvested units provide suitable habitat.
Planned Projects
For the Kuiu Timber Sale action alternatives, an individual timber sale
or more than one sale over a period of several years, may occur.
It is reasonable to assume that timber harvest and associated road
management will continue on Kuiu Island. The current Tongass timber
sale schedule lists other timber sale projects;
• Crane and Rowan Mountain Timber Sales ROD was signed June
1998 and is considered in cumulative effects. Approximately 482
and 745 acres were considered as reasonable future foreseeable
harvest within the Project Area and WAA 5012, respectively (refer
to Changes Between DEIS and EIS section in Chapter 2).
• Threemile Timber Sale ROD was signed in April of 2004. The
Threemile Timber Sale will harvest approximately 19.5 mmbf on
approximately 665 acres and construct 4.2 miles of new NFS roads
and 4.2 miles of temporary roads.
Cumulative Effects
The cumulative effects analysis area for POG and for low elevation,
high volume POG is WAA 5012. The WAA was selected as the
analysis landscape scale since it is the same scale used for analysis for
most MIS and can be used to compare to Forest Plan data.
Historically, 1 12,677 acres of total POG were available in WAA 5012.
That amount has been reduced to 90,856 acres. This is a 19 percent
reduction (Table 3-11). The action alternatives would reduce POG in
the WAA by two percent for Alternative 2, three percent for
Alternative 3, five percent for Alternative 4 and four percent for
Alternative 5 (Table 3-12). The Crane and Rowan Mountain Timber
Sales EIS prescribed the removal of additional acres for the WAA.
Approximately 659 acres of POG, of which 102 acres are low
elevation, high volume POG, could be harvested within WAA 5012.
42 • Chapter 3
Kuiu Timber Sale FEIS
‘■V:
I
Kuiu Timber Sale
Figure 3-4
Coarse Canopy Forest
Legend
Forest Plan OGR
Productive Old-Growth
Coarse Canopy
Unit Pool
Managed Stands
Non-National Forest
Lakes/Saltwater
Roads in Storage (Closed)
Decommissioned Roads
Existing Open Roads
Project Area Boundary
500ft Contour Interval
800ft Contour Interval
Stream Value Class I & II
Miles
Issue 2: Deer Habitat and Subsistence Use
Cumulatively, this would reduce POG in the WAA by less than one
percent. The Forest Plan predicts that 54 percent of the 1954 POG
habitat will remain at the end of the rotation in WAA 5012 (Forest
Plan, FEIS p. 3-387). Analysis shows that WAA 5012 is well within
this predicted decline.
Past management activities in WAA 5012 have reduced important deer
winter range by 39 percent. All action alternatives would reduce
important deer winter range from the historic condition by less than to
one percent. The reasonably foreseeable harvest of remaining units in
the Crane and Rowan Mountain Timber Sales EIS would further
reduce the important deer winter range in WAA 5012 by an additional
227 acres (all of which would be harvested by helicopter with 50
percent of the stand’s basal area remaining), bringing the cumulative
reduction of high value winter range to between 39 percent for the No-
Action Alternative and 40 percent for Alternative 4.
The Forest Plan predicts that 56 percent of the deer habitat capability
would remain at the end of the rotation (2095) (Forest Plan FEIS Part
1, p. 3-373) in WAA 5012. These changes assume all harvest is even-
aged. The results should be somewhat less for Alternatives 2, 3, and 4
because of the partial harvest prescriptions proposed.
The scoping for this project found that there is concern that timber
harvest on private lands on both Kuiu and Kupreanof Islands has had,
or may have, harmful effects to deer populations on Kuiu Island. There
are very few acres of State or private lands on Kuiu Island. State lands
include the State Marine Park in Security Bay and two town sites in
Rowan Bay and No Name Bay. There may be clearing of the Rowan
Bay site in the future if the State sells lands for a town site. The No
Name Bay site is part of the over-selection and is low on the priority
list of lands the State will select. Harvest will most likely not occur on
the remaining State lands because of the nature of the lands
withdrawn.
The Sealaska Corporation owns lands on the northern portion of Kuiu
in VCU 398. At this time, no harvest has occurred on these lands.
These are small acreages and are not expected to have much impact to
wildlife.
The harvest of private lands on Kupreanof Island around the village of
Kake is extensive. The Native Corporation completing this harvest has
followed the State Forestry Practices Act and has cut what is available.
This large harvest area has had major impacts to deer on Kupreanof
Island but probably has had little effect to Kuiu populations
Kuiu Timber Sale FEIS
Chapter 3 • 45
3 Environment and Effects
With the passage of the Alaska National Interest Lands Conservation
Act (ANILCA), the U.S. Congress recognized the importance of
subsistence resource gathering to the rural communities of Alaska.
ANILCA (16 use 31 130) defines subsistence 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 non-edible byproducts of fish and wildlife
resources taken for personal or family consumption; and for customary
trade.”
ANILCA provides for the continuation of the opportunity for
subsistence uses by rural residents of Alaska, including both Natives
and non-Natives, on public lands. It also set legislation that customary
and traditional subsistence uses of renewable resources shall be the
priority consumptive use of all such resources on the public lands of
Alaska. Non-rural residents are not provided a preference for the
taking of fish and wildlife on public lands.
Kake residents probably use Kuiu Island more than residents of any
other community in Southeast Alaska. They fish, hunt deer and
waterfowl, and gather seaweed, medicinal plants, shellfish, and
berries. Petersburg and Wrangell residents make limited use of the
Project Area and WAA 5012 for hunting deer and commercial fishing.
Other nearby rural communities with reported fish and wildlife
gathering activities in the Project Area and WAA 5012 include Port
Protection, Point Baker, Port Alexander, and Meyers Chuck. Detailed
information on these other communities can be found in the
Subsistence Resource Report available in the planning record.
3.3.5.1 Kake
Kake residents harvest a variety of subsistence resources, documented
in detail through the Tongass Resource Use Cooperative Study
(TRUCS) (Kruse and Frazer 1988). Households in Kake reported they
consume an average of 160 pounds of meat and fish annually. The
subsistence resources most often used are salmon, other finfish and
deer. In terms of pounds of edible harvest, fish constituted 48 percent
of the 1996 total harvest (24 percent salmon, 24 percent other fish),
large mammals 29 percent, marine invertebrates 12 percent, plants five
percent, and birds less than one percent, and five percent unknown.
There is a long history of use of the waters near the Project Area by
Kake residents. The saltwater is heavily used by commercial, sport,
and subsistence users. The stream locally known as Fall Dog Creek is
adjacent to the Project Area and is heavily used by Kake residents for
subsistence fishing and gathering when they are traveling to the Bay of
Pillars. Most of the large streams on Kuiu Island are used by Kake
3.3.5
Community
Subsistence
Profiles
3.3.4
Subsistence
46 • Chapter 3
Kuiu Timber Sale FEIS
3.3.6
Types and
Amounts of
Resources
Gathered
Issue 2: Deer Habitat and Subsistence Use
residents, especially in the Rocky Pass area because of the easy access,
even in inclement weather. These areas are used for hunting, fishing,
and gathering seaweed. Additional information about Kake regarding
employment, income, population, and ethnicity can be found in the
Socioeconomic Specialist report available in the planning record.
3.3. 5.2 Other Community Use
Residents of Port Protection and Point Baker generally use the
southern portion of Kuiu Island and the lower reaches of Keku Strait,
but the Project Area gets some use. Meyers Chuck, Petersburg and
Wrangell residents make limited use of the Project Area for
subsistence purposes.
Summary subsistence harvest information is presented in Table 3-16.
This table displays the total harvest of terrestrial game species from
Kuiu Island for regulatory years 1984-2003. Between 1975 and 1991
Kuiu Island was closed for deer hunting. Most of the subsistence
harvest on Kuiu Island was by Petersburg and Kake residents. The
Sitka black-tailed deer is by far the most important species listed in
this table, followed by black bear and moose. Trapping numbers for
marten and beaver are relatively small and variable. Local patterns are
discussed briefly below. The primary subsistence resource of potential
concern is deer, which will be discussed in more detail.
3.3.6.1 Direct Effects of the Alternatives
Detailed analysis of effects of the proposed activities by alternative for
Sitka black-tailed deer are found earlier in this section and other
wildlife species can be found by species under the Wildlife section of
this chapter.
Sitka Black-tailed Deer
The subsistence evaluation of deer is based on a comparison of supply
and demand. The deer habitat capability model was used in this
analysis for the habitat within WAA 5012. If the demand for deer
exceeds the supply, then a significant possibility of a significant
restriction of a subsistence resource exists.
On Kuiu Island, the subsistence use of WAA 5012 is limited and
variable. In past years, Petersburg and Kake residents heavily hunted
Kuiu Island for deer. As a result of severe winters the deer population
crashed in the early 1970s and the hunting season on Kuiu was closed
from 1975 to 1991. Since 1992 Kuiu Island has been open to hunting
with a two-buck bag limit. During the long hunting closure on Kuiu,
subsistence hunters shifted to Admiralty Island (especially WAAs
3938-3940) and, to a lesser extent, the northern part of Prince of Wales
Island, as well as the nearby mainland. When hunting was again
Kuiu Timber Sale FEIS
Chapter 3 • 47
3 Environment and Effects
Table 3-16. Subsistence harvest of important game species on Kuiu Island
Year
Beaver
Otter
Wolf
Wolverine
Deer
Marten
Black Bear^
Moose
1984
17
40
0
0
N/A
N/A
51
N/A
1985
18
19
4
0
N/A
N/A
66
N/A
1986
14
5
1
0
N/A
N/A
89
N/A
1987
9
3
4
0
N/A
N/A
84
N/A
1988
11
3
3
0
N/A
N/A
118
N/A
1989
2
0
3
0
N/A
N/A
109
N/A
1990
0
0
0
1
N/A
N/A
78
N/A
1991
6
0
7
0
N/A
N/A
77
1
1992
8
0
3
0
N/A
N/A
88
0
1993
0
11
16
0
11
23
121
0
1994
9
9
1
0
24
0
111
0
1995
0
7
8
0
25
51
124
0
1996
0
6
9
0
22
21
131
0
1997
0
7
5
0
13
35
165
0
1998
0
0
8
0
29
15
161
0
1999
0
0
10
0
18
0
168
0
2000
1
0
7
0
27
17
166
0
2001
0
0
3
0
8
0
105
0
2002
0
0
13
0
17
0
112
1
2003
0
0
4
0
7
10
121
0
2004
0
0
0
0
N/A
0
114
0
Average
4
5
5
<1
19
14
112
<1
N/A = Harvest records were not available.
Source; Meucci 2005
' Numbers include sport hunting harvest.
48 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
allowed, the low numbers of deer and their availability did not
persuade hunters to return to Kuiu Island. The deer population is
slowly growing, but it is not advantageous enough at this time for most
hunters to spend their time or energy hunting on Kuiu Island.
Subsistence use areas and the levels of harvest were estimated from a
variety of sources. Data compiled from the ADF&G shows the average
number of deer harvested on Kuiu Island since 1992 when the season
reopened was 18, with a range of 7 to 29 animals harvested. In
contrast, the average for Kupreanof is 174, with a range of 90 to 373.
On Mitkof Island the average is 139 with a range of 64 to 232 during
the same period.
ADF&G estimated hunter demand on Kuiu Island to be 68 deer, based
on estimated annual harvest during the years 1960-1968. These years
represent the demand before the deer population crash in the early
1970s. The minimum number of deer needed to support that demand
indefinitely is 10 times that demand, or 680 deer. This is well within
the capability of the WAA and is therefore considered a sustainable
harvest.
However, testimony from the Crane and Rowan Mountain Timber
Sales EIS, Threemile Timber Sale EIS, and the Kuiu Timber Sale EIS
subsistence hearings indicated that the subsistence hunters did not
always accurately report their location when they were successful at
hunting deer. So while both information from the Forest Plan “Deer
Harvest Map” and Chapter 3: Subsistence and Communities as well as
Tongass Resource Use Cooperative Study (TRUCS) (Kruse and Frazer
1988) has been used, it is recognized that this information may not be
entirely accurate. The following information reflects the testimonies of
subsistence hunters from Kake:
• The Organized Village of Kake feels the 1960s deer use figures
(from ADF&G) substantially underestimate what the use was in
those years, and thus this carries over into underestimating current
and future demand. Several declarations from Kake residents attest
to their remembrance of deer taken from Kuiu during the 1950s
and 1960s. These residents recall that more than 30 deer were
taken by them or their families alone, and others estimate around
80 for an extended family to more than 100 for Kake people.
• Kake residents have pointed out that their recent (since 1975)
reliance on Admiralty Island for deer hunting is not their
preference, and that as the Kuiu herds increase more of their
hunting will shift back to Kuiu Island. Kake residents on average
(based 1993 to 1995) take about 250 deer annually (TEMP
Revision FEIS, Appendix H, p. H-76, based on 75 percent of their
harvest being 185 deer). If all of these deer were harvested from
Kuiu Island the minimum number of deer needed to support that
Kuiu Timber Sale FEIS
Chapter 3 • 49
3 Environment and Effects
demand would be 2,500. Table 3-17 shows that WAA 5012 alone
would be able to meet this demand in all alternatives if the deer
density were at the carrying capacity. At the present time, the deer
numbers are still recovering and the recovery is slow due to the
high black bear and wolf predation on the island.
All action alternatives would result in a reduction of deer habitat
capability. Alternatives 2 and 3 would result in a less than one percent
decline in deer habitat capability. Alternatives 4 and 5 would result in
a one percent decline in deer habitat capability in WAA 5012. WAA
5012 has the habitat capability sufficient to meet the State of Alaska’s
population objectives (680 deer) including the hunter demand for the
people of Kake (2,500 deer).
Table 3-17. Deer habitat capability (deer/mi^) for WAA 5012 by alternative
1954
Alt 1
Alt 2
Alts
Alt 4
Alt 5
Deer density (deer/mi^) to
support wolf and hunter
demand for WAA 5012
37
29
29
29
29
29
Deer density (deer/mi^) to
support wolf and hunter
demand for Kuiu
Biogeographic Province
37
34
34
34
34
34
% Change from current condition
<1%
<1%
1%
1%
Moose
ADF&G harvest records show that moose is not an important
subsistence species on Kuiu Island because only two moose have been
harvested in the past 1 5 years.
Black Bear
The black bear is an important subsistence animal in Southeast Alaska.
In GMU 3, where Kuiu Island is located, the bear is important to
resident and nonresident hunters. There is concern about the Kuiu
Island black bear population and what will happen if timber harvest
continues on the island at its projected rate. Outfitter/Guides are now
advertising their hunts on Kuiu Island as a “World Class Trophy Hunf ’
and are able to command higher prices because of the large bear
population and the large size of the individual animals.
Concern was expressed over the potential competition between
subsistence hunters and nonresident hunters. As a result, the State of
50 • Chapter 3
Kuiu Timber Sale FEIS
Issue 2: Deer Habitat and Subsistence Use
Alaska limited nonresident bear harvest on Kuiu Island to 120 bear per
year in 2001.
Black bears use a variety of habitat types for forage, denning, and
cover. Saltwater and freshwater influence zones are of ecological
importance to bear. None of the alternatives are expected to result in
any restrictions to subsistence harvest of black bear (see the Recreation
section in this chapter).
Furbearers
Past subsistence hearings have indicated that most marten trapping is
by local area residents. Very few people travel to Kuiu Island to hunt
or trap from other communities in Southeast Alaska.
No significant subsistence restrictions on marten are anticipated from
any of the action alternatives. See the Management Indicator Species
section in this chapter for more information on harvest within units of
high value marten habitat.
Fish and Shellfish
Application of Forest Plan riparian standards and guidelines and road
construction Best Management Practices (BMPs) would be expected to
minimize the risk of impact to fish habitat and fish populations. Stream
buffers are specified for all proposed harvest units. Refer to the unit
cards in Appendix B for descriptions of stream buffers and water
quality BMPs. All action alternatives would result in road crossings
across fish streams; however, the effects to fish populations from these
proposed activities should be minor. Refer to the Fisheries section of
this chapter for additional information on stream crossings proposed
for this project.
There are no expected measurable effects on shellfish populations for
all action alternatives. With the exception of the use of the Saginaw or
Rowan Bay LTFs, all proposed activities are located in the uplands,
away from shellfish populations. Use of either LTF would present the
greatest potential for adverse impacts to shellfish, but mitigation
measures specified in the permits for the LTF should reduce these
potential effects.
Subsistence fishing and shellfish harvesting in or near the Project Area
are not likely to be affected by the proposed activities for this project.
As discussed above, the distribution and abundance of these resources
should not change as a result of this project, and any changes in access
or competition for these resources should be minor and of limited
duration.
Kuiu Timber Sale FEIS
Chapter 3*51
3 Environment and Effects
Upland Birds and Waterfowl
Upland game birds, such as grouse, are found throughout the Project
Area.
Waterfowl nesting and breeding areas are adjacent to the Project Area.
Saginaw, Security, and Rowan Bays all provide resting, nesting, and
feeding habitat for waterfowl throughout the year. Rocky Pass, to the
east of the Project Area, provides excellent habitat for waterfowl.
Upland birds do not seem to be affected by increased road access. The
amount of upland bird habitat unaffected by the proposed projects will
support the current populations. Beach, estuary, and riparian buffers
would retain habitat for waterfowl. The Forest Plan Standards and
Guidelines for waterfowl buffers would be applied if necessary to
protect nesting or breeding waterfowl.
No measurable effects on bird populations are expected from any of
the action alternatives.
Upland birds and waterfowl are a small percentage of the foods
harvested by subsistence users. The activities proposed for this project
should not change the distribution, abundance, or use of upland birds
or waterfowl in the Project Area.
Marine Mammals
Forest Plan Standards and Guidelines for protection of marine
mammal habitat would be followed and none of the alternatives is
expected to negatively impact marine mammals. No significant
possibility of a significant restriction to the subsistence use of marine
mammals is expected under any alternative.
Food Plants
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).
However, since Project Area roads are not connected to any
community, little competition for plant foods is anticipated. None of
the alternatives is expected to negatively affect subsistence plant
gathering for food. Reasonably foreseeable effects of the action
alternatives on the abundance and distribution of food plants would be
minimal.
52 • Chapter 3
Kuiu Timber Sale FEIS
3.3.7
Cumulative
Effects
Issue 2: Deer Habitat and Subsistence Use
3.3. 6.2 Access
The primary modes of access include boats, foot travel, cars, and all-
terrain vehicles. The existing road system on Kuiu Island does not
connect directly to any other road systems or the Alaska State Ferry
System, so only minimal impacts due to road use are expected.
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.
Road construction and reconditioning of existing roads may
temporarily increase access in the Project Area, but this effect would
be minimal and the increased access would end when logging is
completed and the roads are returned to storage condition or
decommissioned. Proposed road management objectives would keep
motorized access below its current levels.
3. 3.6.3 Competition
Kake is the only rural community that relies heavily on Kuiu Island for
a substantial portion of its subsistence food needs. As reported earlier,
deer hunting has moved mostly to Admiralty Island, which increases
the competition for deer at that location with other rural communities
and sport hunters. It also changes the historic use of Kuiu Island.
Most furbearer trapping comes during the winter months and is done
from a boat. Kuiu Island is remote and few trappers are able to reach it
reliably during the trapping season. There is no longer a year-round
logging camp and much of the recreational trapping that occurred
when this camp was occupied has stopped.
Competition for upland birds and waterfowl should not be affected by
any of the proposed activities. The number of hunters in the area may
temporarily increase during active logging operations, but long-term
competition would be reduced by road closures and the difficulty in
accessing the area during the spring and fall months when these
animals are normally harvested for food.
None of the action alternatives should have any effect on competition
between rural and non-rural residents since none of the alternatives
would change the existing access patterns to other communities.
Potential conflicts among user groups for subsistence resources would
not vary by alternative.
The Catalog of Events for Kuiu Island was referenced in determining
cumulative effects. Projects considered include the following:
• Forest Service Timber Sale EISs: Threemile Timber Sale EIS
(outside Project Area), and Crane and Rowan Mountain Timber
Sales EIS (within the Project Area),
Kuiu Timber Sale FEIS
Chapter 3 • 53
3 Environment and Effects
• Other Forest Serviee programs such as the provision of personal
use wood,
• Timber offered by other landowners (private, State of Alaska,
Mental Health Trust), and
• General population dynamics.
According to model predictions, WAA 5012 can meet the State of
Alaska’s objectives for a deer population to meet current hunter
demand for all alternatives and meet the Kake subsistence needs as
testified to by residents of Kake.
In recent years, intensive timber management has taken place on
Native Coiporation and National Forest System lands adjacent to Kake
further reducing the winter habitat capability of the nearby areas to
support deer, and increasing the need of Kake subsistence users to
travel further distances to harvest deer. With the deer populations still
low on Kuiu Island, hunters have been traveling to Admiralty Island,
which is an increased risk to the hunters, as the distance is further and
Fredrick Sound can be dangerous to cross during the winter months.
Finally, looking into the future, the current habitat capability is
estimated to decline by about two percent over the next 30 years.
The analysis for this project indicates that for any action alternative,
the proposed timber harvest, in combination with past and reasonably
foreseeable future timber harvest, will not likely result in a significant
possibility of a significant restriction of subsistence resources.
The Forest Plan addressed the long-term consequences on subsistence
and concluded that full implementation of the Forest Plan may result
in a significant possibility of a significant restriction to subsistence use
of deer due to the potential effects of projects on the abundance and
distribution of deer, and on competition for deer (Forest Plan ROD, p.
24). At this time this restriction is not anticipated in the reasonably
foreseeable future for the following reasons:
• The Forest Plan analysis was based on full implementation of the
Forest Plan by 2095. Forest Plan FEIS (p. 3-373) predicts that
WAA 5012 will retain 56 percent of the 1954 deer habitat
capability (compared to 80 percent in 1995). These projections
were made using the assumption that the Forest Plan would be
implemented in its entirety (most harvest completed using even-
aged management, clearcutting).
• To date, planned timber harvest on Kuiu Island has had less impact
on wildlife habitat values than predicted because modified
prescriptions have reduced the use of clearcutting as the major
method for cutting trees.
54 • Chapter 3
Kuiu Timber Sale FEIS
3.3.8
Conclusions
and Findings
Issue 2: Deer Habitat and Subsistence Use
• The Forest Plan assumed an 18 percent increase in community
population growth for each of the first two decades and a 1 5
percent increase for each of the next three decades (Forest Plan
FEIS Part 2, p. 3-528).
• Populations in Southeast Alaska have actually declined an average
of three percent between 1995 and 2003.
Given the above rationale, it is likely that this restriction, if it occurs,
would occur somewhat later than predicted.
At some time in the future, if projected human population increases
occur, and as habitat degradation (reduced deer habitat capability)
increases, the demand for deer for all hunters (subsistence plus sport)
may well exceed supply. At that time, a restriction on sport hunting
may be required to ensure the availability of adequate subsistence
resources needed by rural communities (Forest Plan FEIS Part 2, p. 3-
625). Until that time, cumulative effects on subsistence use patterns of
Kuiu Island by rural residents are expected to remain unaltered.
Cumulative effects from past actions, the proposed action, and
reasonably foreseeable future activities within WAA 5012 are not
expected to result in a significant restriction of subsistence uses of
Sitka black-tailed deer, black bear, moose, furbearers, marine
mammals, upland birds, waterfowl, salmon, other finfish, shellfish, or
other foods.
Based on the habitat modeling and subsistence deer harvest reported
by the ADF&G, the Federal Subsistence Program, and the Forest Plan,
the current level of subsistence deer harvest (1992-2005) can be
achieved for any of the alternatives within the WAA.
Subsistence hearings were held in Petersburg on March 16, 2006 and
in Kake on March 21, 2006; written comments were accepted. Three
people testified in Petersburg and one person testified in Kake.
Kuiu Timber Sale FEIS
Chapter 3 • 55
3.4.1
Introduction
3.4 Issue 3 - Timber Sale Economics
Timber purchasers and affected communities are concerned about the
quantity, quality, frequency, and profitability of timber offered for sale
from the Tongass National Forest. Additionally, there is a concern how
an unstable supply affects communities through primary and
secondary employment and support.
Some comments that were received during the scoping period offered
suggestions for improving overall timber harvest economics on the
Tongass National Forest. Suggestions included; 1) meet the Forest
Plan Allowable Sale Quantity to ensure adequate supply; 2) provide
economic sales that allow adequate profit for both small and medium-
sized businesses; 3) limit the use of helicopter yarding; 4) minimize
the use of partial harvest; and 5 ) minimize road construction.
3.4.1. 1 Methods
Data used in preparation of this analysis was gathered through field
evaluations, GIS analysis and mapping and Region 10 approved
models.
NEPA Economic Analysis Tool Residual Value (NEAT_R)
NEAT_R (Version 2.10) was used to analyze the alternatives based on
the Residual Value Appraisal (RV) (FSH 2409.22) information
combined with project-specific infonnation to produce an estimate of
net volume, costs, jobs, and relative bid value for the alternatives
presented. At the time of this FEIS, the NEAT_R model was updated
to reflect the new residual value appraisal system and the Limited
Interstate Commerce Shipping policy. NEAT_R is a model designed to
show the financial differences between alternatives to help the
decision maker see the economic implications of the decision.
NEAT_R is not intended to display a final appraised stumpage of an
individual timber sale. Before a timber sale is advertised, it is
appraised to estimate the fair market value and when a timber sale is
offered, it is offered competitively with the contract normally awarded
to the highest bidder. These requirements help ensure that the
government receives a fair market value for any timber it sells. For
further details on the NEAT_R model, see the Timber Economics
Resource Report available in the planning record.
Road Construction CostsILogging Costs
The economic analysis process calculates net stumpage values from
costs collected from current timber sale purchasers. The estimated
stumpage value for any given sale is based on these collected costs,
with adjustments for sale specific data. Logging costs (stump-to-truck
56 • Chapter 3
Kuiu Timber Sale FEIS
3.4.2
Changes
between DEIS
and FEIS
3.4.3
Environmental
Consequences
Issue 3: Timber Sale Economics
costs) vary by quality and quantity of timber per acre. Logging costs
include timber falling, bucking, and yarding. The net stumpage values
vary by volume and species composition, timber quality, silviculture
prescriptions, logging systems, and type and amount of road
construction.
3.4.1. 2 Analysis Area
The Kuiu Timber Sale analysis area includes approximately 46,102
acres of land. This land is comprised of the project unit pool, along
with all surrounding forestland that, if harvested, would logically be
brought to the project’s road system and hauled to either Rowan Bay
LTF or Saginaw Bay LTF. For a detailed description of the Project
Area refer to Chapter 1, Description of the Project Area (1.6).
Changes identified between the Draft and Final EIS have made it
necessary to update the logging system and timber sale economics
analysis for the Kuiu Timber Sale. These changes included the
exclusion of MMI-4 soils from certain alternatives and within units,
and the changes in economics (see Changes Made Between the Draft
EIS and the Final EIS in Chapter 2).
The changes in the economic condition have made the most significant
impact to the economic feasibility of the alternatives analyzed for the
Kuiu Timber Sale. In the DEIS all action alternatives were
economically positive. While all alternatives are now economically
negative, the relative ranking of the alternatives has not changed.
Alternative 5 remains the most economical.
As shown between the DEIS and the FEIS, timber markets and values
tend to fluctuate dramatically. Because of these market fluctuations, it
is good management to have timber volume cleared through the NEPA
process to be available for sale when favorable markets exist.
This section compares the costs and benefits than can be quantified in
terms of actual dollars spent or received with the sale of any
alternative. These costs consider the following factors; volume offered,
logging costs, stumpage values (predicted bid per unit of measure),
and direct employment.
3.4.3.1 ASQ and Non-Interchangeable Components (NIC)
The allowable sale quantity (ASQ) is the amount of timber that can be
sold from lands suitable for timber production by decade for a
National Forest. It is divided into two non-interchangeable
components (NIC I and NIC II) based on economic factors. Timber
harvest is more economic on NIC I lands than it is on NIC II lands. For
the Project Area all of the proposed timber harvest units are on NIC I
lands (see the Transportation section in this chapter). Refer to
Appendix A for more information about the ASQ.
Kuiu Timber Sale FEIS
Chapter 3 • 57
3 Environment and Effects
S.4.3.2 Payments to the State of Alaska
Prior to 2000, in states with national forests, 25 percent of the returns
to the US Treasury from revenue producing activities such as timber
sales were returned to each state for distribution to counties (or in
Alaska, boroughs) having national forest within their boundaries.
Those payments were commonly referred to as the 25 percent fund and
by law were dedicated to funding schools and roads. Under that
approach, as specific revenues from national forest lands increased or
decreased so did the payments to states.
In October 2000, the Secure Rural Schools and Community Self-
Determination Act was enacted to stabilize those federal payments to
states in response to declining federal receipts from national forests.
The legislation was originally authorized for implementation from
2001 through 2006. In May 2007, emergency supplemental legislation
extended the legislation for one year, for fiscal year 2007.
Under the Secure Rural Schools legislation, payments to the state are
not linked to actual annual revenues from national forest lands, rather
they are based on a high 3 year historic average. As a result during the
period 2001 through 2006, Alaska received payments of
approximately $9 million per year, primarily for schools and roads,
with provisions for special project funding to boroughs who decide to
convene citizen committees, called RACs, or Resource Advisory
Committees.
For fiscal year 2007, payments to states continue to follow the
direction in the Secure Rural Schools legislation. Under that approach,
funding to states is based on a historic high 3 year average. If that
legislation is not extended or reauthorized, payments will revert back
to the 25 percent approach, which means funding amounts would
increase or decrease as revenue generating activities, like timber sales,
increase or decrease.
3.4.3.S Volume Estimates
Volume calculations for this economic analysis are based on
information from stand exams and historic timber sale cruise statistics.
Volumes for the alternatives are displayed in thousand board feet
(mbf) in Table 3-52 in the Timber and Vegetation section of this
chapter. The sum of unit volumes by species is also factored into the
economic analysis. Table 3-52 also displays the species composition in
proposed harvest units for each action alternative.
Based on averages for the Petersburg Ranger District, volume
classification for the suitable and available productive forest land is
estimated for the Project Area and is displayed in Table 3-18.
58 • Chapter 3
Kuiu Timber Sale FEIS
Issue 3: Timber Sale Economics
Detailed explanations of the rationale for considering timber harvest in
the Project Area and market demand for wood products is located in
Appendix A. More information can also be found in the Forest Plan
FEIS, Part 1 (pp. 3-248 to 3-307).
Table 3-18. Suitable and available productive forest land strata and
volume estimates for the Kuiu Project Area
Volstrata
Percentage
Acres
Sawlog
mbf/acre
Sawlog
mmbf
Sawlog &
utility
mbf/acre
Sawlog
& Utility
mmbf
Low
2%
454
16.9
27
18.9
31
Medium
18%
3,790
24.1
123
27.5
140
High
78%
16,082
29.3
482
33.4
549
None®
2%
382
Total
100%
20,708
632
720
These acres are “holes” in the GIS layer and represent forested areas of unknown volume quality or
small inclusions of non-forest land.
3.4.3.4 Road Construction Costs/Logging Costs
This analysis compares estimated costs and net stumpage values for
transporting the logs to both Rowan Bay LTF (Table 3-19) and
Saginaw Bay LTF (Table 3-20) and estimates a relative bid value for
each action alternative (Table 3-21).
The differences in logging costs and the estimated bid among the
action alternatives can be attributed to multiple factors, including:
• Differences in species composition, volume per acre harvested, and
timber quality,
• Differences in harvest prescriptions,
• Differences in yarding systems,
• Amount of temporary road construction,
• Differences in haul distances, and
• Unique costs associated with the alternative.
The towing/barging cost is appraised to the nearest production site for
all sawlogs and utility wood. All alternatives were appraised assuming
towing/barging to the same production site in Sawmill Cove,
Wrangell, Alaska, which is the closest facility that could handle the
total sale volume. Road costs include the construction of new NFS and
Kuiu Timber Sale FEIS
Chapter 3 • 59
3 Environment and Effects
temporary roads and the reconditioning and maintenance of NFS
roads.
Table 3-19. NEAT_R logging costs by alternative for haul to Rowan Bay LTF
Cost Item
Alternatives
Ait 1
Alt 2
Alt 3
Alt 4
Alts
Stump-to-truck
$ per mbf
N/A
$168.36
$172.90
$181.96
$171.30
Haul, barge, tow
$ per mbf
N/A
$126.70
$132.48
$126.96
$134.18
Road
Maintenance
$ per mbf
N/A
$29.70
$20.38
$23.54
$7.41
Unusual
Adjustments®
$ per mbf
N/A
$12.31
$11.77
$11.34
$11.37
Road Costs
$ per mbf
N/A
$59.94
$79.52
$49.28
$54.09
Total
$ per mbf
N/A
$397.01
$417.05
$393.08
$378.35
Unusual adjustments are estimates for surface replacement deposits, camp days, and camp setup costs.
Table 3-20. NEAT_R logging costs by alternative for haul to Saginaw Bay LTF
Cost Item
Alternatives
Altl
Alt 2
Alt 3
Alt 4
Alts
Stump-to-truck
$ per mbf
N/A
$168.36
$172.90
$181.96
$171.30
Haul, barge, tow
$ per mbf
N/A
$111.53
$116.52
$112.98
$119.34
Road Maintenance
$ per mbf
N/A
$23.23
$15.29
$19.14
$5.19
Unusual Adjustments®
$ per mbf
N/A
$12.31
$11.77
$11.34
$11.37
Road Costs
$ per mbf
N/A
$59.94
$79.52
$49.28
$54.09
Total
$ per mbf
N/A
$375.37
$396.00
$374.70
$361.29
Unusual adjustments are estimates for surface replacement deposits, camp days, and camp setup costs and include costs
associated with the reconstruction of Saginaw Bay LTF.
60 • Chapter 3
Kuiu Timber Sale FEIS
Issue 3: Timber Sale Economics
Table 3-21. Volume by alternative and expected bid to Rowan Bay and Saginaw
Bay LTFs
Alternative
Volume
Indicated Bid/MBF
Expected Bid/MBF
MBF
NEAT_R Rowan
NEAT_R Saginaw
Alt 1
0
$0.00
$0.00
Alt 2
9,617
$(157.99)
$(136.27)
Alt 3
15,859
$(179.99)
$(158.94)
Alt 4
33,300
$(155.11)
$(136.71)
Alts
31,354
$(141.28)
$(126.92)
3.4.3.S Harvest Prescriptions
In general, the more volume per aere removed from a stand, the lower
the per-unit logging cost. Table 3-22 displays the acres of harvest by
prescription for each alternative.
Table 3-22. Acres of harvest prescriptions by alternative
Harvest System
Alternative
Alt 1
Alt 2
Alt 3
Alt 4
Alts
Even-aged management
(clearcut)
0
197
409
1,025
1,208
Two-aged management
(clearcut with reserves)
0
175
286
128
0
Uneven-aged management
(single tree selection)
0
87
72
193
0
Uneven-aged management
(group selection)
0
19
19
41
0
Total
0
478
786
1,387
1,208
3.4.3. 6 Logging Systems
Three different yarding systems are proposed in the Project Area.
Total acres by yarding system are shown in Table 3-23. Proposed
Kuiu Timber Sale FEIS
Chapter 3*61
3 Environment and Effects
yarding methods for individual units are noted on the unit cards
(Appendix B).
Table 3-23. Acres of proposed timber harvest by yarding
system
Harvest System
Alternative
Alt 1
Alt 2
Alt 3
Alt 4
Alts
Cable
0
395
751
1,092
1,059
Shovel
0
83
35
147
149
Helicopter
0
0
0
148
0
Total
0
478
786
1,387
1,208
Cable yarding
Cable yarding systems are best suited for steep slopes and wet soils.
Cable systems minimize soil disturbance by partially or fully
suspending the logs over the ground. Cable yarding is not suitable for
all silvicultural prescriptions. Cable systems can be more limited when
compared to the other systems because a clear path is needed to pull
the logs to the landing.
Cable yarding is most efficient with clearcut systems. Two-aged and
uneven-aged silvicultural systems are possible, but the tower for the
cable system needs to be moved more often, which increases costs.
Downhill yarding with cable yarding systems require open areas to
reduce the risk of injury to logging crews, since there is less control of
the logs as they approach the landings. Uphill yarding gives more
flexibility, especially if a lateral carriage is used to bring the logs from
the sides to the middle of the corridor. Extra care is needed to protect
the remaining trees in a partial harvest.
Among the action alternatives. Alternative 4 proposes the most cable
logging, followed in descending order by Alternative 5, Alternative 3,
and Alternative 2.
Shovel yarding
Track mounted log loaders (shovels) have been used throughout the
Tongass National Forest where the slope is generally less than 20
percent. Placing slash underneath the tracks as the loader moves
through the unit provides a mat to displace the weight of the
equipment over a larger surface area, which minimizes the possibility
of soil compaction.
62 • Chapter 3
Kuiu Timber Sale FEIS
Issue 3: Timber Sale Economics
Shovel yarding is limited to roadsides. The average yarding distance
on each side of the road has been 700 feet. Recently, however,
distances of up to 900 feet have been shovel yarded. In many units,
shovel yarding is used for the timber near the road and the rest of the
unit is cable logged. Shovel logging does provide flexibility in the
selection of trees to be harvested. Shovel yarding is the least costly
yarding method used in this analysis.
Among the action alternatives. Alternative 5 proposes the most shovel
logging, followed in descending order by Alternative 4, Alternative 2,
and Alternative 3.
Helicopter yarding
Helicopter yarding is the most expensive yarding method due to the
high costs associated with operating and overhead. Many factors
influence the economic viability of helicopter yarding. They include,
but are not limited to: yarding distance, turn time, fuel costs, and the
value of the timber harvested.
Helicopter yarding can have an extreme effect on the economic
viability of an alternative. However, higher quality timber in
combination with short yarding distances could result in an economic
alternative with helicopter yarding requirements.
Helicopter yarding is best suited for units where NFS or temporary
roads cannot be constructed to access suitable timber areas and is the
least ground disturbing yarding method. Helicopter yarding also
allows for partial harvest silviculture prescriptions.
Alternative 4 is the only alternative that proposes helicopter yarding.
S.4.3.7 Small Sales
Maintaining a consistent small sale offering is a component of the
Petersburg Ranger District timber sale program. Due to the distance of
the Project Area from processors, it is unlikely individual units would
be offered for sale.
Small Business Administration Program
The Forest Service and the Small Business Administration review
market demand and supply and agree on an annual amount of volume
to be offered to small businesses from the Tongass National Forest.
Once the Record of Decision is signed, any changes in timber sales
offered would be reflected in an update to the Tongass National Forest
5 -year sale schedule and the Periodic Timber Sale Announcement for
timber sale schedules which is available upon request. All of the mills
in Southeast Alaska currently qualify as small businesses.
Kuiu Timber Sale FEIS
Chapter 3 • 63
3 Environment and Effects
3.4.3. 8 Employment
Any of the proposed action alternatives could generate or maintain
employment and income in Southeast Alaska as a result of timber
harvest, if timber is offered and sold (Table 3-24). All action
alternatives would provide diverse opportunities, including direct and
indirect employment. Direct jobs are logging, construction, marine
transport, and processing. Indirect employment refers to businesses
supporting the wood products industry. Historically, Alaska yellow-
cedar has been exported and it is unlikely this pattern will change in
the near future. In March 2007 the Regional Forester approved a new
limited interstate commerce shipping policy. Shipments will be 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, unless the Regional Forester expressly grants an
exception in advance on case-specific unusual circumstances.
In Southeast Alaska, sawmilling results in 4.31 annualized jobs per
MMBF and logging results in 2.07 annualized jobs per MMBF. This
data is based on 2000 to 2004 data and on total volume sold on the
Tongass National Forest (Alexander 2006). The estimate of the
sawmilling jobs was taken into account by the NEAT_R analysis
model (Version 2.10).
Predictably, the higher the volume of timber available and sold, the
more jobs and income generated. The Forest Plan FEIS, which bases
its employment figures on the Tongass-wide timber base, has indicated
the estimated number of available jobs expected for the planning
period.
Table 3-24. Logging and Milling Related Employment and Income
Alt 2
Alt 3
Alt 4
Alts
A.
Direct employment (Job Years)
61
100
111
198
B.
Total Direct income (Millions $)
3.39
5.60
9.95
8.54
A = Job year (one year job = full time 12 month job equivalent) per harvest. Averages on file with
Regional Economist. Range accounts for the interstate commerce policy.
B = Gross income per harvest estimate. Average on file with Regional Economist.
3.4.3.9 Administrative Project Costs
The costs and management expenses include environmental analysis,
sale preparation, sale administration, and engineering support. Forest
Service cost per thousand board feet (mbf) is based on the Region 10
average budget allocation of $48.16/mbf for analysis, $25.76/mbf for
64 • Chapter 3
Kuiu Timber Sale FEIS
3.4.4
Direct and
Indirect
Effects
Issue 3; Timber Sale Economics
sale preparation, $10.08/mbf for sale administration, and $28.00/mbf
for engineering support.
Environmental Analysis
Environmental analysis costs include field inventory and the analysis
of data, public involvement, and the preparation of a document that
satisfies the requirements of the National Environmental Policy Act.
Although it is based on timber volume, the cost fluctuates more with
the amount of area to be examined and the accessibility of that area.
The Project Area is accessible by helicopter, floatplane or boat, and is
located on Kuiu Island on the Petersburg Ranger District. The
environmental analysis cost is constant based on the proposed action
and applies to all alternatives, including the No-Action alternative.
Sale Administration
Sale administration costs are higher when helicopter logging is
involved because of the increased cost of accessing the timber harvest
for administration. Scattered and smaller harvest areas are more costly
to visit. Alternative 4 would have higher costs than the other action
alternatives because of the higher sale administration costs for
helicopter yarding. Alternative 5 would be the next most costly.
Sale Preparation
Unit layout and cmising costs increase significantly when partial
harvest is prescribed compared to clearcutting. The Altematives-to-
clearcutting Research Study on Kupreanof Island required about eight
times more person-days to prepare a unit that involved marking
individual trees throughout the unit compared to a clearcut unit.
Designation of two-acre patches took about four times longer than a
clearcut. Accessibility to the units is another major cost factor.
Helicopter access and steeper terrain increase sale preparation costs
compared to areas with existing road access.
Using these cost factors. Alternative 2 would be the least costly to
prepare. Alternatives 3 and 5 would be more costly than 2. Alternative
4 would be the most costly because it has the most acres of two-aged
and uneven-aged management stands.
3.4.4.1 Financial Analysis
Economic efficiency analysis or cost/benefit analysis is best done at a
scale much larger than a project area. A regional scale economic
analysis is presented in the Forest Plan FEIS Part 2, which balances
resource uses and values for the Tongass National Forest. The
economic analysis compares the costs and benefits of all resources,
whether or not these costs and benefits are realized as an explicit
Kuiu Timber Sale FEIS
Chapter 3 • 65
3 Environment and Effects
market price. This analysis considers a variety of positive and negative
resource-related external factors, passive use, non-consumptive use,
and opportunity costs at various scales.
An economic efficiency analysis includes benefits and costs that are
not easily valued through the market or exchange of money, and can
be difficult to quantify or summarize. Often, the same impact may be
considered a cost to some and a benefit to others, depending on
individual values. The analysis in this document tiers to the analysis
done in the Forest Plan for non-commodity resources. Direct effects of
the Kuiu project for economic sectors are displayed in the previous
tables to the extent that they are known.
Alternative 1, No-Action, would maintain the current level of
opportunities other than timber harvest for resource use. Those people
interested in maintaining unroaded areas, primitive recreation
opportunities, current levels of roaded access, and scenery would have
the same condition in the near future as they have now. Those
interested in using or expanding roaded recreation and access, or
increasing wood product resource uses, would also have the same
opportunities in the near future as they do now.
All action alternatives would cause changes to the existing economic
conditions. These changes are described as increases or decreases in
opportunities, benefits, or costs. In general, alternatives with lower
harvest levels tend to have less impact on other resources when
compared to those with higher levels. Many of the costs are short-
term, lasting only as long as the timber sale is active. Noise, LTF
activity, and increased traffic are examples of short-term impacts.
Other costs have more long-term effects. Road development, visual
changes to harvest units, increased access, and scenery changes are
impacts that would remain after timber harvest.
3.4.4.2 Effects common to all action alternatives
Alternatives 2, 3, 4, and 5 were designed to satisfy the Purpose and
Need and address the significant issues. This project is consistent with
the management goals and desired conditions for Timber Production
LUDs. Unit designs address specialists concerns, such as wildlife
habitat, visual landscape, and sensitive soils. Yarding systems were
assigned through field verification and cost considerations. The current
export policy for the Tongass National Forest allows for the export of
Alaskan yellow cedar and limited interstate shipments.
In all alternatives, no NIC II ground is harvested. All action
alternatives would include small roadside landings constructed to
widen existing roads for log yarding and decking operations. The
timber from all action alternatives was analyzed assuming it would be
66 • Chapter 3
Kuiu Timber Sale FEIS
Issue 3: Timber Sale Economics
barged or rafted to Wrangell from either Rowan Bay or Saginaw Bay
LTF.
All action alternatives contribute to the Tongass National Forest’s
orderly flow of timber by providing timber for sale that can be
adjusted to coincide with the latest market conditions.
S.4.4.3 Effects by Alternative
Alternative 1
No timber would be harvested. In order to meet the estimated demand
for timber, more timber may need to be harvested elsewhere on the
Tongass National Forest. This alternative would provide no
opportunities for local wood products employment, and no return to
the U.S. Treasury. There would be no small sales offered for local
operators. There would be no effect on commercial recreation use,
commercial fisheries, or the current level of opportunities, other than
timber harvest, for resource use. Alternative 1 does not propose to do
any timber harvest or road construction, so there would be no other
costs.
Alternative 2
This alternative proposes to harvest 9,617 mbf using shovel and cable
yarding systems. This alternative would harvest the lowest volume of
the four action alternatives.
Estimated logging costs to Rowan Bay LTF would be $397.10/mbf
and $375.38/mbf to Saginaw Bay LTF. The predicted bid is a negative
$157.99/mbf for Rowan Bay LTF and a negative $136.27/mbf for
Saginaw Bay LTF. About 61 direct jobs would be maintained with this
alternative.
Alternative 3
This alternative proposes to harvest 15,859 mbf using shovel and cable
yarding systems. This alternative represents the least economic
alternative of the four action alternatives with an estimated logging
cost to Rowan Bay LTF of $417.05/mbf and $396.00/mbf to Saginaw
Bay LTF.
The predicted bid is a negative $179.99/mbf for Rowan Bay LTF and a
negative $158.94/mbf for Saginaw Bay LTF. About 100 direct jobs
would be maintained with this alternative.
Alternative 4
This alternative proposes to harvest 33,300 mbf (the highest volume of
the alternatives) using shovel, cable, and helicopter yarding systems. It
Kuiu Timber Sale FEIS
Chapter 3 • 67
3 Environment and Effects
is the only alternative that would require the use of helicopter yarding
systems.
Estimated logging costs to Rowan Bay LTF would be $393.10/mbf
and $374.70/mbf to Saginaw Bay. The predicted bid is a negative
$155.1 1/mbf for Rowan Bay LTF and a negative $136.71/mbf for
Saginaw Bay LTF. About 21 1 direct jobs would be maintained with
this alternative.
Alternative 5
This alternative proposes to harvest 31,354 mbf using shovel and cable
yarding systems. It is the only alternative that proposes clearcut
prescription for all units and is therefore the most economical.
Estimated logging costs to Rowan Bay LTF would be $378.35/mbf
and $361.28/mbf to Saginaw Bay. The predicted bid is negative
$141.28/mbf for Rowan Bay LTF and negative $126.92/mbf for
Saginaw Bay LTF. About 198 direct jobs would be maintained with
this alternative.
3.4.5.1 Alternative 1
No timber would be harvested from the Project Area. Timber needed
to meet estimated demand would have to be harvested from other areas
on the Tongass National Forest.
3.4.5.2 Alternatives 2, 3, 4, and 5
These alternatives would help contribute to a stable timber industry in
Southeast Alaska, which depends on a steady flow of economic timber
sales in order for operators to make investments in machinery and to
employ qualified workers. All action alternatives would contribute to
supplying timber sales to meet market demand. Volume from the Kuiu
Timber Sale Area, in combination with other timber sales offered on
the Tongass National Forest, would contribute to a stable long-term
timber supply. A 5-year Timber Sale Plan on Kuiu Island has been
approved by the Forest Supervisor.
Other timber sale projects on Kuiu Island include volume analyzed in
the Crane and Rowan Mountain Timber Sales EIS (July 1998) and the
Threemile EIS.
3.4.5
Cumulative
Effects
68 • Chapter 3
Kuiu Timber Sale FEIS
3.5 Issue 4 - Cumulative Effects of
Logging and Road Construction on
Watersheds
3.5.1
Introduction
Kuiu Island is subject to the State of Alaska Water Quality Standards
(18 AAC 70), which are set according to protected water use classes
and subclasses. Protected water use classes for freshwater include: 1)
water supply, 2) water recreation, and 3) growth and propagation of
fish, shellfish, other aquatic life, and wildlife. The fresh waters of Kuiu
Island are used primarily for water recreation and growth and
propagation of fish, shellfish, other aquatic life, and wildlife. There is
one special use permit at Saginaw Bay for private use and some use of
water at the Forest Service camp at Rowan Bay.
The Forest Plan guides the management of soil and water resources on
the Tongass National Forest. Appendix J of the Forest Plan describes
the need for watershed analysis, defines the core topics of the
watershed analysis, and guides the scale and intensity of the analysis.
The scale, intensity, and complexity of the watershed analysis are to be
commensurate with the level of cumulative risk. The following
characteristics are used to determine whether a watershed may receive
a more intensive, complex, and field-based watershed analysis:
• High value fish habitat,
• High sediment yield risks or erosion potential,
• Extensive very high and high hazard soils,
• Presence of threatened, endangered, or sensitive species,
• More than 20 percent of the watershed acres with trees in second-
growth younger than 30 years, or
• A high density of roads and stream crossings.
The Kuiu Timber Sale proposes timber harvest and road building in
many previously harvested watersheds on Kuiu Island. All of the
major watersheds within the Project Area have streams with high value
fish habitat. Three of the watersheds within the Project Area have near
20 percent or greater cumulative harvest levels over the last 30 years,
and there is a high potential for changes in stream channel conditions
This section describes the watersheds affected by the proposed Kuiu
Timber Sale, and provides an analysis of the effects of the proposed
activities on watershed resources. A detailed description of the
watersheds affected by this project can be found in the project
planning record.
Kuiu Timber Sale FEIS
Chapter 3 • 69
3 Environment and Effects
if sediment loads increase. Public comments generated from scoping
for the Kuiii Timber Sale indicate that some people are concerned
about the possibility of negative cumulative watershed effects resulting
from the proposed project. To address the issue of cumulative
watershed effects, and to follow the intent of the Forest Plan, a detailed
watershed analysis was completed for the watersheds affected by
proposed activities (analysis is located in the project planning record).
The watershed analysis includes the elements of a six step process
outlined in Ecosystem Analysis at the Watershed Scale (Regional
Interagency Executive Committee 1995). The six step process
includes: 1 ) characterization of the watershed, 2) identification of
issues and key questions, 3) description of current conditions, 4)
description of reference conditions, 5) synthesis and interpretation of
infonnation, and 6) recommendations.
Different components of the watershed analysis are framed within
different time scales, depending on what is being analyzed, and what
supporting documentation is being used (Table 3-25).
Table 3-25 Com
ponents of the Watershed Analysis
Analysis
component
Timeframe
for analysis
Interpretation
Rationale
Source
Percent of
watershed in
second growth
Within last 30
years
Greater than 20%
indicates need for
detailed watershed
analysis
Conservative
timeframe ensures
appropriate detail
Forest Plan,
Appendix J
Acres of second
growth in
watershed
Within last 20
years
Treated as possible
source area for
landslide in sediment
risk analysis
Research indicates
logging increases
landslide
susceptibility for
about 20 years
Brardinoni et al.
2002
Acres of road
within watershed
No time limit,
all roads
included
Treated as possible
source area for
landslide in sediment
risk analysis
Increased landslide
susceptibility
associated with
roads may persist
for decades,
depending on many
factors
Brardinoni et al.
2002
In this document, a basic watershed analysis is presented for all
watersheds that could be affected by proposed activities. The basic
watershed analysis includes a Sediment Risk Assessment, the details
of which are described below. For watersheds that have had greater
than 20 percent cumulative harvest within the last 30 years, a more
detailed watershed analysis is presented. For these watersheds, the
70 • Chapter 3
Kuiu Timber Sale FEIS
3.5.2
Area of
Analysis
3.5.3
Methods
Issue 4: Cumulative Effects on Watersheds
analysis incorporates the results of detailed, field-based assessments of
stream channel condition. The criteria for these assessments are
described below.
The spatial analysis area for the assessment of all direct, indirect, and
cumulative effects to watershed resources in the Project Area includes
the entire Dean Creek, Saginaw Creek, Security Creek, Rowan Creek
and Kadake Creek watersheds, and unnamed watersheds #109-45-
10090 and #109-44-10370. The watershed boundaries correspond to
the 6th level Hydrologic Unit Code (HUC), and all are true
watersheds, meaning that each watershed is well defined by
topographic boundaries and all surface water within the watershed
drains to a single stream or river.
The seven watershed listed above were selected as the area of analysis
because the watershed boundaries are large enough to allow a
comprehensive accounting of all activities that affect current and
future watershed conditions, yet small enough to allow the analysis to
be sensitive to the potential effects of the proposed activities (Regional
Interagency Executive Committee 1995).
Temporally, cumulative watershed effects may be influenced by some
of the activities summarized in the Kuiu Catalog of Events. In this
analysis, emphasis was given to timber harvest activities in the past 30
years and road building activities regardless of age. Both activities are
known to potentially effect changes in peak flow, timing of runoff, and
sediment delivery to streams.
3.5.3. 1 Sediment Risk Assessment
The Sediment Risk Assessment (SRA) was developed for use in
Southeast Alaska (Geier 1998) and the information presented in this
document originally appeared in the Kuiu Island Landscape
Assessment (USDA 2005). This tool integrates stream, soil and
watershed characteristics to facilitate a comparison of the relative
potential for sediment-related changes in stream channels to occur
among a group of watersheds. Because the assessment tool is designed
to compare the relative sediment risk among groups of watersheds, it is
most appropriately used at large scales where there are many
watersheds with varying morphology.
The basic assumptions of the Sediment Risk Assessment are:
• The potential for sediment delivery to streams (transport potential)
in a watershed increases with higher density of steep slopes,
unstable soils, harvest areas, and roads.
• The higher the density of low-gradient, sediment-storing stream
channels in a watershed (storage potential), the greater the chance
Kuiu Timber Sale FEIS
Chapter 3 • 71
3 Environment and Effects
that sediment inputs to streams will eause ehanges sueh as ehannel
widening or pool filling.
This analysis results in the sediment risk index (SRI), which ranges
from very low to very high (Table 3-26). The SRI is highest where
there are combinations of high transport potential in headwaters areas
of watersheds and high storage potential in the lower portions of
watersheds.
Table 3-26. Interpretation of the Sediment Risk Index (SRI)
SRI Percentile
SRI Ranking
Greater than 90**^
Very High
Between 75*^ and 90*'^
High
Between and 75‘^
Moderate
Between 25*^ and 50'*^
Low
Less than 25*'^
Very low
The SRA was run twice for the Kuiu Island Landscape Assessment,
and a third time for this proposed timber sale. The first run did not
account for timber harvest and road building. This provides an
assessment of the inherent risk of sediment effects to streams based
solely on the natural characteristics of the watershed and the stream
network. The second run of the SRA accounted for all roads and
landings, regardless of their age, and all timber harvest occurring
within the past 20 years. Except for roads and landings, timber harvest
that occurred more than 20 years ago was not accounted for because
harvested slopes are expected to recover rooting strength in the soil
and stabilize after a 20-year period (Brardinoni et al. 2002). The
second run of the SRA was used to describe the current condition of
the watersheds analyzed. The third run accounts for proposed harvest
and road building associated with each alternative. Relative levels of
sediment delivery risk from the second and third runs of the SRA
change as cumulative harvest levels increase or decrease. Since most
timber harvest in the Kuiu watersheds occurred in the 1970s- 1980s,
cumulative harvest levels are declining and SRI values are trending
toward inherent levels. Results of the third run are presented below
under each alternative.
The SRA highlights the variations in watersheds on Kuiu Island with
regard to watershed morphology, stream channel morphology,
topography, and soil characteristics. These variations demonstrate why
landslides and sediment-related changes to stream channels, such as
pool filling or channel widening, are more likely in some watersheds
72 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
than others on Kuiu Island. This is consistent with findings from
research on landslide frequency (Swanston and Marion 1991), and
stream channel response to sediment inputs.
S.5.3.2 Channel Condition Comparisons
The Forest Plan calls for using baseline fish habitat objectives, as
described in the Anadromous Fish Habitat Assessment (USD A FS
1995 ), for evaluating the condition of aquatic habitat in stream
channels. The Tongass maintains an inventory of stream channel
measurements obtained in streams draining unharvested basins. This
inventory allows percentile ranges to be defined for a set of physical
habitat characteristics that are considered important to fish
populations. This provides criteria for evaluating the physical habitat
characteristics of streams draining harvested basins (Table 3-27).
Flood Plain (FP) channels were surveyed in most watersheds analyzed
below, and results were compared to the established Tongass baseline
fish habitat objective values. The criteria used for assessing the
condition of physical habitat characteristics in this analysis include:
• Pools per kilometer,
• Percent of stream channel area in pools,
• Pieces of large wood per kilometer of stream channel, and
• Stream width-to-depth ratio.
Table 3-27. Interpretation of Percentile Ranking for Flood Plain
(FP) Stream Channel Characteristics
Parameter
Percentile ranking and interpretation
25th
50th
75th
Pools per reach,
percent pool
area,
LWD per 1000m^
Poor
Fair
Good
Excellent
Width-to-depth
ratio
Excellent
Good
Fair
Poor
3.5.4
Existing
Condition
This analysis considers seven major watersheds on Kuiu Island (Figure
3-5 and Table 3-28). Watersheds that do not have names on USGS
quad maps are numbered according to the system used by ADF&G in
the Catalog of Waters Important for Anadromous Fishes (Johnson et
al. 2004). The watershed boundaries correspond to the 6th level
Hydrologic Unit Code (HUC).
Kuiu Timber Sale FEIS
Chapter 3 • 73
3 Environment and Effects
Table 3-28. Watersheds within the Project Area, Cumulative Harvest since 1977 and
Existing Roads (National Forest System and Temporary Roads)
Watershed
ADF&G
Number
ws
Acres
Harvest (ac)
since 1977
Existing
road (mi)
Existing
road^ (ac)
Cumulative
harvest since 1977
(%)
Dean Creek
109-50-10070
4,690
1,010
15.4
65.4
22.9
Saginaw Creek
109-44-10390
8,302
591
20.5
86.8
8.2
Unnamed
109-45-10090
2,140
353
11.5
48.7
18.8
Unnamed
109-44-10370
4,992
383
6.3
26.7
8.2
Security Creek
109-45-10100
5,931
939
15.8
67.2
17.0
Rowan Creek
109-52-10060
13,234
946
23.5
99.5
7.9
Kadake Creek
109-42-10300
32,270
5,167
80.3
340.6
17.1
^ Assumes that existing roads have an average clearing width of 35 feet. Actual clearing widths vary from zero on
closed roads overgrown with vegetation to 75 feet on open NFS roads.
3. 5.4.1 Sediment Risk Analysis
The current Sediment Risk Index (SRI) is either high or very high in
five major watersheds within the Project Area (Table 3-29). Increases
in the SRI above inherent levels reflect that timber harvest has
temporarily increased the risk of landslides on harvested slopes,
thereby potentially increasing sediment delivery to streams. This
statement is consistent with research on forestry and landslide
frequency in Southeast Alaska (Swanston and Marion 1991). For
sediment-related changes to stream channels to occur, there must be an
increase in sediment delivery to streams. Therefore, minimizing the
risk of sediment inputs to streams from landslides and roads provides a
strategy to avoid undesirable channel changes.
Table 3-29. Changes to the SRI in Watersheds in the Project Area
Watershed
Inherent sediment risk
index (SRI)
Current SRI
Dean Creek
Low
Moderate
Saginaw Creek
Moderate
High
WS #109-45-10090
Very low
Moderate
WS #109-44-10370
Very high
Very high
Security Creek
Moderate
High
Rowan Creek
Very high
Very high
Kadake Creek
High
Very high
74 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds o
3. 5.4.2 Dean Creek Watershed
The Dean Creek watershed lies entirely within the Timber Production
LUD, and has been managed intensively for timber harvest since 1972.
A fishpass was constructed in Dean Creek, representing a major
investment in fisheries production. Thirty-three percent (1,538 acres)
of this watershed has been harvested (including road clearings) with 23
percent of the watershed harvested in the last 30 years. Timber harvest
that has been approved but not implemented would bring the
cumulative harvest level to 24 percent. Harvest of riparian areas totals
105 acres or 2.2 percent of the watershed area. There are a total of 15.4
miles of NFS and temporary roads in the Dean Creek watershed (Table
3-28). Road building in this watershed dates back to the 1970s.
Sediment Risk Assessment and Stream Channel
Characteristics
The sediment risk assessment (SRA) for Kuiu Island identified the
Dean Creek watershed as having a low inherent risk for sediment-
related changes in stream channel characteristics compared to other
Kuiu watersheds. After accounting for harvest and road building, the
risk rating for sediment-related changes in stream channel
characteristics is moderate.
Dean Creek is in excellent condition for the number of pools and in
fair condition for the percentage of channel area in pools; in good
condition for wood loading; and in fair condition concerning the
width-to-depth ratio (Table 3-30). The excellent rating for number of
pools, and fair rating for percent of channel area in pools indicates that
there are many pools, but that they are smaller than average for a
stream of this size. It is unlikely that this is due to a lack of wood
loading in the channel, because wood loading was rated as good.
Below average pool area and the fair width-to-depth ratio may be
related to high sediment loading. This stream was not surveyed prior to
timber harvest, so no data is available to describe pre-harvest stream
channel conditions.
Table 3-30. Stream Channel Condition: Dean Creek
Channel characteristic
Value
Percentile ranking
Condition
Number of poois / kilometer
57.0
Greater than 75'*^
Excellent
% channel area in pools
37.6
Between 25*'^ and 50‘^
Fair
Pieces of wood per 1000m^
27.1
Between 50‘^ and 75"^
Good
Width-to-depth ratio
27.3
Between 50*'^ and 75**^
Fair
Kuiu Timber Sale FEIS
Chapter 3 • 75
3 Environment and Effects
3. 5.4.3 Saginaw Creek Watershed
The Saginaw Creek watershed lies almost entirely within a Timber
Production LUD and has a harvest history dating to 1968. Twenty-nine
percent of this watershed has been harvested; eight percent of the
watershed has been harvested within the last thirty years. Early harvest
was concentrated in valley bottoms and toe slopes. Harvest in riparian
areas totals 450 acres. More recent harvest has occurred on mid-slopes
and ridge tops (Figure 3-6). There are 20.5 miles of NFS and
temporary roads in the Saginaw Creek watershed. Road building dates
back to the 1960s.
Sediment Risk Assessment and Stream Channel
Characteristics
The SRA for Kuiu Island identified the Saginaw Creek watershed as
having a moderate inherent risk for sediment-related changes in stream
channel characteristics compared to other Kuiu watersheds. The SRI
increases to high after accounting for timber harvest and road building.
This indicates that low gradient stream reaches in Saginaw Creek may
be susceptible to channel changes such as widening, braiding, or pool
filling if sediment supply increases.
The East Fork of Saginaw Creek is in fair condition both for the
number of pools and the percentage of channel area in pools; in good
condition concerning the width-to-depth ratio; and in excellent
condition for wood loading (Table 3-31). The West Fork of Saginaw
Creek is in good condition for number of pools; in fair condition for
pool area; in excellent condition for wood loading; and in good
condition considering the width-to-depth ratio (Table 3-32). The
streams were not surveyed prior to timber harvest so no data is
available to describe pre-harvest stream channel conditions.
Table 3-31. Stream Channel Condition: East Fork Saginaw Creek
Channel characteristic
Value
Percentile ranking
Condition
Number of pools / kilometer
37.1
Between 25*^ and 50’^
Fair
% channel area in pools
37.9
Between 25*^ and 50‘^
Fair
Pieces of wood per lOOOm^
56.3
Greater than 75*^
Excellent
Width-to-depth ratio
20.0
Between 25"^ and 50'*^
Good
76 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
Table 3-32. Stream Channel Condition: West Fork Saginaw Creek
Channel characteristic
Value
Percentile ranking
Condition
Number of pools / kilometer
48.9
Between SO**^ and 75*^
Good
% channel area in pools
31.8
Between 25*^ and 50"^
Fair
Pieces of wood per lOOOm^
54.7
Greater than 75'*^
Excellent
Width-to-depth ratio
20.0
Between 25"^ and SO*'^
Good
3.S.4.4 Watershed (WS) #109-45-10090
This watershed lies entirely within the Timber Production LUD and
has a harvest history dating to 1972 (Figure 3-6). Fifty-nine percent
(1,266 acres) of this watershed has been harvested (after accounting
for road clearings); 19 percent of the watershed has been harvested
within the last 30 years. Harvest in riparian areas totals 85 acres or
four percent of the watershed area. There are a total of 1 1.5 miles of
roads in watershed #109-45-10090 (Table 3-28). Road building dates
back to the 1960s.
Sediment Risk Assessment and Stream Channei
Characteristics
The sediment risk assessment for Kuiu Island identified watershed
#109-45-10090 as having a very low inherent risk for sediment-related
changes in stream channel characteristics, compared to other Kuiu
watersheds. After accounting for harvest and road building, the risk
rating for sediment-related changes in stream channel characteristics is
moderate.
The major stream draining watershed #109-45-10090 is in good
condition for the number of pools, fair condition for the percentage of
channel area in pools, excellent condition for wood loading, and poor
condition concerning the width-to-depth ratio (Table 3-33). The good
rating for number of pools and fair rating for percent of channel area in
pools indicates that there are many pools, but that they are smaller than
average for a stream of this size. The high number of pools is likely
due to the excellent wood loading in the stream. Below average pool
area and the poor width-to-depth ratio may be related to high sediment
loading. While these could be natural characteristics of the stream
channel, they may also reflect channel adjustments that have resulted
from landslides originating in clearcuts, which would likely increase
sediment loading in channels upstream. This stream was not surveyed
prior to timber harvest, so no data is available to describe pre-harvest
stream channel conditions.
Kuiu Timber Sale FEIS
Chapter 3 • 77
3 Environment and Effects
Table 3-33. Stream Channel Condition: ADF&G stream # 109-45-10090
Channel characteristic
Value
Percentile ranking
Condition
Number of pools / kilometer
49.1
Between 50'^ and 75'^
Good
% channel area in pools
48.1
Between 25"^ and
Fair
Pieces of wood per lOOOm^
89.2
Greater than 75'*^
Excellent
Width-to-depth ratio
35.6
Greater than 75*'^
Poor
3.5.4.5 Watershed (WS) #109-44-10370
The watershed has a harvest dating back to 1983, with a cumulative
harvest level of 9 percent, with 8 percent occurring within the past 30
years (Figure 3-6). Riparian harvest totals three acres or less than one
percent of the watershed area. There are a total of 6.3 miles of NFS
and temporary roads within the watershed (Table 3-28).
Sediment Risk Assessment and Stream Channel Condition
The sediment risk assessment for Kuiu Island identifies watershed
#109-44-10370 as having a very high inherent risk for sediment-
related changes in stream channel characteristics, compared to other
Kuiu watersheds. The rating does not change after accounting for
harvest and road building. The very high SRI indicates that low
gradient stream reaches in this watershed may be susceptible to
channel changes such as widening, braiding, or pool filling if sediment
supply increases.
The watershed analysis for this watershed did not include a detailed
assessment of stream channel conditions in this watershed. More
detailed, field-based studies were only conducted for watersheds with
greater than 20 percent cumulative harvest levels. Consequently, field
data on the condition of the major stream draining this watershed is not
available. Field investigations of streams draining proposed harvest
units did not identify any impaired stream channels.
3. 5.4.6 Security Creek Watershed
The Security Creek watershed lies almost entirely within the Timber
Production LUD, and has a harvest history dating to 1974 (Figure 3-6).
Twenty six percent (1,546 acres) of this watershed has been harvested
(including road clearings); 17 percent has been harvested within the
last 30 years. Harvest in riparian areas totals 77 acres, or 1.3 percent of
the watershed area. There are a total of 15.8 miles of NFS and
temporary roads in the Security Creek watershed (Table 3-28). Road
building in this watershed dates back to the 1960s.
78 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
Sediment Risk Assessment and Stream Channei
Characteristics
The SRA for Kuiu Island identified the Security Creek watershed as
having a moderate inherent risk for sediment-related changes in stream
channel characteristics compared to other Kuiu watersheds. After
accounting for harvest and road building, the risk rating for sediment-
related changes in stream channel characteristics is high. The high SRI
indicates that low gradient stream reaches in Security Creek may be
susceptible to channel changes such as widening, braiding, or pool
filling if sediment supply increases.
Security Creek is in poor condition for the number of pools; in fair
condition for the percentage of channel area in pools; and in excellent
condition concerning the width-to-depth ratio (Table 3-34). Data for
wood loading in Security Creek is not available. This stream was not
surveyed prior to timber harvest so no data is available to describe pre-
harvest stream channel conditions.
Table 3-34. Stream Channel Condition: Security Creek
Channel characteristic
Value
Percentile ranking
Condition
Number of pools / kilometer
7.1
Less than 25th
Poor
% channel area in pools
39.0
Between 25*^ and 50th
Fair
Pieces of wood per 1000m^
No data
No data
No data
Width-to-depth ratio
27.5
Less than 25'^
Excellent
3. 5.4.7 Rowan Creek Watershed
The Rowan Creek watershed has a harvest history dating to 1942, with
most of the harvest occurring after 1972 (Figure 3-6). Nineteen percent
of this watershed has been harvested (including road clearings), and 8
percent of the watershed has been harvested within the last 30 years.
About 8 acres of timber harvest that has been approved but not
implemented would not increase the cumulative harvest level above 8
percent. Riparian harvest totals 79 acres, or less than one percent of the
watershed area. There are a total of 23.5 miles of NFS and temporary
roads in the Rowan Creek watershed (Table 3-28). Road building dates
back to the 1960s.
Sediment Risk Assessment and Stream Channei Condition
The SRA for Kuiu Island identifies the Rowan Creek watershed as
having a very high inherent risk for sediment-related changes in stream
channel characteristics compared to other Kuiu watersheds. The rating
does not change after accounting for harvest and road building. The
Kuiu Timber Sale FEIS
Chapter 3 • 79
3 Environment and Effects
very high SRI indicates that low gradient stream reaches in Rowan
Creek may be susceptible to channel changes such as widening,
braiding, or pool filling if sediment supply increases.
The watershed analysis for the Rowan Creek watershed did not include
a detailed assessment of stream channel conditions in the main stem of
Rowan Creek. Field investigations of streams draining proposed
harvest units did not identify any impaired stream channels in the
Rowan Creek watershed. This stream was not surveyed prior to timber
harvest, so no data is available to describe pre-harvest stream channel
conditions.
3.5.4.S Kadake Creek Watershed
In addition to providing timber, the Kadake Creek watershed provides
recreation opportunities, and is important for fisheries production. The
watershed has a harvest history dating to 1972 (Figure 3-6). Nineteen
percent (6,151 acres) of this watershed has been harvested (including
road clearings), and 1 7 percent of the watershed has been harvested
within the last 30 years. Timber harvest that has been approved but not
implemented would not increase the cumulative harvest level above 1 7
percent. Riparian harvest totals 100 acres, or less than one percent of
the watershed area. There are a total of 80.3 miles of NFS and
temporary roads in the Kadake Creek watershed (Table 3-28). Road
building dates back to the 1960s.
Sediment Risk Assessment and Stream Channel
Characteristics
The SRA for Kuiu Island identifies the Kadake Creek watershed as
having a high inherent risk for sediment-related changes in stream
channel characteristics compared to other Kuiu watersheds. The risk
rating increases to very high after accounting for harvest and road
building. The very high SRI indicates that low gradient stream reaches
in Kadake Creek may be susceptible to channel changes discussed
above.
Kadake Creek is in poor condition for the number of pools, excellent
condition for the percentage of channel area in pools, and between fair
and good condition for wood loading and width-to-depth ratio (Table
3-35). The poor rating for number of pools, and excellent rating for
percent of channel area in pools indicates that there are few pools, but
that they are larger than average for a stream of this size. Both wood
loading and width-to-depth ratio are average. This stream was not
surveyed prior to timber harvest; therefore, no data is available to
describe pre-harvest stream channel conditions.
80 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
Table 3-35. Stream Channel Condition: Main Stem Kadake Creek
Channel characteristic
Value
Percentile
ranking
Condition
Number of pools / kilometer
11
Less than 25*'^
Poor
% channel area in pools
69
Greater than 75*^
Excellent
Pieces of wood per lOOOm^
5
= 50'^ percentile
Fair / good
Width-to-depth ratio
45
= 50*^ percentile
Fair / good
3.5.5
Effects
Common to all
Action
Alternatives
3. 5. 5.1 Direct and Indirect Effects
Each of the proposed action alternatives relies on the existing road
system, with newly constructed NFS roads proposed in all alternatives
except Alternative 1 ; action Alternatives 2 through 5 would require the
construction and/or reconstruction of temporary roads. All new NFS
roads would be placed closed following harvest, and temporary roads
would be decommissioned. Closing roads minimizes potential fish
passage problems and ensures protection of water quality and fish
habitat by keeping road maintenance needs low, and minimizing the
potential for sediment delivery to streams from the failure of drainage
structures.
3.5.6
Cumulative
Watershed
Effects
Timber harvest and road building would inerease the area of potential
sediment sources within the watershed. Sediment loading would be
expected to be eonsistent with the Forest Plan, and would not be
expected to exceed water quality standards set by the State of Alaska.
The inereased risk of landslides is considered an indireet effect to
streams, because if landslides do occur they may or may not deliver
sediment to streams. 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.
More specific infonnation about landslide potential is presented below
under each alternative and in the Soils and Geology section in this
chapter.
3.5.6.1 Analysis Area
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 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). The 6th level HUC scale
Kuiu Timber Sale FEIS
Chapter 3*81
3 Environment and Effects
provides boundaries large enough to allow a comprehensive
accounting of all activities affecting mainstem streams draining the
watersheds, and small enough to allow the analysis to be sensitive to
potential effects of the proposed activities.
Temporally, cumulative watershed effects may be influenced by some
of the activities summarized in the Kuiu Catalog of Events. In this
analysis emphasis was given to timber harvest activities in the past 30
years and road building activities regardless of age, activities which
are known to potentially effect changes in peak flow and timing of
runoff, and sediment delivery to streams.
Past Activities
Management-related and naturally occurring activities influencing
watershed hydrology were considered. The activities considered from
the Kuiu Catalog of Events include road building, timber harvest,
APC-related planting projects, road and LTF maintenance, riparian
and commercial thinning, channel restoration and large woody debris
placements, vegetation improvements following landslides and fire,
the Kadake Cabin relocation, the Rocky Pass water line, number and
location of known landslides, and miles of NFS and temporary roads
including their respective stream crossings.
Current Activities
Current activities influencing cumulative effects are maintenance of
existing roads, revegetation on previously closed roads, and
revegetation in managed stands with previous harvest.
Future Activities
Besides the timber harvest and road building activities analyzed in
each alternative below, activities occurring in the foreseeable future
that could influence cumulative watershed effects include previously
analyzed timber harvest, 2"^ growth riparian thinning projects in the
Saginaw and Kadake watersheds, and closure of select NFS roads.
Some of the timber harvest approved under the ROD for the Crane and
Rowan Mountain Timber Sales has been harvested. The remainder
would include about 5 1 acres of harvest in the Dean Creek watershed,
326 acres in the Security Creek watershed, 8.5 acres in the Rowan
Creek watershed, and 86 acres in the Kadake Creek watershed.
3. 5.6.2 Timber Harvest and Water Yield
Timber harvest causes changes in the collection and storage of water
in watersheds primarily by affecting canopy interception and
evapotranspiration, which can affect the amount of stream discharge.
Extensive reduction in plant transpiration rates by vegetation removal
82 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
can increase annual water yield, as well as peak flows in small
streams, particularly during the driest part of the growing season (Harr
et al. 1975, Jones and Grant 1996). Peak flow increases have been
demonstrated in small watersheds where as little as 25 percent of
vegetation has been completely removed in a single entry (Jones and
Grant 1996). However, increases may be undetectable when harvest
levels are below 25 percent (Jones and Grant 1996, Beschta et al.
2000).
Hydrologic recovery due to re-growth of vegetation in harvested areas
offsets changes in water yield over time. Full hydrologic recovery in
the absence of roads is dependent upon re-growth following harvest,
and is expected to require between 10 and 30 years in the Pacific
Northwest (Hicks et al. 1991(a), Jones 2000).
Potential changes in water yield are assessed for each alternative in the
sections that follow. These qualitative assessments are made assuming
that 1) cumulative harvest levels affecting less than 25 percent of the
total watershed area generally do not cause detectable increases in
water yield (Jones and Grant 1996; Beschta et al. 2000), and 2) water
yield recovers to pre-harvest levels within 30 years (Hicks et al.
1991(a), Jones 2000).
3.S.6.3 General Timber Harvest and Watershed Recovery on
Kuiu Island
High rates of timber harvest occurred on Kuiu Island in the 1960s and
1970s, and in the 1980s in the Dean Creek watershed. Research
discussed above suggests that timber harvest levels may have eaused
temporary increases in landslide potential and water yield during
certain time periods, and that recovery to pre-harvest conditions is
ongoing. Currently, only the Dean Creek watershed has 30-year
cumulative harvest levels approaching 25 percent. Regardless of which
alternative is selected, 30-year cumulative harvest levels in the Project
Area watersheds will decrease rapidly until the year 2010, after which
time the 30-year cumulative harvest levels in all watersheds will be
well below 20 percent. More specifically, if the No-Action Alternative
were implemented, the highest 30-year cumulative harvest levels in
any watershed would be about 12 percent in 2010 (Chart 3-1). In
comparison, if Alternative 4 were selected, the highest 30-year
cumulative harvest levels in any watershed would be about 17 percent
by 2010 (Chart 3-2). The sharp decline in 30-year harvest levels
happening between years 2001 and 2010 reflects the sharp decline in
harvest rates within the Project Area since the 1960s and 1970s.
The general trend in all watersheds is toward recovery of slope
stability and pre-harvest rates of canopy interception and
evapotranspiration.
Kuiu Timber Sale FEIS
Chapter 3 • 83
3 Environment and Effects
Chart 3-1. Change of cumulative harvest levels in the Project
Area over 30 years for Alternative 1, the No-Action
Alternative. This calculation accounts for
unharvested units in the Crane and Rowan Mountain
Timber Sales ROD, but does not account for road
clearings.
Alternative 1
Year
♦- Dean Creek WS
■ Saginaw Creek
-kr-V\IS 109-45-10090
109-44-10370
X - Security Creek WS
— Rowan Creek
— I — Kadake Creek
84 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
Chart 3-2. Change of cumulative harvest levels in the Project
Area over 30 years for Alternative 4, the alternative
proposing the highest number of acres for harvest.
This calculation accounts for unharvested units in
the Crane and Rowan Mountain Timber Sales ROD,
but does not account for road clearings.
Alternative 4
Year
• Dean Creek WS
• Saginaw Creek
• WS 109-44-10370 -^Security Creek WS
• Kadake Creek
-WS 109-45-10090
- Rowan Creek
3. 5. 6.4 Sediment Risk and Stream Channel Condition in
Kuiu Watersheds
Generally, observed stream channel conditions were fair, good, or
excellent, except for the poor width-to-depth ratio in watershed 1 09-
45-10090, and the poor number of pools per kilometer in the Security
Creek and Kadake Creek watersheds. These conditions may be
exacerbated if sediment loads in these watersheds are increased.
The current SRI is greater than the inherent SRI in five of the major
watersheds within the Project Area (Table 3-36). This reflects the fact
that recent timber harvest has increased the risk of landslides in these
Kuiu Timber Sale FEIS
Chapter 3 • 85
3 Environment and Effects
watersheds, and that streams in these watersheds may be susceptible to
channel changes if landslides do occur. All of the action alternatives
would slightly increase the risk of landslides over what would occur
naturally, as discussed below under each alternative. Alternative 3
proposes enough timber harvest and road building to further increase
the SRI in the Saginaw Creek watershed. Alternatives 4 and 5 propose
enough timber harvest and road building to increase the SRI in both
the Saginaw Creek and Dean Creek watersheds. Low gradient stream
channels in the lower valleys of watersheds with high and very high
SRI values have an increased risk of sediment-related changes in
channel morphology including channel widening, braiding, and
changes to channel roughness, grain size, pool depth and pool
frequency. This statement is consistent with research on stream
channel morphology and stream channel change associated with
increased sediment inputs (Lyons and Beschta 1983, Sullivan et al.
1987, Madej 1999).
Table 3-36. Current Sediment Risk Index (SRI) in Project Area Watersheds, and SRI
after Accounting for Proposed Timber Harvest and Road Construction
Watershed
Inherent
SRI
Current
SRI
Alt 2 SRI
Alt 3 SRI
Alt 4 SRI
Ait 5 SRI
Dean Creek
Low
Moderate
Moderate
Moderate
High
High
Saginaw Creek
Moderate
High
High
Very high
Very high
Very high
WS #109-45-10090
Very low
Moderate
Moderate
Moderate
Moderate
Moderate
WS #109-44-10370
Very high
Very high
Very High
Very High
Very
High
Very High
Security Creek
Moderate
High
High
High
High
High
Rowan Creek
Very high
Very high
Very high
Very high
Very high
Very high
Kadake Creek
High
Very high
Very high
Very high
Very high
Very high
3.5.7
Cumulative
Effects of
Roads
Each of the action alternatives described in this section responds to the
issue of cumulative watershed effects in similar ways. After the
completion of proposed harvest activities, all action alternatives would
result in a net decrease in the amount of road needing maintenance due
to closure of specific roads in each alternative (see the Transportation
section in this chapter). Closure would be accomplished using
techniques that may include use of gates, removing culverts and
bridges, installing “tank traps” and berm barriers, excavating
additional waterbars in the road surface, and allowing vegetation to
become re-established on the road and in the road ditch. This would
restore more natural drainage patterns and eliminate the risk of road
86 • Chapter 3
Kuiu Timber Sale FEIS
3.5.8
Effects by
Alternative
Issue 4: Cumulative Effects on Watersheds
failures at stream crossings, culvert plugging, and stream diversion.
Natural revegetation would further reduce the risk of sediment
delivery to streams.
3. 5.8.1 Alternative 1 No-Action alternative
Direct and Indirect Effects
In the No- Action Alternative, no 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. With periodic road
maintenance, sediment delivery to streams from roads is expected to
be minor and within water quality standards set by the State of Alaska.
Cumulative Effects
Cumulative effects associated with the No- Action Alternative are
limited to those associated with timber harvest activities that have been
previously approved, maintenance of existing roads, growth of trees in
managed stands harvested in the past, and reestablisliment of more
natural drainage patterns and vegetation on closed roads. Under this
alternative, no changes in water yield, sediment delivery to streams or
fish passage are expected beyond those associated with these activities
and naturally occurring events. Most of the timber harvest approved
under the ROD for the Crane and Rowan Mountain Timber Sales has
been implemented. The remainder of the timber harvest would include
about 51 acres of harvest in the Dean Creek watershed, 326 acres in
the Security Creek watershed, nine acres in the Rowan Creek
watershed, and 86 acres in the Kadake Creek watershed.
3. 5.8.2 Alternative 2
Direct and Indirect Effects
Alternative 2 would harvest 471 acres (Table 3-36). Harvest units
included in this alternative would be accessed using the existing NFS
roads and 1.5 miles of temporary road that would be decommissioned
after timber harvest is complete. This alternative would require new
construction of 1.8 miles of NFS road, all of which would be closed
following timber harvest. An additional 7.8 miles of currently open
NFS roads would be closed following harvest. Yarding systems would
include ground-based cable and shovel yarding. This alternative
would require the installation of three culverts or bridges on Class I
streams, three culverts or bridges on class II streams, 1 culvert on a
Class III stream, and 5 culverts on class IV streams (Table 3-57).
Culverts or bridges would be removed as a part of decommissioning
on temporary roads.
Kuiu Timber Sale FEIS
Chapter 3 • 87
3 Environment and Effects
A direct effect of implementing this alternative would be the
temporary increase in sediment delivery to streams due to new road
building, new constmction on decommissioned roadbeds, bridge
construction, and the installation of culverts. Short-term (48 hours)
increases in sediment delivery are not expected to degrade water
quality or fish habitat.
Alternative 2 proposes 197 acres of clearcut harvest, of which 2.0
acres are on slopes with a high mass movement index (MMI-3). The
proposed timber harvest would increase the risk of landslides
occurring on these slopes, which lie in the northeast corner of Unit
417. See the Unit Cards in Appendix B and the Soils and Geology
section of this chapter for more information on MMl soils. This
alternative does not propose any road building on slopes with a
gradient over 67 percent.
Table 3-37. Summary of timber harvest and road building proposed in
Alternative 2, and associated changes in cumulative harvest levels.
Watershed
(WS)
ADF&G
Number
WS
Acres
Existing
Condition
Proposed Activities in Alternative 2
Cumulative
harvest (%)
since 1977
Harvest
(ac)
New
road
(mi)
New
road®
(ac)
Cumulative
harvest (%)
Dean Creek
109-50-10070
4,690
24
0
0.0
0.0
24.0
Saginaw Creek
109-44-10390
8,302
8
95
0.8
7.4
9.4
Unnamed
109-45-10090
2,140
19
24
0.0
0.0
19.9
Unnamed
109-44-10370
4,992
8
125
0.0
0.0
10.8
Security Creek
109-45-10100
5,931
23
41
0.9
6.2
23.3
Rowan Creek
109-52-10060
13,234
8
68
0.2
1.1
9
Kadake Creek
109-42-10300
32,270
17
124
1.4
8.9
17.7
Total:
477'
3.3
23.6
aAssumes a 40-foot clearing width for proposed temporary roads and a 75-foot clearing width for newly constructed
NFS roads.
^ Difference in total acres harvested for alternative due to rounding.
Cumulative Effects
Cumulative effects include the reasonably foreseeable future harvest of
remaining units and associated road clearing from the Crane and
Rowan Mountain Timber Sales EIS. Harvest of 477 acres within the
Project Area would increase cumulative harvest levels in the Saginaw
88 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds o
Creek, Security Creek, Rowan Creek, and Kadake Creek watersheds
and in watersheds #109-45-10090 and #109-44-10370 (Table 3-37).
Dean Creek watershed (in which no harvest is proposed) would have a
30-year cumulative harvest level of 24 percent (including roads). If
Alternative 2 were implemented, and completed by 2008, all
watersheds within the Project Area would have 30-year cumulative
harvest levels below 14 percent by 2010.
This alternative addresses cumulative effects associated with roads by
closing 7.8 miles of currently open NFS roads (Forest Roads 6413 (2.8
miles), 46096 (3.6) miles, 46021 (1.4 miles)). This would result in a
decrease of 4.8 miles of currently open NFS road in the Saginaw
Creek watershed, 1.4 miles in watershed #109-45-10090, and 1.6 miles
in watershed #109-44-10370. Closing roads would be accomplished
using techniques that may include use of gates, removing culverts and
bridges, installing “tank traps” and berm barriers, excavating
additional waterbars in the road surface, and allowing vegetation to
become reestablished on the road and in the road ditch. This restores
more natural drainage patterns and eliminates the risk of road failures
at stream crossings, culvert plugging, and stream diversion. Natural
revegetation further reduces the risk of sediment delivery to streams.
3.5.8. 3 Alternative 3
Direct and Indirect Effects
Alternative 3 would harvest 786 acres (Table 3-38). Harvest units
included in this alternative would be accessed using the existing NFS
roads and 2.1 miles of temporary road. This alternative would require
new construction on 5.4 miles of road, all of which would be closed
following timber harvest (Table 3-38). An additional 8.0 miles of
currently open NFS roads would be closed following harvest. Yarding
systems would include only ground-based cable and shovel yarding.
This alternative would require the installation of two culverts or
bridges on Class I streams, four culverts or bridges on Class II streams,
eight culverts or bridges on Class III streams, and 19 culverts or
bridges on Class IV streams (Table 3-57). These culverts or bridges
would be removed after the completion of harvest activities on
decommissioned temporary roads.
A direct effect of implementing this alternative would be the
temporary increase in sediment delivery to streams due to new road
building, new construction on decommissioned temporary old
roadbeds, bridge construction, and the installation of culverts. Short-
term increases in sediment delivery (48 hours) are not expected to
degrade water quality or fish habitat.
Alternative 3 proposes 409 acres of clearcut harvest, none of which
will occur on slopes with a high or extreme mass movement index
Kuiu Timber Sale FEIS
Chapter 3 • 89
3 Environment and Effects
(MMI-3 or MMI-4). The proposed timber harvest would increase the
risk of landslides occurring on these slopes. This alternative does not
propose any road building on slopes with a gradient over 67 percent.
Cumulative Effects
Cumulative effects include the reasonably foreseeable future harvest of
remaining units and associated road clearing from the Crane and
Rowan Mountain Timber Sales EIS. Harvest of 786 acres within the
Project Area would increase cumulative harvest levels in the Saginaw
Creek, Security Creek, Rowan Creek, and Kadake Creek watersheds
and in watershed #109-44-10370 (Table 3-38). Of the watersheds
within the Project Area, Dean Creek has the highest 30-year
cumulative harvest percent of 24 percent (including roads).
If Alternative 3 were implemented, increases in cumulative harvest
levels in Security Creek may result in slight increases in water yield.
However, any increase in water yield would be short-lived due to the
ongoing regrowth of trees in stands harvested over a period of decades.
If alternative 3 were implemented and completed by 2008, all
watersheds within the Project Area would have 30-year cumulative
harvest levels below 12 percent by 2010.
This alternative addresses cumulative effects associated with roads by
closing 8.0 miles of currently open NFS roads after accessing units on
them; Forest Roads 6413 (2.8 miles), 46096 (3.6 miles), and 6418 (1.6
miles). This would result in a decrease of 6.4 miles of open NFS road
in the Saginaw Creek watershed, and 1.6 miles in WS #109-44-10370.
Closing roads involves using techniques that may include use of gates,
removing culverts and bridges, installing “tank traps” and berm
barriers, excavating additional waterbars in the road surface, and
allowing natural vegetation to become reestablished on the road and in
the road ditch. This restores more natural drainage patterns and
eliminates the risk of road failures at stream crossings, culvert
plugging, and stream diversion. Natural revegetation further reduces
the risk of sediment delivery to streams.
90 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4; Cumulative Effects on Watersheds
Table 3-38. Summat7 of timber harvest and road building proposed in
Alternative 3, and associated changes in cumulative harvest
levels.
Watershed
(WS)
ADF&G
Number
WS
Acres
Existing
Condition
Proposed Activities in Alternative
3
Cumulative
harvest (%)
since 1977
Harvest
(ac)
New
Road
(mi)
New
Road
(ac)"
Cumulative
harvest (%)
Dean Creek
109-50-10070
4,690
24
0
0.0
0.0
24.0
Saginaw Creek
109-44-10390
8,302
8
330
2.7
19.3
12.4
Unnamed
109-45-10090
2,140
19
0
0.0
0.0
18.8
Unnamed
109-44-10370
4,992
8
115
0.0
0.0
10.6
Security Creek
109-45-10100
5,931
23
100
1.5
12.6
24.4
Rowan Creek
109-52-10060
13,234
8
115
0.1
0.7
8.8
Kadake Creek
109-42-10300
32,270
17
126
3.2
26.5
17.8
Total:
786
7.5
59.1
a
Assumes a 40-foot clearing width for proposed temporary roads and a 75-foot clearing width for newly
constructed NFS roads.
3. 5.8.4 Alternative 4
Direct and Indirect Effects
Alternative 4 would harvest 1,387 acres (Table 3-39). Harvest units
included in this alternative would be accessed using the existing NFS
roads and 3.9 miles of temporary road. This alternative would require
new construction of 6.4 miles of NFS road, all of which would be
closed following timber harvest (Table 3-39). An additional 10.6 miles
of currently open NFS roads would be closed following harvest.
Yarding systems would include helicopter yarding, cable yarding, and
shovel yarding. This alternative would require the installation of three
culverts or bridges on Class I streams, five culverts or bridges on Class
II streams, 14 culverts or bridges on Class III streams, and 19 culverts
or bridges on Class IV streams (Table 3-57). These culverts or bridges
would be removed after the completion of harvest activities on
decommissioned temporary roads.
A direct effect of implementing this alternative would be the
temporary increase in sediment delivery to streams due to new road
building, road reconditioning, bridge construction, and the installation
Kuiu Timber Sale FEIS
Chapter 3 • 91
3 Environment and Effects
of culverts. Short-term (48 hrs.) increases in sediment delivery are not
expected to degrade water quality or fish habitat.
Table 3-39. Summary of timber harvest and road building proposed in Alternative
4, and associated changes in cumulative harvest levels.
Watershed
(WS)
ADF&G
Number
WS
Acres
Existing
Proposed Activities in Alternative 4
Cumulative
harvest (%)
since 1977
Harvest
(ac)
New
road
(mi)
New
road^
(ac)
Cumulative
harvest (%)
Dean Creek
109-50-10070
4,690
24
120
0.6
4.1
26.7
Saginaw Creek
109-44-10390
8,302
8
416
1.9
12.5
13.3
Unnamed
109-45-10090
2,140
19
96
0.5
3.8
23.4
Unnamed
109-44-10370
4,992
8
125
0.0
0.0
10.8
Security Creek
109-45-10100
5,931
23
144
1.8
15.0
25.2
Rowan Creek
109-52-10060
13,234
8
236
1.2
7.2
9.8
Kadake Creek
109-42-10300
32,270
17
249
4.3
34.7
18.2
Total:
1,387
10.3
77.3
a
Assumes a 40-foot clearing width for proposed temporary roads and a 75-foot clearing width for newly constructed
NFS road.
Alternative 4 proposes 1,025 acres of clearcut harvest, of which about
14 acres are on slopes with an extreme mass movement index, MMI-4
(see the Soils and Geology section in this Chapter). These slopes are
located in Unit 1 0 1 along the western edge of the unit where there are
no streams. The proposed timber harvest would increase the risk of
landslides occurring on these slopes, however because there are no
streams a slide would not increase sedimentation (see the Unit Cards
in Appendix B and Soil and Geology section of this chapter). A Soils
Stability Investigation Report was eompleted with a site visit in which
it was determined that this area showed no signs of instability and was
suitable for harvest. This alternative does not propose any road
building on slopes with a gradient over 67 percent.
Cumulative Effects
Cumulative effects include the reasonably foreseeable future harvest of
remaining units and associated road clearing from the Crane and
Rowan Mountain Timber Sales EIS. Harvest of 1,387 acres within the
Project Area would increase cumulative harvest levels in all
watersheds within the Project Area (Table 3-39). Of the watersheds
92 • Chapter 3
Kuiu Timber Sale FEIS
Issue 4: Cumulative Effects on Watersheds
within the Project Area, only the Dean Creek and the Security Creek
watersheds would have a 30-year cumulative harvest level above 20
percent (including roads).
If Alternative 4 were implemented, increases in cumulative harvest
levels in Dean Creek, Security Creek, and watershed #109-45-10090
may result in slight increases in water yield. However, any increase in
water yield would be short-lived due to the ongoing re-growth of trees
in stands harvested over a period of decades.
This alternative addresses cumulative effects associated with roads by
closing 10.6 miles of currently open NFS roads after accessing units
on them; Forest Roads 6413 (2.8 miles), 46096 (3.6 miles), 6427 (1.1
miles), 46021 (1.4 miles), and 6418 (1.6 miles). This would result in a
decrease of 6.4 miles of open NFS road in the Saginaw Creek
watershed, 1.0 mile of road in the Dean Creek watershed, 1.5 miles of
road in watershed 109-45-10090 and 1.6 miles in WS #109-44-10370.
Closing roads involves using techniques that may include use of gates,
removing culverts and bridges, installing “tank traps” and berm
barriers, excavating additional waterbars in the road surface, and
allowing natural vegetation to become reestablished on the road and in
the road ditch. This restores more natural drainage patterns and
eliminates the risk of road failures at stream crossings, culvert
plugging, and stream diversion. Natural revegetation further reduces
the risk of sediment delivery to streams.
3. 5.8. 5 Alternative 5
Direct and Indirect Effects
Alternative 5 would harvest 1,208 acres (Table 3-40). Harvest units
included in this alternative would be accessed using the existing NFS
roads and 3.5 miles of temporary road. This alternative would require
new construction of 6.5 miles of NFS road, all of which would be
closed following timber harvest (Table 3-40). An additional 10.5 miles
of currently open NFS roads would be closed following harvest.
Yarding systems would include only ground-based cable and shovel
yarding. This alternative would require the installation of three
culverts or bridges on Class I streams, five culverts or bridges on Class
II streams, 15 culverts or bridges on Class III streams, and 19 culverts
or bridges on Class IV streams (Table 3-57). These culverts or bridges
would be removed after the completion of harvest activities on
decommissioned temporary roads.
A direct effect of implementing this alternative would be the
temporary increase in sediment delivery to streams due to new road
building, road reconditioning, bridge construction, and the installation
of culverts. Short-term increases in sediment delivery are not expected
to degrade water quality or fish habitat.
Kuiu Timber Sale FEIS
Chapter 3 • 93
3 Environment and Effects
Alternative 5 proposes 1,208 acres of clearcut harvest, of which about
20 acres are on slopes with a high or extreme mass movement index
(MMI-3 or MMI-4) (see the Soils and Geology section in this
Chapter). These include about 16 acres of MMI-4 soils in Unit 101
along the western edge of the unit where there are no streams, and in
an area drained by Class III and Class IV streams in the southeast
comer. Clearcut harvest is also proposed on about 2 acres of MMI-4
soils along a large v-notch that creates the southern boundary of Unit
401, and on about 2 acres of MMI-3 soils in the northeast comer of
Unit 417 along a stream. A Soils Stability Investigation Report was
completed with a site visit in which it was determined that this area
showed no signs of instability and was suitable for harvest. This
alternative does not propose any road constmction on slopes with a
gradient over 67 percent.
Table 3-40. Summary of timber harvest and road building proposed in Alternative 5, and
associated changes in cumulative harvest levels.
Watershed
(WS)
ADF&G
Number
WS
Acres
Existing
Condition
Proposed Activities in
Alternative 5
Cumulative
harvest (%)
since 1975
Harvest
(ac)
New Road
(mi)
New Road^
(ac)
Cumulative
harvest (%)
Dean Creek
109-50-10070
4,690
24
120
0.7
4.1
26.7
Saginaw
Creek
109-44-10390
8,302
8
313
2.6
19.3
12.2
Unnamed
109-45-10090
2,140
19
96
0.4
3.8
23.4
Unnamed
109-44-10370
4,992
8
125
0.0
0.0
10.8
Security Creek
109-45-10100
5,931
23
144
1.8
15.0
25.2
Rowan Creek
109-52-10060
13,234
8
260
1.2
7.2
10.0
Kadake Creek
109-42-10300
32,270
17
150
3.2
26.5
17.9
Total:
1,208
9.9
75.9
a
Assumes a 40-foot clearing width for proposed temporary roads and a 75-foot clearing width for newly constructed NFS
roads.
li
94 • Chapter 3
Kuiu Timber Sale FEIS
■■ i
I
\
' i.
Kuiu Timber Sale
Figure 3-5
Watersheds and Streams
Legend
Non-National Forest
Lakes/Saltwater
Stream Value Class I
Stream Value Class II
Stream Value Class
Stream Value Class IV
Project Area Boundary
Watershed Boundary
Existing Roads
4
■ Miles
3
ipean preek
WafersTiegf
w&ersnedj 4
iioSSs^Wom
j^Saaid^Creek^ \
L>I
^Watershed-p
109-44^-10370'
Kadake
Bay
SecMy-Qreek
Watersheds
Rowan Creek
tiWatershed k
Kadake Creek-
Watershed
Kuiu Timber Sale
Figure 3-6
Managed Stands, Roads, Landslides
Legend
Harvested Between 1911-1959
Harvested Between 1960-1969
Harvested Between 1970-1979
Harvested Between 1980-1989
1990 - Present
Non-National Forest
Stream Value Class I & II
Existing Open Roads
Project Area Boundary
500ft Contour Interval
Watershed Boundary
• Slides (From 1998 Aerial Photos)
Miles
3
Issue 4: Cumulative Effects on Watersheds
Cumulative Effects
Cumulative effects include the reasonably foreseeable future harvest of
remaining units and associated road clearing from the Crane and
Rowan Mountain Timber Sales EIS. If Alternative 5 were
implemented and 1,208 acres were harvested, the cumulative harvest
levels in all watersheds within the Project Area would increase. Of the
watersheds within the Project Area, the Dean Creek watershed, the
Security Creek watershed, and watershed #109-45-10090 would have
a 30-year cumulative harvest level above 20 percent (including roads).
If Alternative 5 were implemented, increases in cumulative harvest
levels in Dean Creek, Security Creek, and watershed #109-45-10090
may result in slight increases in water yield. However, any increase in
water yield would be short-lived due to the ongoing re-growth of trees
in stands harvested over a period of decades.
This alternative addresses cumulative effects associated with roads by
closing 10.6 miles of NFS roads after accessing units on them; Forest
Roads 6413 (2.8 miles), 46096 (3.6 miles), 6427 (1.1 miles), 46021
(1.4 miles), and 6418 (1.6 miles). This would result in a decrease of
6.4 miles of open road in the Saginaw Creek watershed, 1 .0 mile of
road in the Dean Creek watershed, 1.5 miles of road in watershed 109-
45-10090 and 1.6 miles in WS #109-44-10370. Closing roads involves
using techniques that may include use of gates, removing culverts and
bridges, installing “tank traps” and berm barriers, excavating
additional waterbars in the road surface, and allowing natural
revegetation on the road and in the road ditch. This restores more
natural drainage patterns and eliminates the risk of road failures at
stream crossings, culvert plugging, and stream diversion. Natural
revegetation further reduces the risk of sediment delivery to streams.
Kuiu Timber Sale FEIS
Chapter 3 • 99
3.6 Alaska Region Threatened,
Endangered, Candidate, and Sensitive
Species
3.6.1
Introduction
3.6.2
Threatened,
Endangered
and Candidate
Species
Federally listed threatened and endangered species are those plant and
animal species fonnally listed by the U.S. Fish and Wildlife Service
(USFWS) or the National Marine Fisheries Service (NFMS) under
authority of the Endangered Species Act of 1973, as amended. Under
the Endangered Species Act, 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. USFWS defines a
candidate species as a species for which there is on file sufficient
information on biological vulnerability and threat(s) to support
proposals as threatened or endangered.
The Regional Forester of the USDA Forest Service has the authority to
designate species as “sensitive.” Sensitive species are those plant and
animal species for which population viability is a concern, as
evidenced by significant current or predicted downward trends in
population numbers or density, or significant current or predicted
downward trends in habitat capability that would reduce a species’
existing distribution. Information on threatened, endangered,
candidate, and sensitive species distributions and occurrences in the
Project Area was obtained from agency contacts, a review of the
available literature on these species in Southeast Alaska, and field
review by interdisciplinary survey teams.
A Biological Evaluation (BE) was completed to determine whether the
Kuiu Timber Sale may affect federally listed or sensitive species. The
document was prepared in accordance with legal requirements set
under Section 7 of the Endangered Species Act of 1973 (19 U.S.C.
1536 (c)), and follows standards established in Forest Service Manual
(FSM) direction (2672.42) and the Code of Federal Regulations (50
CFR 402). The BE is available from the Kuiu Timber Sale planning
record. Findings are summarized below.
3.6.2. 1 Wildlife Species
Alaska Region threatened endangered, candidate, and
sensitive species wildlife species
Table 3-41 displays the potential habitat for the Alaska Region’s
threatened, endangered, candidate, and sensitive wildlife species
within the Project Area. The Forest Service consulted with the
100 • Chapter 3
Kuiu Timber Sale FEIS
TES Species
USFWS and the NMFS as part of this analysis. No terrestrial speeies
listed by the USFWS as threatened, endangered, or eandidate speeies
are known to oeeur within the Projeet Area.
Table 3-41. Federally listed threatened, endangered, and candidate wildlife species,
and Alaska Region sensitive wildlife species potential habitat within the
Kuiu Timber Sale Project Area
US Fish & Wildlife Service and
National Marine Fisheries Listed
Species (T, E, & C)
Potential Habitat
in Project Area
Carried Forward For Analysis
a
Humpback Whale (Endangered)
NO
NO. Waters adjacent to the Project
Area are outside known concentration
areas. No effects are expected.
Snake River Sockeye (Endangered)
NO
NO. Habitat or individuals do not occur
in Project Area. Compliance with TLMP
standards and guidelines. No effects
are expected.
a
Steller’s Sea Lion (Threatened)
NO
NO. There is no critical habitat within
or near the Project Area. No effects are
expected.
Snake River Spring/Summer Chinook
(Threatened)
NO
NO. Habitat or individuals do not occur
in Project Area. Compliance with TLMP
standards and guidelines. No effects
are expected.
Snake River Fall Chinook
(Threatened)
NO
NO. Habitat or individuals do not occur
in the Project Area. Compliance with
TLMP standards and guidelines. No
effects are expected.
Kittlitz’s Murrelet (Brachyramphus
brevirostris) (Candidate)
NO
NO. Habitat or individuals do not occur
in the Project Area.
Alaska Region Sensitive Species
Potential Habitat
in Project Area
Carried Forward for Analysis
Northern Goshawk (Accipiter
gentilis)
YES
YES.
Trumpeter Swan {Olor buccinator)
NO
NO. Habitat does not occur in the
Project Area.
Osprey {Pandion haliaetus)
YES
NO. Habitat is not affected by
proposed activities.
Peale’s Peregrine Falcon (Falco
peregrin us peaiei)
NO
NO. Habitat does not occur in the
Project Area.
a
Appendix J of the 1997 Forest Plan Final EIS includes a Biological Assessment for the humpback whale and Steller’s sea
lion that are found in waters of Southeast Alaska. The Forest Plan includes appropriate standards and guidelines for
management operations within the waters of Southeast Alaska when these species could be affected, such as in the vicinity
of sea lion haul outs.
Kuiu Timber Sale FEIS
Chapter 3 • 101
3 Environment and Effects
No federally listed threatened or endangered animal speeies would be
adversely affeeted by the proposed actions. The Forest Service has
prepared a complete Biological Evaluation for these species located in
the Kuiu Timber Sale planning record (see the Wildlife Biological
Evaluation available in the Kuiu Timber Sale planning record for more
information).
Sensitive Species
The northern goshawk, trumpeter swan, and Peale’s peregrine falcon
are Alaska Region sensitive species known to occur on Kuiu Island,
but only the northern goshawk is documented to occur within the
Project Area. There is no habitat within or near the Project Area for
Peale’s peregrine falcon and while Kuiu Island has potential habitat for
osprey, there is no evidence that this rare migrant to central Southeast
Alaska uses Kuiu Island.
The Forest Plan provides standards and guidelines for the protection of
these species. If sensitive species’ nests are located, the Forest Plan
Standards and Guidelines will be implemented.
Northern Goshawk
Field surveys have been conducted since the 1993 field season. There
are ten known nesting locations on Kuiu Island. Of the ten nests
located, two are within the Project Area.
A nest site in the Rowan Bay drainage was first discovered in 1993.
The area was surveyed in 1998, 1999, 2000, 2002, 2004, and 2005 and
no activity was observed during the surveys. In the 2004 and 2005
surveys, the nest structure was found to be in poor condition.
A nest site in Security Bay was active starting in 1997. In 2003 and
2004 it was surveyed for goshawk nesting activity. In 2003 two plucks
(varied thrush) were found in the vicinity, but no other evidence of
goshawk activity was observed. In 2004 the nest was found to be
unoccupied and in poor condition.
The standards and guidelines applied to the management activities
meet the requirements of the Forest Plan. The Rowan Bay nest is
protected by a buffer of suitable habitat greater than 100 acres. The
Security Bay nest does not require a buffer, as it is located within a
medium old-growth habitat reserve and is protected from timber
harvest activities.
102 • Chapter 3
Kuiu Timber Sale FEIS
TES Species
3. 6.2.2 Plant Species
Federally listed plant species
In the State of Alaska, one plant species is federally listed: the
endangered fern Polystichiim aleuticum, known only from Adak Island
in the Aleutians. No federally listed or proposed plant species are
known or suspected to occur on Kuiu Island.
Alaska Region listed sensitive plant species
The Alaska Region lists 19 plant species as sensitive. There are three
known and nine suspected plant species on the Petersburg Ranger
District of the Tongass National Forest where the Project Area is
located (Figure 1-1 and Table 3-42). More information is in the Plant
Biological Evaluation located in the Kuiu Timber Sale planning
record.
All three of sensitive plant species found on the Petersburg Ranger
District are known to occur on Kuiu Island. Loose-flowered bluegrass
(Poa laxiflora) has been documented on several upper beaches in the
wilderness areas 15-20 miles south of the Project Area and along one
stream on north Kuiu Island within the Project Area. Davy mannagrass
(Glyceria leptostachya) has been found along a stream bank near the
Affleck Portage Trail, which is about 25 miles south of the Project
Area. Wright filmy fern (Hymenophyllum wrightii) was found in Port
Beauclerc during a wilderness plant survey in early July 2007. Port
Beauclerc is about 30 miles south of the Project Area.
Until 2006, the Wright filmy fern had only been found on two sites on
Mitkof Island in the 1960s. In 2006, new information on how to locate
the species led to finding the fern at three new sites on Mitkof The
fern was also documented on Kupreanof and Etolin Islands in the
summer of 2006. As of spring 2007, no additional surveys for the fern
were conducted in the Project Area using the new search knowledge.
Sensitive plant surveys for the Project Area were conducted in 24 out
of 38 of the proposed units during the summers of 2003 and 2004
within habitats and microsites where activities were planned and
sensitive plants were most likely to be found. These sites included wet
seeps, wet meadows, stream banks, and rocky areas. Also, dark, damp
areas on downed logs and at the base of trees were searched for Wright
filmy fern. Areas with limestone substrates were also targeted in the
surveys. Approximately 50 percent of the proposed roads were also
surveyed. Areas outside of the proposed units, but within the Project
Area, were not surveyed except for the road leading to Units 402 and
403. One sensitive plant species was found, loose-flowered blue grass
{Poa laxiflora), along a stream below Unit 307. The population
consisted of about 25 individual plants on a rocky area near the edge
Kuiu Timber Sale FEIS
Chapter 3 • 103
3 Environment and Effects
of the stream. The plants are within the riparian buffer on the stream so
they are not within a proposed harvest unit. Unit 307 is proposed in
Alternatives 3, 4 and 5.
Rare plants were also recorded during the plant surveys. One rare
plant, Botrichium multifidiiin, was found near the proposed road
leading to Unit 419. The unit and road were later dropped due to high
vulnerability karst in the area. No other rare plants were found.
Table 3-42. Current Alaska Region sensitive plant species known or suspected
to occur on Petersburg Ranger District
Common Name
Scientific Name
Habitat description
Goose-grass sedge
Carex lenticularis van dolia
Wet meadows, snowbed
edges, and lakeshores in
alpine areas
Edible thistle
Cirsium edule
Wet meadows (muskegs) and
open forests
Davy mannagrass
Glyceria leptostachya
Wet areas, usually along
streams, ponds, and lake
margins
Wright filmy fern
Hymenophyllum wrightii
On the base of trees and rock
outcrops in damp humid
woods
Truncate quillwort
Isoetes truncata
Immersed in shallow
freshwater pools
Calder lovage
LIgusticum calderi
Alpine and margins of
subalpine and mixed conifer
stands, on limestone
Bog orchid
Platanthera gracilis
Wet meadows and wet open
habitats
Loose-flowered bluegrass
Poa laxiflora
Moist lowland woods, open-
forested meadows, upper
beaches, along streams
Kamchatka alkali grass
Puccinellia kamtschatica
Wet areas and sea beaches
Unalaska mist-maid
Romanzoffla unalaschcensis
Rock outcrops, along stream
banks, beach terraces, and
open rocky areas
Queen Charlotte
butterweed
Senecio moresbiensis
Alpine and subalpine with
open, rocky, or boggy slopes,
grassy talus slopes, or rocky
heaths. Usually on limestone
Circumpolar starwort
Stellaria ruscifolia spp.
aleutica
Moist, gravelly sites and
along creeks in mountains
104 • Chapter 3
Kuiu Timber Sale FEIS
3.6.3
Conclusions
TES Species
3.6.3.1 Direct and Indirect Effects
Wildlife Species
There would be no effects on any threatened, endangered, or sensitive
wildlife species other than the goshawk for any of the alternatives. For
goshawk, proposed timber harvest and road building activities in the
Project Area may impact individuals but are not likely to cause a trend
toward federal listing or a threat to population viability. Goshawk
nesting and foraging habitat would be reduced in all action
alternatives. Indirect effects may include reduction of prey species
habitat for goshawk as a result of old-growth habitat fragmentation.
Application of Forest Plan Standards and Guidelines will ensure that
no known goshawk nest sites would be disturbed by any of the
proposed activities.
Plant Species
The proposed timber harvest activities in the Project Area would not
have any direct effects on threatened, endangered, and sensitive plant
species. One sensitive plant species. Loose-flowered bluegrass {Poa
laxiflora), was found within the Project Area. It would not be directly
affected by the proposed alternatives since it is within a riparian buffer
along a stream that is outside any proposed harvest units or proposed
road construction or reconstruction. The nearest proposed units are
Units 307 and 308 which are across the stream and uphill from the site.
These units are proposed in Alternatives 3, 4 and 5.
Poa laxiflora populations have been documented in over 40 locations
on the Tongass with over 30 of those populations located on Kuiu
Island. Most populations are in the beach fringe buffer and Wilderness
areas which would not be affected by timber harvest. Even if the
population were indirectly affected by blowdown in a riparian buffer,
individual plants may be adversely impacted, but the event is not likely
to result in loss of viability or cause a trend to federal listing. Potential
indirect effects would not significantly add to cumulative impacts for
the species since it is relatively common and mostly protected from
adverse activities due to its likely habitat.
There is a possibility that undocumented sensitive species could be
impacted by the proposed project. The project may adversely impact
individual plants, but it is not likely to result in a loss of viability or
cause a trend to federal listing.
3. 6. 3. 2 Cumulative Effects
The Catalog of Events for Kuiu Island was referenced to determine
cumulative effects. There are no anticipated cumulative effects for all
Kuiu Timber Sale FEIS
Chapter 3 • 105
3 Environment and Effects
listed wildlife and plant species, with the exception of goshawk,
including the reasonably foreseeable future harvest of 482 acres from
the remaining Crane and Rowan Mountain Timber Sales EIS units.
With the harvest of the reasonably foreseeable future acres, the
cumulative harvest within the Project Area would be between 31
percent (No-Action alternative) and 36 percent (Preferred Alternative).
For goshawk, the Forest Plan projects that VCUs reaching a harvest
level of ^t least 47 percent of their original productive old-growth
(POG) may have an elevated risk of not sustaining goshawks in the
VCU, unless at least 6,700 acres of POG remain in the VCU. As
indicated above, the Project Area is still well below the 47 percent
harvest level, and the while the cumulative effects of all activities
within the Project Area may impact individuals, it is not expected to
contribute to a trend towards federal listing or cause a loss of viability
to the goshawk population.
106 • Chapter 3
Kuiu Timber Sale FEIS
3.7 Wildlife
3.7.1
Old-Growth
Forest Habitat
Conservation
Strategy
The Forest Plan contains a comprehensive conservation strategy to
assure viable and well-distributed wildlife populations (Forest Plan
FEIS Appendix, Volume 4, Appendix N 1997). There are two
components to this strategy: (1) establishment of a system of small,
medium, and large OGRs, and other non-development LUDs; and (2)
management of the matrix of lands where development that would
alter the old-growth forest ecosystem is allowed (productive old-
growth). Connectivity is provided by a combination of non-
development LUDs, such as small OGRs, Wilderness, beach and
estuary fringe, and riparian management areas.
3.7. 1.1 Large and Medium Old-growth Habitat Reserves
Currently there is one large OGR on Kuiu Island in the
Tebenkof/South Kuiu Wilderness Area, south of the Project Area.
Three medium OGRs, two are adjacent to the Project Area, one in
VCUs 400 and 401, and the other in VCUs 428 and 429. Three small
OGRs are within, or adjacent to, the Project Area. They are located in
VCUs 398, 399, and 402 (Figure 3-8).
3.7.1. 2 Small Old-growth Habitat Reserves
Small reserves serve two principal functions:
• act as corridors for habitat connectivity between large and medium
reserves, and
• serve as functional habitat for species less able to disperse between
larger reserves, specifically the flying squirrel, a species closely
associated with mature forests.
3. 7.1. 3 Design Options for the Small OGRs
In a meeting with the Forest Service (December 1, 1998 in Petersburg,
Alaska), the U.S. Fish and Wildlife Service (USFWS) and the Alaska
Department of Fish and Game (ADF&G) expressed concerns about the
size, shape, and connectivity of the small OGRs on Kuiu Island, and
options were designed for the OGRs of concern. An additional
meeting and field trip to Kuiu Island took place in 2004 to review the
proposed OGR changes suggested in the December 1998 meeting. The
agency representatives agreed concurred with recommendations. This
process is documented in “Revision to Existing Small Old-Growth
Habitat Reserves (OGRs) on Kuiu Island” and is included in the
planning record for this project.
Two options for the small OGR in VCUs 398, 399 and 404 were
compared in detail using the criteria from Appendix K of the Forest
Plan (Tables 3-12 through 3-14 and Figure 3-8). The options include
Kuiu Timber Sale FEIS
Chapter 3 • 107
3 Environment and Effects
the original Forest Plan design. Option 1, and the design developed by
USFWS, ADF&G, and the Forest Service during the 1998 meeting,
Option 2. Either option for each VCU would maintain connectivity to
other OCRs.
Keku Small OGR (VCU 398)
Option 1 VCU 398
This is the existing small OGR identified in the Forest Plan. It meets
the objectives of the standards and guidelines as designed, contains the
largest block of old growth within the watershed and maintains
connectivity to other OGRs. However, its shape is linear, and it
includes more acres of timber harvest than Option 2.
Option 2 VCU 398
Option 2 would increase the amount of POG from the original OGR
design by approximately 54 acres by expanding the western boundary
to make it more circular. It would still contain the largest block of old
growth within the watershed and maintain connectivity to other OGRs.
Table 3-43 and Figure 3-8 compare the Forest Plan small OGR with
the proposed OGR for VCU 398.
Saginaw Small OGR (VCU 399)
Option 1 VCU 399
This is the existing small OGR identified in the Forest Plan. The
Forest Plan small OGR did not meet Appendix K criteria for total
acreage.
Option 2 VCU 399
Option 2 would expand the OGR boundary to the south to meet the
Recreational River corridor, which maintains connectivity through a
travel corridor out of the VCU. This design excludes the small islands
off the coast of Kuiu Island which increases the fragmentation of
Option 1 OGR. Table 3-44 and Figure 3-8 display the small OGR
options for VCU 399.
Rowan Small OGR (VCU 402)
Option 1 VCU 402
This is the existing small OGR identified in the Forest Plan. The
Forest Plan small OGR did not meet Appendix K criteria for total
acreage.
Option 2 VCU 402
The boundary would be adjusted to exclude as many managed stands
as possible. The overall size would be increased to meet minimum
OGR size requirements. Table 3-45 and Figure 3-8 display the small
OGR options for VCU 402.
108 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
Table 3-43. Small old-growth habitat reserve options for VCU 398
Option 1
Option 2
General Criteria
a
Total acres - should be at least 2, 11 2 acres
2,244
2,472
b
Acres of POG - should be at least 1 ,056 acres
1,150
1,204
Shape
Linear
More Circular
Acres of early serai habitat included
215
126
Miles of NFS road included
0.13
1.09
Site-specific Factors
Acres of important deer winter range (FISI 0.6-1 .0)
412
391
Acres of high value marten habitat (FISI 0.9 - 1 .0)
391
413
Total acres of high volume strata
411
387
Total acres of medium volume strata
386
323
Total acres of low volume strata
535
494
Total acres below 1500 ft. elevation
2,244
2,472
Total acres below 800 ft. elevation
2,244
2,472
Contains the largest blocks of contiguous old-
growth within a watershed?
Yes
Yes
Known or suspected goshawk nesting habitat
Yes
Yes
Connectivity to other OCRs
Yes
Yes
Suspected marbled murrelet nesting habitat
Yes
Yes
Acres of coarse canopy forest
features
81
67
a
16 percent of VCU acres need to be within the small OGR
50 percent of the 16 percent must be in POG
Kuiu Timber Sale FEIS
Chapter 3 • 109
3 Environment and Effects
OCRs (Tables 3-43 to 3-45). The adjustments to boundaries in the
Option 2 designs change acres from a non-development LUD to a
resource development LUD or from a development LUD to a non-
development LUD. The adjustments to the Option 2 designs also
change the net acres suitable for timber management. The net change
would be a loss of 1,030 acres from development LUDs.
Table 3-44. Small old-growth habitat reserve options for VCU 399
Option
Option 2
General Criteria
b
Total acres - should be at least 4,088 acres
2,628
4,158
c
Acres of POG - should be at least 2,044 acres
2,386
3,770
Shape
Linear
Circular-Linear
Acres of early serai habitat included
154
99
Miles of NFS road included
2.91
4.75
Site-specific Factors
Acres of important deer winter range (HSI 0.6 - 1 .0)
508
523
Acres of high value marten habitat (HSI 0.9 - 1.0)
1,466
2,501
Total acres of high volume strata
1,462
2,623
Total acres of medium volume strata
422
852
Total acres of low volume strata
52
175
Total acres below 1500 ft. elevation
2,229
3,722
Total acres below 800 ft. elevation
1,893
2,082
Contains the largest blocks of contiguous old-growth
within a watershed?
Yes
Yes
Known or suspected goshawk nesting habitat
Yes
Yes
Connectivity to other OCRs
Yes
Yes
Suspected marbled murrelet nesting habitat
Yes
Yes
Acres of coarse canopy forest
features
815
1,454
a
Includes acres on several small islands off Kuiu Island shore
b
16 percent of VCU acres need to be within the small OGR
C
50 percent of the 16 percent must be in POG
110 • Chapter 3
Kuiu Timber Sale FEIS
I
h
IN
A
Legend
m
Old-growth Reserves
Non-development LUD
Non-national Forest
Saltwater
—
Project Area Boundary
VCU Boundary
KuprcanoF
Island
V
Kosciusko
Island
Kuiu Timber Sale
Figure 3-8
Small Old-Growth Reserve
Options in VCDs
398, 399 and 402
Legend
lllllllllli Forest Plan OGR (Option 1)
Interagency OGR (Option 2)
Recreational River
I . - ' I Lakes/Saltwater
I I Managed Stands
I I Non-National Forest
Forest Land Suitable for
Commercial Timber Production
Stream Value Class I & II
Project Area Boundary
VCU Boundary
— - Existing Open Roads
A
5
Wildlife
3. 7.1. 4 Cumulative Effects
The small OCRs in VCUs 419 and 420 were adjusted during the
Threemile Timber Sale and were analyzed in the Threemile Timber
Sale EIS. Proposed changes in small OGRs in VCUs 416, 417, and
418 will be analyzed when planning is done in those areas or as part of
the Forest Plan Amendment. These adjustments to the small OGRs
improve connectivity, increase the function of the OGRs, and help
meet the intent of the Forest Plan on a landscape scale.
Table 3-45. Small old-growth habitat reserve options for VCU 402
Option 1
Option 2
General Criteria
a
Total acres - should be at least 5,197 acres
4,008
5,279
b
Acres of POG - should be at least 2,599 acres
2,642
3,658
Shape
Linear
Linear
Acres of early serai habitat included
458
361
Miles of NFS road included
4.19
3.44
Site-specific Factors
Acres of important deer winter range (HSI 0.6 - 1 .0)
676
841
Acres of high value marten habitat (HSI 0.9 - 1 .0)
2,520
2,575
Total acres of high volume strata
1,787
2,575
Total acres of medium volume strata
495
712
Total acres of low volume strata
360
371
Total acres below 1500 ft. elevation
3,967
5,008
Total acres below 800 ft. elevation
3,480
4,317
Contains the largest blocks of contiguous old-growth within a
watershed?
No
Yes
Known or suspected goshawk nesting habitat
Yes
Yes
Connectivity to other OGRs
Yes
Yes
Suspected marbled murrelet nesting habitat
Yes
Yes
Rare features Acres of coarse canopy forest
749
67
a
16 percent of VCU acres need to be within the small OGR.
b
50 percent of the 16 percent must be in POG.
Kuiu Timber Sale FEIS
Chapter 3*115
Environment and Effects
3.7.2
Management
Indicator
Species
3.7.3
Endemic
Marten
Species
3.7.4
Marten Habitat
Capability
Model
Management indicator species (MIS) are those wildlife species whose
responses to land management activities can be used to predict the
likely response of a wide range of other species with similar habitat
requirements. Under the MIS concept, the responses to management
activities of relatively few species are studied and monitored in order
to predict the impacts to entire assemblages of species and associated
habitats. MIS are used to assess maintenance of population viability,
biological diversity, and management of game (Forest Plan FEIS).
The following Forest Plan MIS are known to occur on Kuiu Island:
Sitka black-tailed deer, Alexander Archipelago wolf, Vancouver
Canada goose, American marten, black bear, river otter, red squirrel,
bald eagle, red-breasted sapsucker, hairy woodpecker, and brown
creeper. Table 3-46 shows the MIS known to occur on Kuiu Island,
which species have been selected as MIS for this project, and a
rationale for that selection. The selected species are discussed in this
section and in the Wildlife Resource Report which can be found in the
Kuiu Project planning record.
American Marten
Marten was selected as an MIS because of its association with old-
growth and this habitat’s value to many other species including
goshawk. Marten (Martes caiirina) are endemic to Kuiu Island.
Recent studies have shown that about half of the Kuiu Island marten
population is Martes americana, common to nearby islands (Mitkof
and Kupreanof Islands) and mainland populations, and the remaining
population is Martes caurina that is endemic to Kuiu Island (Stone and
Cook 2002). The americana clade appear to be recent arrivals from
nearby islands. Due to the fact that very narrow stretches of saltwater
separate the islands of Mitkof, Kupreanof, and Kuiu from each other
and the mainland, the immigration of the americana clade appears to
be a natural occurrence (Cook et al. 2001). The two clades appear to
be hybridizing. More information on the occurrence of these unique
clades on Kuiu Island is available in Small et al. 2003, Stone and Cook
2002 and in the Wildlife Resource Report available in the planning
record.
The Forest Plan marten model (Alarid 1995, Primaky 2002) was
developed to evaluate and compare the potential quality of habitat for
marten. The model assumes that optimal habitat for marten must have
sufficient protective canopy cover, and available prey species. A
habitat suitability index (HSI) is assigned to areas based on volume,
stand size class (stand age), presence of beach fringe or riparian
habitat, and elevation. The model assumes that habitat with an HSI
116* Chapter 3
Kuiu Timber Sale FEIS
Wildlife
Table 3-46. Management Indicator Species
Management
Indicator Species
Potential
habitat in
Project
Area?
Carried forward for Kuiu Timber Sale
analysis?
Sitka Black-tailed
Deer
Yes
Yes - Important subsistence and game
species, uses low-elevation, old growth. See
Issue 2 in this chapter.
Alexander
Archipelago Wolf
Yes
Yes - Furbearer and game species, uses old-
growth for denning. May be affected by deer
populations.
American Marten
Yes
Yes - Furbearer, uses high volume old-growth
habitat.
Red Squirrel
Yes
No - There is no concern with red squirrel
habitat: leave trees, riparian buffers and the
matrix retain sufficient habitat.
River Otter
Yes
No - The majority of river otter habitat is
protected by Forest Plan Standards and
Guidelines.
Black Bear
Yes
Yes - Important game species. Bear hunting is
discussed in the Recreation section of this
chapter.
Bald Eagle
Yes
No - The majority of bald eagle nesting and
foraging habitat is protected by Forest Plan
Standards and Guidelines. The majority of
bald eagle nesting, roosting and foraging
habitat is protected by Forest Plan Standards
and Guidelines. An existing nest is located
next to the Rowan Bay LFT.
Hairy Woodpecker,
Brown Creeper, Red-
breasted Sapsucker
Yes
No - Habitat considerations are included in the
biodiversity and coarse canopy (i.e. old-
growth) analysis.
Vancouver Canada
Goose
Yes
No - Forest Plan Standards and Guidelines
protect primary habitat.
value of 1.0 is capable of supporting a marten population density of
2.7 marten per square mile. Figure 3-9 displays the high value marten
habitat capability values in the Project Area.
High value marten habitat is defined as high volume strata, old-growth
stands below 1,500 feet in elevation (Forest Plan FEIS pp. 3-354 and
3-360). The habitat model assigns these areas a suitability index (HSI)
of 0.9 and above. This habitat also represents important Queen
Charlotte goshawk nesting and foraging habitat (TPIT 1998). Coastal
beach fringe and riparian areas have very high values. Cavities in large
Kuiu Timber Sale FEIS
Chapter 3*117
3 Environment and Effects
boles of trees and snags, hard downed logs, and beneath tree roots are
most important for natal dens (Soutiere 1979, Spencer 1987 and
Campbell 1979). Marten were analyzed at the WAA level using the
most current version of the marten model. WAA 5012 currently
contains 51,614 acres of high value marten habitat.
Approximately 21,886 acres have been harvested within WAA 5012
since 1954, much of it clearcut. Table 3-47 compares the acres of high
value marten habitat of the historic (1954), and current (2006)
conditions to the proposed alternatives within WAA 5012. The table
shows that high value marten habitat acres has been reduced
approximately 29 percent from the historic condition and the reduction
in the acres of current high value marten habitat would range from less
than one percent in Alternative 2 to approximately two percent in
Alternatives 4 and 5.
Effects to high value marten habitat in Alternatives 2 and 3, and to a
lesser amount Alternative 4, were most likely overestimated as the
model analyzes all units as if they would be clearcut.
Table 3-47 High value marten habitat (HSI > 0.89) in WAA 5012 remaining
after harvest by alternative
Historic condition- 72,847 acres
Alternative
1
Current
condition
2
3
4
5
Acres remaining after harvest
51,614
51,211
50,984
50,438
50,676
Percent reduction from current
condition
0%
<1%
1%
2%
2%
Percent reduction from historic
condition
29%
30%
30%
31%
30%
3.7.5
Existing
Conditions
118* Chapter 3
Kuiu Timber Sale FEIS
I
Kmiakc 1
Bay
Kuiu Timber Sale
Figure 3-9
High Value Marten Winter Habitat
Legend
High Value Marten Winter Habitat HSI .9-1
I I Managed Stands
I I Non-National Forest
I I Lakes/Saltwater
I I Unit Pool
500 ft Contour Interval
Project Area Boundary
Existing Open Roads
Stream Value Class I & II
WAA5012 Boundary
A
0 0.5
3 4
Miles
Wildlife
3.7.6
Roads
Road density is not a component of the Habitat Capability Model.
However, studies have shown that road density may affect the quality
of habitat for marten through trapping (Suring et al. 1992).
ADF&G has expressed concern that the total road density is relatively
high on north Kuiu and that additional roads on Kuiu may increase the
potential hunter and trapper access and make a greater segment of the
island’s marten populations vulnerable to human caused mortality. In
addition, ADF&G has expressed concerned that low trapping success
may indicate low population density. They are concerned that
increasing fur prices may increase trapping effort and when combined
with the current road density it could potentially lead to over trapping.
However, ADF&G acknowledges that most of the historic and current
trapping effort for marten on Kuiu occurs from the shoreline.
Very few trappers use the road system to trap on Kuiu Island annually.
No permanent communities are on the island, and ferry service to the
island does not exist. The only areas available for trapping during the
winter are along Keku Strait (east side of Kuiu) shoreline and along
the road system from the Threemile LTF. All other access points are
extremely difficult to get to during the winter months due to severe
weather along Frederick Sound and Chatham and Sumner Straits.
Table 3-16 in Section 3.3 documents increased trapping mortality for
marten on Kuiu Island during years when temporary residents had
motorized access to the area.
There is little evidence of OHV use on most of the closed roads,
mainly due to the remoteness of Kuiu Island and the impassibility on
the roads once the stream crossings have been removed. Most personal
vehicle use on the island is in the form of pickup trucks, which cannot
navigate the alder or the mound and pit-type barriers normally found
on closed roads. Game trails along the closed roads are common.
Currently, the open road density in WAA 5012 is 0.46 mi/mi^. Total
road density in the WAA is 0.68 mi/mi^. Most of the former temporary
roads in the Project Area and WAA were closed by decommissioning
after their use was terminated. Closed roads generally have structures
(bridges and culverts) removed, intact water bars, and are grown in
with alder. Table 3-48 shows the open road densities by alternative
within WAA 5012 after implementation. All temporary roads would
be decommissioned and all NFS roads, new or reopened for the
project, would be placed into storage, effectively closing these roads to
all motorized vehicles after the completion of harvest activities. In
fact, all action alternatives would decrease the open road density
within the Project Area by placing some currently open roads into
Kuiu Timber Sale FEIS
Chapter 3 • 121
3 Environment and Effects
storage (see the Transportation section of this chapter for current and
proposed road densities by alternative).
Table 3-48. Open road density in WAA 5012
Alternative
Alt 1 (No-
Action
Alt 2
Alt 3
Alt 4
(Proposed
Action)
Alts
Proposed Open
Road Density
(mi/mi^) after
Harvest
0.46
0.42
0.42
0.41
0.41
At this time, ADF&G acknowledges it does not have a good
understanding of the current or historic marten populations, nor has it
limited the number of marten that may be trapped on Kuiu island
(pers. comm. Lowell 2006). The Forest Plan directs that where marten
data (harvest or population data) suggest that mortality exceeds
sustainable levels, the Forest Service will work with the ADF&G to
identify the probable sources of mortality, examining the relationship
between hunter/trapper harvest and human access. It further states that
where road access has been determined through the analysis to
significantly contribute to unsustainable marten mortality, effective
road closures would be implemented to reduce mortality (Forest Plan
p. 4-1 18). Neither the USFWS nor the ADF&G has indicated that
marten population or harvest data suggest that mortality on Kuiu
Island exceeds sustainable levels.
Alexander Archipelago Wolf
The Alexander Archipelago wolf was selected as an MIS because the
wolf is both hunted and trapped in Southeast Alaska. It is one of the
major predators in Southeast Alaska on deer and moose and helps
maintain healthy prey populations.
The Alexander Archipelago wolf occurs on the Southeast Alaska
mainland and on all large islands in Southeast Alaska except for
Admiralty, Baranof, and Chichagof (Person et al. 1996). 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 landform, climate, or vegetation
(Suring et al. 1994, Person et al. 1996). The wolf secondarily preys
upon beaver and moose, and, when available, spawning salmon and
waterfowl (Person et al. 1996). Wolves on Kuiu Island consume deer.
122 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
moose, black bear, mink, muskrats, marten, other rodents, waterfowl,
fish and grouse.
The Forest Plan initial direction was to maintain 13 deer/mi^ to support
wolves (Forest Plan p. 4-116). However, as a result of monitoring and
additional research, this was been changed to 1 8 deer/mi^ over broad
areas using the current deer habitat capability model (Monitoring and
Evaluation Report 2000, Person et al. 1996). Since wolves tend to have
home ranges that cross several WAAs, the appropriate scale at which
this model should be applied is the biogeographic province (USDA
1998 p. 16). However, the State of Alaska showed concern over the
ability of north Kuiu Island (WAA 5012) to support deer at a carrying
capacity high enough to support wolves. Therefore, the carrying
capacity was analyzed by both the biogeographic province (entire
Kuiu Island) and by WAA 5012. Table 3-49 displays deer densities.
Table 3-49. Habitat Capability Changes for Sitka Black-tailed Deer
1954
Alt 1
Alt 2
Alts
Alt 4
Alt 5
Deer density (mi/mf) to
support wolf and hunter
demand for WAA 5012
37
29
29
29
29
29
Deer density (mi/mF) to
support wolf and hunter
demand for Kuiu
biogeographic province
37
34
34
34
34
34
Deer density numbers used in Table 3-49 were generated by the deer
model. They are theoretical numbers which estimate the deer density
that the habitat can support and should be used with caution.
The IDT evaluated the impacts to wolves on an island-wide basis
(Kuiu Island Biogeographic Province). According to the deer winter
habitat capability model, Kuiu Island theoretically has enough habitat
to currently support 34 deer/mF and WAA 5012 currently has enough
habitat to support 29 deer/mi^. With the implementation of any action
alternative, the capability of the island and WAA to support deer
would not change measurably. Person et al. (1996) believes this is a
sufficient prey density to support a sustainable wolf population and
meet human deer harvest demands.
ADF&G Harvest Data
Ninety-four wolf pelts taken from WAA 5012 were turned in to the
Alaska Department of Fish and Game for sealing between 1990 and
2001 (Meucci 2005). The annual average harvest over the last twenty
Kuiu Timber Sale FEIS
Chapter 3 • 123
3 Environment and Effects
years is five wolves. Refer to the Subsistence section of this chapter
fora description ofWAA 5012.
Dens
Availability of suitable denning habitat is of secondary importance to
wolves. Dens are generally located in sites with good drainage and
within 100 meters of fresh water (Person et al. 1996).
During the 2003 field season, field crews located a probable wolf den
in the Project Area. The crew took photos and the crew leader
conferred with Dave Person from ADF&G. The prescribed 1,200-foot
buffer following Forest Plan direction (Forest Plan p. 4-1 13) has been
added to this site. The site was revisited during the 2004 and 2005
field seasons and found to be inactive.
Roads
The primary threat to wolf populations is high road densities and
increased access by humans who kill wolves legally and illegally by
shooting, snaring, or trapping (Person et al. 1996, Person 2001).
Person et al. (1996) found wolves on Prince of Wales Island (POW) to
be intolerant of open road densities that exceed 0.7- 1.0 mi/mi^, raising
a concern of maintaining viable populations. Person (2001) also found
that while wolves are susceptible to hunting and trapping from all
roads, there was an increase in wolf mortality from roads that were
connected to communities. In the POW study area, the roads were
attached to population centers; the island is serviced by the Alaska
Marine Highway ferry system. Also, the methods used to close roads
at the time of the study were not stopping motorized vehicle traffic.
Currently the open road density for Kuiu Island (Kuiu Biogeographic
Province) is 0.2 mi/mi^. The open road density in WAA 5012 is 0.42
mi/mi^. Total road density for WAA 5012 is 0.46 mi/mi^. However,
Kuiu Island is not connected to human population centers and is not
serviced by the Alaska State Ferry system. Closed roads on Kuiu have
bridges and culverts removed and are generally grown over with alder
which prevents motor vehicle traffic. As stated earlier, the average
annual wolf harvest since 1984 has been 5 animals. The harvest of
wolves is not expected to change due to the difficulty of accessing the
island. This project would not increase open road density. In fact, all
action alternatives for this project propose to reduce open road density.
Refer to the Transportation section of this chapter and the Road
Management Objectives in Appendix B for more information.
The Forest Plan directs that when wolf population data suggest
mortality exceeds sustainable levels, the Forest Service will work with
the ADF&G and the USFWS to identify probable sources of mortality
by examining the relationship between wolf mortality, human access.
124 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
and hunter/trapper harvest. It further states that when analysis
determines that road access significantly contributes to unsustainable
wolf mortality, effective road closures will be implemented (Forest
Plan p. 4-116). Neither the USFWS or the ADF&G has indicated that
wolf population or harvest data suggest mortality exceeds sustainable
levels on Kuiu Island.
Bald Eagle
The bald eagle population is widely distributed throughout Southeast
Alaska during the breading season. Bald eagles that breed along the
coast tend to remain close to their breeding territory throughout the
year if food is available. When not involved in nesting activities,
however, these birds may temporarily move to areas with abundant
food sources. Habitats commonly used include beach fringe, some
estuarine fringe and streamside riparian areas. Bald eagles may also
concentrate at feeding grounds in the spring. Throughout their range,
bald eagles are opportunistic in their use of available food resources.
The beach/estuary fringe and riparian buffers described in the Forest
Plan provide sufficient habitat for these animals. Forest Plan Standards
and Guidelines and the Bald Eagle Protection Act provide protection
for nesting and roosting habitat.
Existing Condition
A known bald eagle nest tree is directly adjacent to the Rowan Bay
LTF. The eagle moved into the current nest tree while the Alaska Pulp
Company’s long-term contract was in effect and built the nest next to
the refueling station for both equipment and helicopter operations. The
eagle did not seem disturbed by the activity including helicopter
landings at the refueling site and continued to successfully raise its
young for many years. Since the late 1990s the LTF has not been used
and the nest has not been monitored so the nest activity is not currently
known. After consultation with U.S. Fish and Wildlife Service (per
com Jacobson 2006), it is recommended that the nest be monitored in
the spring and that no heavy equipment be allowed within 330 feet of
the existing nest tree from March 1 to May 31. By May 31, if no eagle
nesting activity has occurred normal operations would be allowed to
continue. If the nest is active, heavy equipment would be excluded
around the nest site, including helicopter activity within % mile of the
nest tree, and the nest would be monitored for the effectiveness of
these guidelines.
Planned activities are not expected to adversely affect bald eagle prey
species or nesting habitat. As a result, this species will not be carried
forward in this analysis.
Kuiu Timber Sale FEIS
Chapter 3 • 125
3 Environment and Effects
3.7.7
Effects
Common to All
Alternatives
3.7.7. 1 Alexander Archipelago Wolf
The island-wide deer density would remain above 34 deer/mi^ after
harvest in all alternatives. The resulting deer density is sufficient to
support a viable wolf population and meet hunters’ demands.
Historically, few wolves have been harvested annually on Kuiu Island.
Small wolf harvests are likely to continue on Kuiu Island due to the
limited access during the trapping season. Only the eastern portion of
the island is vulnerable to trapping from the beach. Hunting pressure is
limited because the road system is not connected to the Alaska Marine
Highway, and, while not impossible, it is difficult to transfer a vehicle
to the road system. Therefore, an increase in trapping pressure is not
anticipated on Kuiu Island due to limited access and the absence of
permanent logging camps or communities.
Alternative 1 would have no impact to road density. For all action
alternatives, open road density both island-wide and for WAA 5012
would temporarily increase during the life of the timber sale; however,
there would be a decrease in current open road density with the
completion of timber harvest activities. Island-wide open road density
would decrease to 0. 1 8 with implementation of any action alternative
and the WAA road density would decrease to 0.42 or 0.41 depending
on the selected action alternative. From discussions with Alaska
Department of Fish and Game, there is agreement that road impacts
are not expected to substantially reduce wolf populations within WAA
5012, or affect overall wolf distribution (Lowell 2006).
3.7.8
Comparison of
Alternatives
for
Management
Indicator
Species
3. 7.7.2 Road Density
Open road density in WAA 5012 is currently 0.46 mi/mP. All action
alternatives would reduce the open and drivable road densities. Island-
wide open road densities are 0.20 mi/mi^ and would be reduced to 0.18
mi/mi^ with the implementation of any action alternative. Roads which
are currently closed to motor vehicles would be reopened and
reconditioned to access timber then returned to storage condition. All
new reconditioned roads and some miles of currently open NFS roads
would be effectively closed to motorized traffic. Temporary roads
would be decommissioned (see the Transportation section in this
chapter).
3. 7.8.1 Alternative 1
This alternative proposes no new activities in the Project Area.
Wildlife habitat may decline in current second-growth stands as they
develop and the understory forage is shaded. There would be no
change in the current road network.
High value marten habitat has been reduced by 29 percent since 1954
in WAA 5012. No additional reductions would be expected with this
alternative.
126 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
5.7.8.2 Alternative 2
Alternative 2 proposes harvest on 478 acres. Harvest prescriptions
include 280 acres of partial harvest with 50 percent basal area
retention and 197 acres of clearcut.
Marten, deer and wolf would unlikely be adversely affected by this
alternative since 281 acres (59 percent of the acres harvested) are in
partial harvest prescriptions that retain 50 percent of the basal area,
which would help maintain a natural forest mosaic and retain habitat
for all the above species. Road closures would reduce hunter
accessibility. The Forest Plan deer and marten models report all units
as harvested by an even-aged prescription, so the model would
overestimate the number of acres of high value habitat removed using
partial harvest.
The current high value marten winter habitat would be reduced by less
than one percent. This reduction is most likely overestimated because
the habitat capability model does not account for partial harvest.
Partial harvest is planned in Units 109b, 111, 207, 209, 404, 405, 415
and 418 and equals 59 percent (281 acres) of the acres harvested by
this alternative. Within these partial harvest units, 60 acres are low
elevation, high volume habitat. The use of partial harvest would help
maintain marten habitat suitability with the retention of some old-
growth characteristics, such as cover, large standing and down trees
for denning and resting sites, and travel corridors. With 50 percent of
the basal area retained, the coarse structure within the stand would be
maintained until the harvested portion could recover and begin to
contribute to the stand structure and cover.
Alternative 2 would harvest 197 acres using even-aged management
(clearcutting). Within these acres, portions of the following units
would occur within low elevation, high volume habitat: 103c, 103d,
208a, 208b, 416 and 417 (totaling 41 acres). Marten have been shown
to avoid clearcut harvest areas for up to 40 years after harvest
(Thompson 1988).
3. 7. 8. 3 Alternative 3
Alternative 3 proposes harvest on 786 acres. Harvest prescriptions
include 377 acres of partial harvest with 50 percent basal area
retention and 409 acres of clearcut harvest.
Marten, deer and wolf would unlikely be adversely affected by this
alternative since 377 acres (48 percent of the acres harvested) are in
partial harvest prescriptions that retain 50 percent of the basal area,
which would help maintain a natural forest mosaic and retain habitat
for all the above species. Road closures would reduce hunter
accessibility.
Kuiu Timber Sale FEIS
Chapter 3 • 127
3 Environment and Effects
Alternative 3 would reduce the current high value marten winter
habitat by approximately one percent, and this reduction is most likely
overestimated because the habitat capability model does not account
for partial harvest.
Partial harvest is planned in Units 109, 112, 204, 207, 209, 404, 405
and 417 and is 58 percent (377 acres) of the acres harvested by this
alternative. Within these partial harvest units, 57 acres are low
elevation, high volume habitat. The use of partial harvest would help
maintain marten habitat suitability with the retention of some old-
growth characteristics, such as cover, and large standing and down
trees that can be used for denning and resting sites, as well as help
maintain travel corridors for marten. With 50 percent of the basal area
retained, the coarse structure within the stand would be maintained
until the harvested portion could recover and begin to contribute to the
stand structure and cover.
Alternative 3 would harvest 409 acres using even-aged management
(clearcutting). Within these acres, portions of the following units
would occur within low elevation, high volume habitat: 109, 208 210,
308, 403, and 416 (totaling 25 acres). The coarse stand structure would
be removed and could take 100-150 years to return to the stands.
3. 7.8.4 Alternative 4
Alternative 4 proposes harvest on 1,387 acres. Harvest prescriptions
include 361 acres of partial harvest with 50 percent basal area
retention and 1,026 acres of clearcut.
Of the action alternatives, this alternative would have the greatest
affect to wildlife since it harvests the most forest and removes the
greatest amount of habitat.
Alternative 4 would reduce the current high value marten winter
habitat by two percent, but this reduction is likely overestimated
because the habitat capability model does not account for partial
harvest.
Partial harvest is planned in Units 207, 209, 303, 305a, 305b, 414, and
415 and equals 26 percent (363 acres) of the acres harvested by this
alternative. Within these partial harvest units, 1 12 acres are low
elevation, high volume habitat. The use of partial harvest would help
maintain marten suitability with the retention of some old-growth
characteristics, such as cover, and large standing and down trees that
can be used for denning and resting sites. Partial harvest would also
help maintain travel corridors for marten. By retaining 50 percent of
the basal area, the coarse structure within the stand would be
maintained until the harvested portion recovers and begins to
contribute to the stand structure and cover.
128 • Chapter 3
Kuiu Timber Sale FEIS
1 3.7.9
Cumulative
Effects for
Management
Indicator
Species
Wildlife
Alternative 4 would harvest 1,025 acres using even-aged management
(clearcutting). Within these acres portions of the following units would
occur within low elevation, high volume habitat: 109, 208 210, 308,
403, and 416 (totaling 147 acres). Marten have been shown to avoid
clearcut harvest areas for up to 40 acres after harvest (Thompson
1988).
3. 7.8. 5 Alternative 5
Alternative 5 proposes harvest of 1,208 acres, all of which would be
clearcut harvested.
Alternative 5 would reduce the current high value marten winter
habitat by two percent.
Alternative 5 would harvest 1,208 acres using even-aged management
(clearcutting). Within these acres, portions of the following units
would occur within low elevation, high volume habitat: 111, 112,
208a, 208b, 209, 210, 308, 401, 403, 404, 412, 416, 417, 418, and 503
(totaling 156 acres). Marten have been shown to avoid clearcut harvest
areas for up to 40 years after harvest (Thompson 1988).
3.7.9.1 Past, Present, and Reasonably Foreseeable Future
Timber harvest has occurred on much of the northern portion of Kuiu
Island. This harvest was mostly to fill the needs of the long-term sale
program starting in 1968. Kuiu Island was an alternate area for the
Alaska Pulp Corporation long-term sale. The Kuiu Catalog of Events
is located in the planning record and was referenced to determine
cumulative effects. All timber harvest in WAA 5012 from the four
acres harvested in 1931 to the planned, but unharvested units from
Crane and Rowan Mountain Timber Sales and Threemile Timber Sale
EISs have been accounted for in this analysis. All non-harvest
activities were reviewed for possible impacts to wildlife species as
well.
Most of the previously harvested units have been treated once with
silvicultural thinning. Wildlife would benefit from the thinning,
girdling and/or pruning treatment to approximately 1,475 acres of 39-
year-old second-growth stands within the Saginaw watershed. The
IDT has visited these units and has determined that it would be
beneficial to prescribe treatments to extend the usefulness of the
wildlife habitat. The judicious use of silvicultural treatments can
extend productive time that harvested units provide suitable habitat.
Planned Projects
For the Kuiu Timber Sale action alternatives, an individual timber sale
or more than one sale over a period of several years, may occur.
Kuiu Timber Sale FEIS
Chapter 3 • 129
3 Environment and Effects
It is reasonable to assume that timber harvest and associated road
management will continue on Kuiu Island. The current Tongass timber
sale schedule lists other timber sale projects:
• Crane and Rowan Mountain Timber Sales ROD was signed June
1998 and is considered in cumulative effects. Approximately 482
and 745 acres were considered as reasonable future foreseeable
harvest in the Project Area and WAA 5012, respectively (refer to
the Changes Between DEIS and EIS section in Chapter 2).
• Threemile Timber Sale ROD was signed in April of 2004. The
Threemile Timber Sale will harvest approximately 19.5 mmbf on
approximately 665 acres and construct 4.2 miles of new NFS roads
and 4.2 miles of temporary roads.
Marten
High value marten habitat has been reduced by 29 percent in WAA
5012 since 1954. Depending on the alternative selected, an additional
reduction of less than one percent to two percent would occur within
WAA 5012 with the implementation of the action alternatives. The
reasonably foreseeable future harvest of the Crane and Rowan
Mountain Timber Sales units would further reduce the high value
marten habitat by 1 percent. This would bring the cumulative
reduction of high value habitat to between 30 and 32 percent.
The Forest Plan FEIS (pp. 3-398 to 3-399) predicts there is a relatively
high likelihood of sustaining viable marten populations when an
average of 57 percent of the POG is retained within the matrix of
development LUDs. Other factors contributing to sustaining viable
marten populations include riparian management, the OGR system,
and use of partial harvest management in high value marten habitat.
Currently, 75 percent of the matrix POG has been retained in the
WAA. Adoption of the design changes to the small OGRs within
VCUs 398, 399, and 402 would improve marten habitat within these
reserve systems.
ADF&G is concerned about the apparent low numbers of marten on
Kuiu (Flynn et al. 2004) but admits that it is not possible to relate the
low population to trapping or loss of habitat on the island, as no
historic or current population information is available (pers. com.
Fowell 2006). Their concern is that the cumulative reduction in habitat
would further restrict and reduce population levels. Analysis of high
value marten habitat shows that WAA 5012 would retain
approximately 50,000 acres of high value marten habitat after
implementation of any of the action alternatives and the reasonably
foreseeable future harvest of the remaining units from the Crane and
Rowan Mountain Timber Sales EIS. From this analysis, habitat would
130 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
remain plentiful within WAA 5012 to sustain viable marten
populations.
Wolf
The cumulative effects analysis includes activities (past, current and
reasonably foreseeable future) within the Kuiu Biogeographic
Province that may affect wolves. Deer are a primary prey item;
therefore, a reduction in deer populations may effect wolf populations.
Historic important deer winter range has been reduced by 1 5 percent at
the island-wide level and the action alternatives would further reduce
important deer winter range by less than one percent. The harvest of
the Crane and Rowan Mountain Timber Sales EIS and Threemile
Timber Sale EIS units would further reduce important deer winter
range by less than one percent for all action alternatives. This small
reduction in important deer winter range would have no measurable
effect to wolf populations. In addition, the Forest Plan predicts that
Kuiu Island would maintain at least 1 8 deer per square mile at the end
of the rotation in 2059 (page 3-379 TEMP FEIS Part 1 ). This is a
sufficient prey density to support a sustainable wolf population and
meet human deer harvest demands (Person et al. 1997).
The Kuiu Biogeographic Province has an open road density of 0.2
mi/mi^. Implementation of any action alternative along with the
implementation of the Crane and Rowan Mountain Timber Sales EIS
or Thi'eemile Timber Sale EIS would reduce island-wide road densities
to 0.18 mi/mP.
Historically, there have been a small number of wolves harvested
annually on Kuiu Island. An increase in trapping pressure on Kuiu
Island is not anticipated since there are no permanent logging camps or
communities present on the island.
S.7.9.2 Coarse Canopy
Coarse canopy is best portrayed by volume class 6 and 7 and described
as high volume - coarse texture. The terms “large diameter tree
forests” and “coarse canopy” are used to describe these stands.
Table 3-50 displays the existing amount of coarse canopy in the
Project Area (Alternative 1), and the amount of coarse canopy
proposed for harvest by alternative. Within the Project Area coarse
canopy is fairly evenly scattered.
Kuiu Timber Sale FEIS
Chapter 3 • 131
Environment and Effects
Table 3-50. Acres of coarse canopy (Volume Class 6 and 7)
harvested by alternative and proportions of coarse
canopy within the Project Area
Project Area coarse
canopy
Alt1
Alt 2
Alts
Alt 4
Alts
Current acres of POG 30,586 current acres coarse canopy 13,009
Acres of coarse
canopy proposed for
clearcut harvest
0
95
172
510
541
Acres of coarse
canopy proposed for
partial harvest
0
123
155
274
0
Acres of coarse
canopy remaining
after harvest
13,009
12,791
12,682
12,225
12,468
Percent of current
coarse canopy
remaining after
harvest
100%
98%
97%
94%
96%
Proportion of POG that
is coarse canopy after
harvest
43%
42%
43%
42%
42%
These stands have low to moderate densities of tall, large diameter
trees that are evenly distributed. These stands are considered to be
important to some old-growth associated species and may have areas
containing the highest biological diversity (Caouette et al. 2000).
Within WAA 5012 and the Project Area the current amount of coarse
canopy forest is much higher than the Tongass average (4 percent).
The amount of historic coarse canopy that occurred prior to any
harvest is unavailable and it is not possible to accurately analyze the
cumulative amount of coarse canopy that has been harvested.
However, by looking at the locations of the current high volume (class
6 and 7) stands and the managed stands in Figure 3-4 it is possible to
theorize that much of the past harvest was in coarse canopy stands.
Table 3-50 shows that the proportion of coarse canopy to POG within
the Project Area would remain consistent with all alternatives.
Alternative 1 would not remove any coarse canopy forest nor change
the proportion of coarse canopy to POG within the Project Area.
132 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
Alternative 2 would harvest the fewest acres of coarse canopy among
the action alternatives (218 acres). Approximately 99 percent of the
current amount of coarse canopy would remain in WAA 5012 if this
alternative were implemented.
Approximately 123 acres (56 percent) of the proposed harvest units
within coarse canopy forests would be partial harvest to help retain
some habitat structure, including a large tree component within the
stands. Units proposed for partial harvest that include coarse canopy
are: 207, 209, 405, and 415.
This alternative would also harvest 95 acres of coarse canopy forest
using even-aged management (clearcutting). The coarse stand structure
would be removed and could take in excess of 100-150 years to
reestablish. Units with coarse canopy that are proposed for clearcut
include: 103c, 103d, 207, 208a, 208b, 416, and 417.
Alternative 3 would harvest 327 acres of coarse canopy forest, of
which 155 acres are partial harvest. Approximately 99 percent of the
current amount of coarse canopy would remain in WAA 5012 if this
alternative were implemented.
The partial harvest would help retain some habitat structure, including
a large tree component, forage, and canopy cover within the stands.
Units proposed for partial harvest that contain portions of coarse
canopy are: 109, 1 12, 204, 207, 209, 404, 405, 409, and 417.
This alternative would also harvest 172 acres of coarse canopy forest
using even-aged management (clearcutting). The coarse stand structure
would be removed and could take in excess of 100-150 years to return
to the harvested stands. Units with portions of coarse canopy that are
proposed for clearcutting are: 109, 207, 208, 210, 308, 403, 410, and
416.
Alternative 4 would harvest the most acres of coarse canopy of the
action alternatives (784 acres). Approximately 96 percent of the
current amount of coarse canopy would remain in WAA 5012 if this
alternative were implemented.
Approximately 274 acres of course canopy forest are proposed for
partial harvest. This would help retain some habitat structure,
including a large tree component within the stands. Units proposed for
partial harvest that contain portions of coarse canopy are: 207, 209,
302, 303, 305a, 305b, 414, and 415.
This alternative would also harvest 510 acres of coarse canopy forest
using even-aged management (clearcutting). The coarse stand structure
would be removed and could take in excess of 100-150 years to return
to the stands. Units with portions of coarse canopy that are proposed
Kuiu Timber Sale FEIS
Chapter 3 • 133
3 Environment and Effects
for clearcutting are; 101, 109, 111, 112, 207, 208, 2 1 0, 2 1 1 , 2 1 2, 308,
401, 402, 403, 404, 405, 409, 410, 412, 416, 418, 503, and 504.
Alternative 5 would clearcut harvest the most coarse canopy habitat
(541 acres). Approximately 98 percent of the current amount of coarse
canopy would remain in WAA 5012 if this alternative were
implemented. The coarse stand structure would be removed and may
take in excess of 100-150 years to return to the harvested stands.
Units with portions of coarse canopy that are proposed for clearcutting
include: 101, 109, 1 1 1, 1 12, 204, 207, 208a, 208b, 209, 210, 21 1, 212,
308, 401, 402, 403, 404, 405, 409, 410, 412, 416, 417, 418, 503, and
504.
Cumulative Effects
The cumulative effects analysis area for coarse canopy is WAA 5012.
The WAA was selected as the analysis landscape scale since it is the
same scale used for analysis of most Management Indictor Species.
Currently 22,956 acres or 18 percent of WAA 5012 is coarse canopy
forest. The proportion of POG that is coarse canopy is approximately
43 percent.
In Alternative 1, no harvest or road building would occur within the
Project Area at this time. However, this area is within a Timber
Production LUD and it should be assumed that it will be harvested in
the future.
Currently 22,956 acres or 16 percent of WAA 5012 is coarse canopy
forest. The proportion of POG that is coarse canopy is approximately
25 percent. Old growth stands with coarse canopy would continue to
support wildlife at their current capability at least until the next
planning cycle.
Of the action alternatives. Alternative 2 would harvest the fewest
acres of coarse canopy (218 acres) with approximately 99 percent of
the existing coarse canopy in WAA 5012 remaining. Approximately
56 percent of the coarse canopy acres proposed for harvest would be
partial harvest. These units include 207, 209, 405, and 415. Units with
coarse canopy proposed for clearcut are 103c, 103d, 207, 208a, 208b,
416, and 417.
Of the action alternatives, Alternative 3 would harvest the second
fewest acres of coarse canopy (327 acres) with approximately 99
percent of the existing coarse canopy remaining in WAA 5012.
Approximately 47 percent of the acres in this alternative with coarse
canopy are partial harvest, which would retain habitat structure
including a large tree component within the stands. Units proposed for
134 • Chapter 3
Kuiu Timber Sale FEIS
3.7.10
Migratory
Birds
Wildlife
partial harvest that contain portions of coarse canopy are 109, 112,
204, 207, 209, 404, 405, 409, and 417. Units with portions of coarse
canopy that are proposed for clearcutting are 109, 207, 208, 210, 308,
403,410, and 416.
Of the action alternatives. Alternative 4 would harvest the most acres
(948) and highest proportion of coarse canopy. Approximately 97
percent of the existing coarse canopy would remain in WAA 5012 if
this alternative were implemented.
Approximately 35 percent of coarse canopy acres harvested in this
alternative would be partial harvest. Units with this prescription
include 207, 209, 302, 303, 305a, 305b, 414, and 415. Units with
portions of coarse canopy proposed for clearcutting are 101, 109, 111,
1 12, 207, 208, 210, 211, 212, 308, 401, 402, 403, 404, 405, 409, 410,
412,416,418, 503, and 504.
Of the action alternatives. Alternative 5 would harvest the second
greatest number of acres (514) of coarse canopy with the highest
number of acres clearcut. Approximately 98 percent of the current
amount of coarse canopy would remain in WAA 5012 if this
alternative were implemented.
All units are proposed for clearcutting, and units with portions of
coarse canopy include: 101, 109, 111, 112, 204, 207, 208a, 208b, 209,
210, 211, 212, 308, 401, 402, 403, 404, 405, 409, 410, 412, 416, 417,
418, 503, and 504.
The Migratory Bird Treaty Act is the domestic law that affirms, or
implements, the United States' commitment to four bilateral
international conventions (with Canada, Japan, Mexico, and Russia)
for the protection of a shared migratory bird resource. Each of the
conventions protects selected species of birds that are common to each
country (i.e., they occur in both countries at some point during their
annual life cycle). The list of migratory bird species protected under
these treaties is filed in the planning record (U.S. Fish and Wildlife
Service 2004).
Existing condition
Executive Order 13186 of January 10, 2001, directs federal agencies to
evaluate the effects of actions and agency plans on migratory birds,
with emphasis on species of concern. A report entitled “Neo-tropical
Birds of Concern on the Tongass National Forest - Kuiu Timber Sale
Area” is filed in the planning record. The report includes a discussion
of 40 protected migratory bird species that may occur on the Tongass
National Forest, and any anticipated effects to these species from the
proposed activities for this project. The report concludes that proposed
activities for this project are not expected to result in measurable
Kuiu Timber Sale FEIS
Chapter 3 • 135
3 Environment and Effects
negative effects to any migratory bird populations for the following
reasons:
• Eighteen of the migratory bird species considered important on the
Tongass National Forest do not occur in habitats where forest
management activities would likely take place. These habitats are
either not impacted by management activities such as logging and
road building, or are protected by Forest Plan LUDs.
• Two migratory bird species are extremely rare on the Tongass
National Forest but their habitat may be impacted by management
activities. These species are associated with riparian shrub and
alder thickets. No timber harvest in this habitat type is proposed for
this project.
• Eight migratory bird species are uncommon on the Tongass
National Forest but could be disturbed by management activities
on the Tongass National Forest. Forest Plan Standards and
Guidelines and LUD allocations should protect sufficient habitat
for these species.
• Twelve species are common or abundant within habitats where
forest management activities may take place. Potential
disturbances may occur to their habitat, but Forest Plan Standards
and Guidelines and LUD allocations should protect sufficient
habitat for these species.
Direct, Indirect and Cumulative Effects
Some direct effects to nesting birds would occur in all of the action
alternatives. The primary effect would be loss of habitat, nest
destruction, or abandonment. The magnitude of the effects would vary
depending upon the alternatives selected and in which season harvest
would occur. Nesting in Southeast Alaska generally begins in May. By
September, the birds are fledged and would not be directly affected.
Indirect effects would be associated with fragmentation and patch size
reduction of suitable habitat. For species such as the northern
goshawk, marbled murrelet, and Townsend’s warbler, habitat removal
would affect forest fragmentation by potentially reducing the
effectiveness of interior habitat and increasing the potential for nest-
site predation from avian predators that are associated with forest
edges and fragmented landscapes.
The retention of approximately fifty percent of the existing overstory
in many of the action alternatives would help mitigate many of these
effects by providing reserve trees and increasing habitat values to these
birds when compared to even-aged silvicultural prescriptions. The
OGR system was designed to maintain large areas of habitat for these
136 • Chapter 3
Kuiu Timber Sale FEIS
Wildlife
species. That, in combination with the management of the matrix
within the lands open to harvest, would mitigate many of the effects of
harvest on neotropical migratory birds. Other species may be more
associated with forest edge, riparian or more open habitats; therefore,
the effects from timber harvest could be beneficial to other bird
species. Individual birds may be affected, but the design of the
alternatives, in conjunction with the management of the matrix and the
OCRs, will meet the requirements of habitat for these bird species and
maintain them within the Tongass National Forest.
Kuiu Timber Sale FEIS
Chapter 3 • 137
3.8.1
Introduction
3.8 Timber and Vegetation Resources
The 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 and
scattered Alaska yellow-cedar. Higher percentages of Sitka spruce are
found along streams and other well-drained sites. The understory
shrubs are 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.
3.8.1. 1 Analysis Area
This section covers the timber and vegetation resource for the Project
Area (VCUs 399, 400, 402, 421) and the lands immediately adjacent to
these VCUs. It tiers to infonnation found in the Tongass Land
Management Plan Revision for the timber resource. TLMP states that
for the purposes of determining limitations on the scheduling, locating,
and calculating the size of additional openings, the adjoining area’s
vegetation would be adequately stocked with desirable tree species
five feet in height. If not, the adjoining area must be considered as an
additional part of the proposed opening. Page references include Forest
Plan FEIS p. 3-248 through 3-307, Appendix B, Modeling and
Analysis Process, and Appendix G, Silvicultural System (USD A
Forest Service 1997).
3. 8. 1.2 Methods
During the 2003 and 2004 field seasons, the Petersburg Ranger
District’s Integrated Resource Inventory Crew collected data in the
Project Area. Information collected contributed to the development of
site specific Silvicultural Diagnosis, Logging Systems, and
Transportation Analysis by timber stand. This analysis included stream
and wildlife surveys and the identification of soils that have a high
potential for mass wasting. This information is located in the planning
record.
Table 3-51 and Table 3-52 display the species composition by volume
for productive forest land in the Project Area and the species
composition in the proposed harvest units for each action alternative.
138 • Chapter 3
Kuiu Timber Sale FEIS
Timber and Vegetation
Table 3-51. Species composition of forest lands in the Kuiu
Timber Sale Area
Species
Percent Volume
Western hemlock
82
Sitka spruce
16
Alaska yellow-cedar
2
Western redcedar
0
Table 3-52. Timber volume (mbf) and species composition proposed for harvest by
alternative
Species
Alternative
Alt 1
Alt 2^
Alt 3
Alt 4
Alt 5
Sitka spruce
N/A
1,988
(21%)
3,189
(20%)
6,738
(20%)
6,009
(19%)
Western
N/A
7,470
12,419
26,025
24,873
hemlock
(78%)
(78%)
(78%)
(79%)
Alaska yellow-
N/A
158
251
537
473
cedar
(2%)
(2%)
(2%)
(2%)
Western
redcedar
N/A
0
0
0
0
Total (mbf)
N/A
9,617
15,859
33,330
31,354
'Percentages do not add up to 100% due to rounding.
3.8.2
Forest Land
Classification
National Forest System (NFS) lands are delineated 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 forest vegetation, with further divisions to show the
amount of forest vegetation capable of commercial timber production.
Chart 3-3 shows the NFS land classifications in the Project Area.
3.8.2. 1 Non-Productive Forest Land
Non-productive forest land comprises about 16 percent of the NFS
land in the Project Area. Non-productive forest land is forested land
that does not support enough timber volume to meet the criteria for
productive forest land.
Kuiu Timber Sale FEIS
Chapter 3 • 139
3 Environment and Effects
3. 8. 2. 2 Forested Land
These lands comprise about 98 percent of the NFS land in the Project
Area. Forested land is land with at least 10 percent tree cover. Land
formerly having had such tree cover and is not developed for non-
forest use is also forested land.
3.8.2. 3 Non-Forest Land
Non-forest land comprises about two percent of the NFS land in the
Project Area. Non-forested land is land that has never supported forest
and lands fonnerly forested but now developed for nonforest uses.
3.8.2.4 Productive Forest Land
These lands comprise about 82 percent of the NFS land in the 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 and
maintain that volume. Productive forest land is capable of producing
20 cu ft/acre/year of industrial wood or has a site index of 40.
Productive forest land does not necessarily mean that the stand is
within the timber base of lands that are available for commercial
timber harvest.
Chart 3-3. Forest land classification in the Kuiu Timber Sale Area
140 • Chapter 3
Kuiu Timber Sale FEIS
3.8.3
Volume
Classification
Timber and Vegetation
3.8.2. 5 Unsuitable Forest Lands
About 22 percent of the productive forest land in the Project Area is
classified as unsuitable for timber production. Land on slopes greater
than 72 percent that have unstable soils and areas within riparian,
beach and estuary buffers are examples of unsuitable forest lands.
3.8.2. 6 Suitable Forest Land
About 78 percent of the productive forest land in the Project Area is
classified as suitable for timber production. Within areas of productive
forest land some land was removed from the suitable timber base
(unsuitable forest lands) due to Forest Plan Standards and Guidelines.
What is left is detenuined suitable for timber production. Appendix A
of the Forest Plan describes the process that was used to identify
suitable forest land.
3.8.3. 1 Volume Strata
The Forest Plan’s volume strata classification system was used for
estimating timber volumes and vegetation structure in the Project
Area. The strata system combines the existing timber inventory
volume classes with additional information on soils and slope to group
the strata. These volume strata are grouped as follows:
High Volume Strata are 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 Strata are 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 non-hydric
soils, or are on hydric soils with slopes greater than 55 percent. Low
Volume Strata are areas within mapped timber inventory volume
class 4 on hydric soils with slopes less than or equal to 55 percent.
Estimated timber volumes for the Kuiu Timber Sale Area are based on
stand exams performed in 2003 and 2004 (Tables 3-53 and 3-54).
Actual timber volume would be determined from a timber cruise prior
to advertisement of the timber sales offered.
Table 3-53. Volume strata in the Kuiu Timber Sale Area
Strata
Average
a
Vol/Acre
Productive
b
Forest Acres
Suitable Acres
Low
17 mbf
650
454
Medium
27 mbf
5,211
3,790
High
44 mbf
21,251
16,082
Kuiu Timber Sale FEIS
Chapter 3 • 141
Environment and Effects
3.8.4
Silvicultural
Systems
Table 3-54. Volume strata acres harvested by alternative
Strata®
Acres
in
Project
Area
Alt 1
Alt 2
Alt 3
Alt 4
Alts
High
21,251
0
388
620
1,152
929
Medium
5,211
0
64
133
183
224
Low
650
0
18
21
30
30
a
Does not include non-productive forest acres within Project Area or units
Silvicultural systems are used to manage, harvest, and re-establish
stands of forest trees for the purpose of meeting management
objectives. Silvicultural systems have been developed to produee more
valuable eommereial timber at a faster rate, maintain wildlife habitat,
and either maintain or enhance seenery values. No single silvicultural
system for a forest stand ean be used to achieve all of the desired
eonditions, but a variety of treatments applied over the Project Area
would result in a mosaie of stands for different uses. Three
silvicultural systems and three harvest methods were eonsidered for
the Projeet Area. Often the proposed treatments are designed to
emulate natural disturbance. The Forest Plan (Appendix G) provides
detailed infomiation about the silvicultural systems recommended for
the Tongass National Forest.
The Kuiu Timber Sale Project Area analysis used a variety of
silvicultural systems tailored to site-specific objectives. The objectives
include:
• Retain stand legacy or old-growth characteristics to maintain
biodiversity,
• Provide for positive eeonomic return and reasonable logging
feasibility,
• Provide a reasonable assuranee of windfirm riparian buffers where
there is signifieant windthrow risk,
• Proteet the soil, watershed, wildlife habitat, and scenery
eharaeteristies of the Project Area, and
• Produce wood-fiber for human use.
A complete silvieultural preseription for the entire length of the
rotation has been written for eaeh stand seleeted for harvest. These
preseriptions provide guidance for treatments following the proposed
timber harvest for this projeet, ineluding subsequent entries, thinning.
142 • Chapter 3
Kuiu Timber Sale FEIS
Timber and Vegetation
and pruning. The systems considered for the Kuiu Timber Sale are
even-aged, two-aged, and uneven-aged systems, and are described
below.
3.8.4.1 Even-aged Systems
All merchantable trees would be harvested. The objectives of this
system are to create a fast-growing stand of trees to maximize wood
fiber production, favorable timber sale harvest economics and logging
feasibility. These stands would develop into a predominately single-
aged stand. Where this treatment is recommended the created openings
would not exceed 100 acres. The regeneration system chosen to
achieve this treatment is clearcutting (the cutting of all the trees in one
harvest entry, producing a fully exposed microsite for the development
of a new age class).
The desired future condition is an even-aged stand of the same species
composition as the original stand that mimics the results of a large
naturally-occurring wind event. Except for reserve trees, all trees
greater than nine inches diameter-at-breast-height (DBH) would be
harvested in the cable and shovel units. Natural regeneration is
expected to be abundant.
3.8.4.2 Two-aged System - Clearcut with Reserves
This system is designed to maintain and develop a stand with two age
classes. Objectives of this prescription are to: (1) retain trees for scenic
values, (2) retain wildlife habitat, and (3) retain structural diversity and
a biological legacy.
The desired future condition is a two-aged stand of the same species
composition as the original stand. Natural regeneration is expected to
be abundant. These stands would not be reentered until the next
rotation in approximately 100 years.
Stands proposed for this system would retain a minimum of 50 percent
of the pre-treatment basal area. Merchantable trees (trees greater than
9 inches in diameter) would be harvested in patches or as individual
trees. Reserves or clumps would be distributed somewhat evenly
across the harvest unit or stand.
3.8.4.3 Uneven-aged System - Group Selection
This system develops and maintains a stand with trees of three or more
distinct age (size) classes, either intimately mixed or in small groups.
Objectives of this prescription are to: (1) retain trees for scenic values,
(2) retain wildlife habitat, and (3) retain structural diversity and a
biological legacy.
The desired future condition is a stand with three or more distinct size
classes resulting in an uneven-aged stand. Natural regeneration is
expected to be abundant.
Kuiu Timber Sale FEIS
Chapter 3 • 143
3 Environment and Effects
Stands proposed for this system would retain a minimum of 50 percent
of the pre-treatment basal area. Merchantable trees (trees greater than
9 inches in diameter) would be harvested in small groups to form a
mosaic of irregularly shaped openings within the stand. Smaller trees
may be left in this area if the larger trees can be safely removed. Each
group harvested would consist of a mixture of tree sizes. Each
harvested opening would regenerate, creating a group of trees with a
uniform age and height. These openings may be thinned. This would
create a stand of three or more distinct size classes in small groups,
resulting in an uneven-aged stand.
The next entry into these stands would be in approximately 75 years
when 25 percent of the stands’ basal area would be removed in groups
or as single trees.
3.S.4.4 Uneven-aged System - Single Tree Selection
Stands proposed for this system would retain a minimum of 50 percent
of the pre-treatment basal area. Objectives of this prescription are to:
(1) retain structural diversity and a biological legacy, and (2) retain
scenic values.
The desired future condition is a stand with three or more distinct size
classes. Natural regeneration is expected to be abundant.
Stands that receive this treatment would develop and maintain a multi-
aged structure through the removal of some trees in various size
classes distributed across the stand. Trees to be harvested would be
selected using criterion such as species, diameter limits or spacing. A
range of diameters, or everything above or below a certain diameter
limit, may define the trees selected for harvest. Different diameters
may be used for different species. The resulting stand may have small
openings plus individual trees harvested throughout the stand. This
would maintain or create a stand of three or more distinct size classes
distributed throughout the stand, resulting in an uneven-aged stand.
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. Damage to the residual trees and lower commercial
stand productivity is an acceptable resource tradeoff to achieve these
goals. The next entry into these stands would be in approximately 75
years when 25 percent of the stands’ basal area would be removed in
patches or as single trees.
Silvicultural prescriptions for the Kuiu Timber Sale were developed by
a silviculturist to meet the objectives identified by the interdisciplinary
planning team. The objectives for the proposed timber harvest units
include: (1) timber sale economics, (2) future timber production, (3)
3.8.5
Silvicultural
Prescriptions
144 • Chapter 3
Kuiu Timber Sale FEIS
Timber and Vegetation
wildlife habitat, (4) soil stability, (5) scenic viewshed, (6) watershed
stream channel stability, and (7) minimizing logging system damage to
residual trees.
Prescriptions for the even-aged and two-aged management systems
cover the entire rotation to provide guidance for intermediate
treatments that may follow the harvests, including thinning and
pruning. Prescriptions for the uneven-aged management system
include the next entry into the stand in approximately 75 years (see the
discussion in the previous section). However, the prescriptions are
subject to change if the management direction changes, such as
through Forest Plan amendments or a new Forest Plan. Table 3-55
displays the silvicultural prescriptions and yarding systems proposed
for the Kuiu Timber Sale Area alternatives. Additional infonnation on
these project-specific prescriptions may be found in the introduction to
the unit cards in Appendix B.
a
Table 3-55. Acres of silvicultural prescriptions by alternative
Silvicultural
System
Yarding
System
Alt 2
Alt 3
Alt 4
Alt 5
Even-aged Management
Clearcut
Shovel
10
12
119
149
Cable
187
397
906
1059
Total acres even-aged management
197
409
1,025
1,208
Uneven-aged Management
Single Tree
Selection, 50%
BA retention
Helicopter
0
0
148
0
Cable
87
72
45
0
Group Selection,
50% BA retention
Cable
19
19
41
0
Total acres uneven-aged
management
106
91
234
0
Two-aged Management
Clearcut with
reserves 50% BA
retention
Cable
102
263
100
0
Shovel
73
23
28
0
Total acres two-aged management
175
286
128
0
a
Acres are gross acres and include the entire unit size and not actual acres harvested within the units.
Kuiu Timber Sale FEIS
Chapter 3 • 145
3 Environment and Effects
3.8.6
Forest Health
and Natural
Disturbance
3.8.7
Direct and
Indirect
Effects
3. 8.6.1 Wind Disturbance
Wind is the major disturbing influence within the Project Area. Most
of the south-aspect stands have evidence of periodic windthrow events
where openings were created in which successive generations of trees,
shrubs, and forbs were established. The most noticeable windthrow
that has occun-ed in the Project Area to date is around the edges of old
southeast facing clearcut units along road 64 1 3.
Regarding windthrow in riparian buffers, the 2005 Tongass
Monitoring and Evaluation Report states that buffers on south facing
slopes were more prone to increased windthrow. Windthrow in
riparian buffers on slopes other than those oriented to the south,
however, was negligible.
3.8. 6.2 Yellow-cedar Decline
The Project Area has a low incidence of cedar decline in the proposed
timber harvest units. Yellow-cedar may be salvaged from the stands.
3.8. 6.3 Dwarf Mistletoe
Dwarf mistletoe reduces the vigor and growth rate of hemlock and
often produces a low quality of timber (Ruth and Harris 1979).
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.
The occurrence of dwarf mistletoe is relatively light within the Project
Area.
3. 8. 6.4 Decay Fungi
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 fimgi throughout the Project Area.
Approximately one third of the old-growth timber volume is defective
in Southeast Alaska old-growth stands (USDA Forest Service 2003a).
Although decay develops slowly, the longevity of individual trees
allows ample time for significant amounts of decay to develop.
The structure of the forest would be affected by timber harvest. The
effects would vary by the silvicultural prescription and the number of
acres harvested. Partial harvest would maintain old-growth forest, but
with fewer trees. The distribution of the trees would vary depending on
the prescription. Removal of trees in patches would result in small
openings that would develop into second-growth forest. Removal of
trees dispersed throughout the stand would result in old trees
146 • Chapter 3
Kuiu Timber Sale FEIS
Timber and Vegetation
interspersed with regeneration of young 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.
Clearcut harvest would result in the creation of primarily second-
growth stands with or without older residual trees.
None of the proposed alternatives are expected to have an adverse
effect on the quantity or composition of cedar, or any other tree
species, in the future. If regeneration surveys indicate that natural
cedar regeneration is inadequate, cedar would be planted to ensure
adequate stocking is maintained as described in the silvicultural
prescription. Since both western redcedar and Alaska yellow-cedar are
shade intolerant, overstory removal of hemlock could release cedar if
advanced regeneration is present. Thinning of second-growth stands
typically benefits cedar.
The proposed closure of NFS roads after the proposed harvest has the
potential to increase the cost of future entries in the stands managed
under uneven-aged silvicultural systems and could increase the cost or
preclude intermediate treatments.
3.8. 7.1 Alternative 1
Vegetation and forest health would not be affected by management
activities. Tree growth and mortality would continue to progress
naturally.
These stands would not contribute volume to the forest-wide sustained
yield at this time as specified in the desired condition but may be
available at a later date. Other forest lands with land use designations
that allow timber harvest would need to meet the objective of
providing timber for public consumption to meet market demand.
Stand growth and productivity would not be improved as
recommended in the objectives for the LUD.
3.8.7.2 Alternative 2
In this alternative 197 acres would be converted to even-aged
management. Forest health and commercial productivity would be
improved by removing dwarf mistletoe infected trees and trees
infected by disease, and by creating younger, faster-growing forests.
Approximately 106 acres would be managed in an uneven-aged
system by removing a maximum of 50 percent of the basal area in
groups 1/4-acre to one acre in size on 1 9 acres and by removing a
maximum of 50 percent of the basal area in individual trees dispersed
throughout the stands on 87 aeres. These stands would be harvested a
second time in approximately 75 years. This second harvest would
remove approximately 25 percent of the basal area. These stands
would retain some of the old-growth characteristics of the forest (older
Kuiu Timber Sale FEIS
Chapter 3 • 147
3 Environment and Effects
trees, wider variation in tree sizes and spacing, decadent trees, multiple
canopy layers), but would also result in a forest with a lower net
commercial volume.
An additional 174 acres would be harvested in a two-aged
management system by harvesting a maximum of 50 percent of the
basal area in patches and individual trees. These stands would not be
re-entered for harvest until the end of the rotation (approximately 100
years). These stands would retain the structural diversity and
biological legacy of the forest (older trees, wider variation in tree sizes
and spacing, decadent trees, multiple canopy layers), but the resulting
forest would have a lower net commercial volume.
Of the action alternatives, this alternative would impact the fewest
acres and harvest the least volume.
3.8. 7.3 Alternative 3
In this alternative, 409 acres would be converted to even-aged
management. Forest health and commercial productivity would be
improved by creating younger, faster-growing forests.
Approximately 91 acres would be managed in an uneven-aged system
by removing a maximum of 50 percent of the basal area in groups % to
1 acre in size on 19 acres, and by removing a maximum of 50 percent
of the basal area in individual trees dispersed throughout the stand on
72 acres. These stands would receive a second harvest in
approximately 75 years, which would remove approximately 25
percent of the basal area. These stands would retain some of the old-
growth characteristics of the forests (older trees, wider variation in tree
sizes and spacing, decadent trees, multiple canopy layers), but would
result in a forest with a lower net commercial volume.
An additional 286 acres would be harvested in a two-aged
management system by harvesting a maximum of 50 percent of the
basal area in patches and individual trees. These stands would not be
entered for harvest again until the end of the rotation (approximately
100 years). These stands would retain structural diversity and
biological legacy (older trees, wider variation in tree sizes and spacing,
decadent trees, multiple canopy layers), but the resulting forest would
have a lower net commercial volume.
This alternative would impact the second lowest number of acres
among the action alternatives and would harvest the second lowest
volume of the proposed action alternatives.
3. 8. 7.4 Alternative 4
In this alternative, 1,025 acres would be converted to even-aged
management. Forest health and commercial productivity would be
148 • Chapter 3
Kuiu Timber Sale FEIS
3.8.8
Cumulative
Effects
Timber and Vegetation
improved by removing dwarf mistletoe infected trees and trees
infected by disease, thereby creating younger, faster-growing forests.
Approximately 234 acres would be managed in an uneven-aged
system by removing a maximum of 50 percent of the basal area in
groups ‘A-acre to one acre in size on 4 1 acres and by removing a
maximum of 50 percent of the basal area in individual trees dispersed
throughout the stand on 193 acres. These stands would receive a
second harvest in approximately 75 years. This second harvest would
remove approximately 25 percent of the basal area. These stands
would retain some of the old-growth characteristics of the forest (older
trees, wider variation in tree sizes and spacing, decadent trees, multiple
canopy layers) but would result in a forest with a lower next
commercial value.
An additional 128 acres would be harvested in a two-aged
management system by harvesting a maximum of 50 percent of the
basal area in patches and individual trees. These stands would not be
re-entered for harvest for the rotation of the stand (approximately 100
years). These stands would retain structural diversity and biological
legacy (older trees, wider variation in tree sizes and spacing, decadent
trees, multiple canopy layers), but the resulting forest would have a
lower net commercial volume.
This alternative would provide the greatest volume and impact the
greatest number of acres of the action alternatives.
3.8.7. 5 Alternative 5
In this alternative 1,208 acres would be converted to an even-aged
forest. Forest health and productivity would be improved by removing
dwarf mistletoe infected trees and trees infected by disease, and by
creating younger, faster-growing forests.
All the stands proposed for harvest in this alternative would mimic the
results of a large, naturally-occurring wind event with the stands
converted to even-aged stands. No structural diversity, biological
legacy, or old-growth characteristics would remain in the stand other
than the reserve trees retained to meet site-specific resource objectives.
Natural regeneration is expected to contribute to the stand being fully
stocked with seedlings within three years of the regeneration harvest.
This alternative would impact the second largest number of acres
among the action alternatives proposed in the Project Area and is the
most economical. It is the only alternative that proposes even-aged
management by clearcutting for all proposed harvest units.
In addition to the Kuiu Timber Sale EIS there is 482 acres of potential
timber harvest available in the Project Area analyzed in the Crane and
Rowan Mountain Timber Sales EIS.
Kuiu Timber Sale FEIS
Chapter 3 • 149
3 Environment and Effects
Within the Kuiu Timber Sale Area, the catalog of past events
documents that past harvesting has resulted in the conversion of
10,393 acres of old-growth forest to second-growth forest.
Approximately 8,654 acres of these lands are on forested land within
the suitable timber base (Table 3-56). The remaining 1,739 acres were
harvested before Forest Plan land use designations were assigned and
generally fall within what are now recognized as riparian reserves and
beach fringe areas and are now designated by the Forest Plan as
unsuitable for timber harvest. Thinning of second-growth or
conversion to uneven-aged management may occur. All of the
proposed harvest units with an uneven-aged management prescription
have subsequent entries planned.
Table 3-56. Cumulative acres of timber harvest by alternative
29,362 acres of suitable forest
land
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Acres of harvest units
proposed for this project
0
478
786
1,387
1,208
% of suitable forest acres
proposed for this project
0
2
3
5
4
Acres of previous harvest on
suitable forest
8,654 acres
Acres of reasonably
foreseeable future harvest in
the Project Area
482 acres
% Cumulative harvest of
suitable forest
31
33
34
36
35
150 • Chapter 3
Kuiu Timber Sale FEIS
3.9 Fisheries
3.9.1
Introduction
Spawning requires the availability of clean gravels of appropriate size
with intragravel flows sufficient to deliver dissolved oxygen to buried
eggs (Sullivan et al. 1987). Management activities, such as removal of
vegetation, management-caused landslides, or poorly designed or
maintained roads, may affect salmon spawning success if an excess of
fine sediments is introduced.
The suitability of salmon spawning habitat is related to the capacity of
stream flows to mobilize and scour bed substrates. Bed load movement
can bury eggs to great depths, prohibiting fry emergence, or,
alternatively, scour can remove or rework redds and crush incubating
eggs or fry (Sullivan et al. 1987).
The Project Area includes approximately 33.7 miles of shoreline
which contains diverse estuarine and tidal ecosystems that is habitat
for shrimp, flatfish, marine worms, starfish, sponges, anemones, sea
cucumbers, urchins, shellfish, plankton, marine algae, and other
organisms. The shallow marine waters are vital habitat for some
commercially important species, such as Dungeness crab and juvenile
salmon.
3.9. 1.1 Stream Value Classes
Stream value classes are mapping units that indicate levels of habitat
use by fish populations. Boundaries were delineated according to the
following criteria, described in the Aquatic Habitat Management
Handbook (FSH 2090.21).
Class I - Streams and lakes with anadromous or adfiuvial fish or fish
habitat, or high quality resident fish waters, or habitat above fish
migration barriers known to be reasonable enhancement opportunities
for anadromous fish.
Class II - Streams and lakes with resident fish or fish habitat and
generally steep (6-25 percent or higher) gradient (can also include
Anadromous fish, such as salmon, spend part of their life in fresh
water and part of their life in saltwater and use a variety of different
stream habitats throughout their life (Sullivan et al. 1987). Limitations
in habitat availability at any stage of development within a species’
life cycle can potentially limit overall production. Forest harvest
activities can potentially affect fish habitat by altering the amount and
timing of runoff and altering sediment transport and deposition
regimes (Sullivan et al. 1987), and by altering stream temperature
(Beschta et al. 1987).
Kuiu Timber Sale FEIS
Chapter 3 • 151
3 Environment and Effects
3.9.2
Resource
Inventory
3.9.3
Area of
Analysis
streams with a 0-6 percent gradient) where no anadromous fish occur,
and otherwise do not meet Class I criteria.
Class HI - Streams which are both perennial and intemiittent 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. For streams less than 30 percent
gradient, special care is needed to determine if resident fish are
present.
Class IV - Other intermittent, ephemeral, and small perennial channels
with insufficient flow or sediment transport capabilities to have
immediate influence on downstream water quality or fish habitat
capability. Class IV streams do not have the characteristics of Class I,
II, or III streams, and have a bankfull width of at least 0.3 meters (one
foot).
The Class IV designation was created under the 1997 Forest Plan and
was identified and mapped for each unit, and when possible, outside
the units.
Non-streams - Rills and other watercourses, generally intermittent and
less than one-foot in bankfull width, little or no incision into the
surrounding hillslope, and with little or no evidence of scour.
During the summer of 2003 and 2004, field surveys were conducted to
verify fish presence or absence, fish species, channel type, and stream
value class. This information was incorporated into a CIS based
inventory (see the Kuiu Fisheries Resource Report available in the
Kuiu Timber Sale planning record).
The analysis area for direct and indirect effects to fisheries includes
the following watersheds; Dean Creek (#109-50-10070), Saginaw
Creek (#109-44-10390), Rowan Creek (#109-52-10060), Kadake
Creek (#109-42-10300), Security Creek (#109-45-10100), and two
unnamed watersheds (#109-44-10370 and #109-45-10090). In addition
to these watersheds, there are several other watersheds and portions of
watersheds within the Project Area. These watersheds are not analyzed
because this project does not propose any harvest. However, one
unnamed unnumbered watershed in the northern portion of the Project
Area will be discussed in the fisheries cumulative effects section.
Each watershed is a topographically delineated catchment in which all
surface water drains to a single stream. The downstream boundary for
the watersheds is sea level. The watershed boundaries are large enough
to allow a comprehensive accounting of all activities that may affect
them. At the same time, the watershed boundaries are small enough to
allow the analysis to be sensitive to the potential effects of the
proposed activities.
152 • Chapter 3
Kuiu Timber Sale FEIS
Fisheries
3.9.3. 1 Watersheds
The north and east sides of Kuiu Island have had the most harvest. The
Project Area is in northern Kuiu and encompasses seven watersheds.
Table 3-28 in the Cumulative Effects of Logging and Road
Construction on Watersheds section shows the acres harvested within
each of these watersheds. The watersheds contain important fish
habitat and is discussed in the following paragraphs. More detailed
discussions on watersheds can be found in Section 3.5 this chapter.
Kadake Creek Watershed
Kadake Creek watershed (ADF&G # 109-42-10300) is the largest
producer of steelhead and salmon on Kuiu Island and is used by sport
fishermen more than any other stream on Kuiu Island. It has
approximately 71 miles of Class I and 18 miles of Class II stream. The
lower portion of the stream is a Recreational River LUD due to its
high fish values for steelhead, coho salmon, and cutthroat trout. Few
other streams receive much angling pressure. Kadake Creek also has
high wildlife, historic, scenic, and recreation values and extends
beyond the project boundary.
The number of steelhead redds and adults has been counted in Kadake
Creek for 10 of the last 12 years (1993-2004). Statistical analysis is
incomplete and no obvious trends are evident.
Dean Creek Watershed
The Dean Creek watershed (ADF&G # 109-50-10070) contains two
small lakes with a total of 6.6 acres and approximately 10 miles of
Class I and four miles of Class II stream habitat.
The Dean Creek fish pass was built in 1984 to provide coho salmon
passage over a 13-foot waterfall. Coho fry were transplanted from
three adjacent drainages (Rowan Creek, Security Creek, and Saginaw
Creek) over a seven year period (1983-1989). The fish pass was
modified in 1994 for pink salmon. In addition to coho and pink
salmon. Dean Creek also has chum salmon, steelhead, and Dolly
Varden (Johnson et al. 2004).
Security Creek Watershed
The Security Creek watershed (ADF&G # 109-45-10100) does not
contain any lakes. There are approximately ten miles of Class I and
five miles of Class II stream habitat. Security Creek has populations of
coho, pink, chum, and Dolly Varden (Johnson et al. 2004).
Kuiu Timber Sale FEIS
Chapter 3 • 153
3 Environment and Effects
Saginaw Creek Watershed
The Saginaw Creek watershed (ADF&G # 109-44-10390) eontains
one small lake and approximately 14 miles of Class 1 and six miles of
Class II stream habitat. Saginaw has coho, chum, pink, steelhead,
Dolly Varden, and cutthroat trout (Johnson et al. 2004).
Rowan Creek Watershed
The Rowan Creek watershed (ADF&G # 109-52-10060) has one large
1 9-acre lake and four smaller lakes which total one acre. There are 22
miles of Class I and 15 miles of Class II stream habitat. Rowan Creek
has populations of coho, pink, sockeye, Dolly Varden, and cutthroat
trout (Johnson et al. 2004).
Watershed #109-44-10370
This unnamed stream system drains into Saginaw Bay. It does not
have any lakes but does have approximately three miles of Class I
stream and six miles of Class II stream habitat. This stream has
populations of coho, pink, and chum salmon as well as Dolly Varden,
and steelhead (Johnson et al. 2004).
Watershed #109-45-10090
This unnamed stream system drains into Security Bay. It does not
contain any lakes but it does have approximately one mile of Class I
and three miles of Class II stream habitat. The fish species present are
coho and pink salmon, and Dolly Varden (Johnson et al. 2004).
3.9. 3.2. Units of Measure
The affects of the proposed Kuiu Timber Sale activities would be
measured by the amount and duration of the fine sediment that may be
introduced to the stream by logging activities, including road
construction and reconstruction; the number of red culverts replaced;
and the effects to the marine environment from the transporting of logs
at the LTFs.
Fine Sediment
Fine sediment can enter streams from log yarding and road
construction activities; however, this effect is expected to be short-
term (48 hours after construction). Hicks et al. (1991b) found that in
some cases in Alaska, salmonid survival was apparently affected over
the short-term when timber harvest activities increased the amount of
fine sediment in spawning habitat. However, the amount of sediment
in gravels returned to pre-logging conditions within five years.
Because sedimentation may reduce oxygen levels to developing eggs
in spawning gravel and/or trap emerging fry in the gravel, construction
154 • Chapter 3
Kuiu Timber Sale FEIS
Fisheries
timing windows for stream crossings on roads proposed for
reconditioning or storage would be implemented. While individual fish
may be impacted, the population as a whole is not expected to be
affected. The placement of buffers and implementation of BMPs and
standards and guidelines would reduce the amount of fine sediment
entering the streams.
Roads and Stream Crossings
Guidelines for fish passage through culverts are specified in the
Aquatic Habitat Management Handbook (FSH 2090.21). The guiding
criteria for culvert design is to allow natural migration by adult and
juvenile fish through the culvert during flows equal to or less than the
discharge predicted to occur two days before or after the mean annual
flood levels.
The miles of proposed NFS and temporary road construction vary
between 3.3 and 10.4 miles, depending on the action alternative (see
the Transportation section this chapter). Between 3.0 and 6.8 miles of
existing NFS closed roads would be reopened (reconditioned) to
access timber, depending on the selected alternative. When these roads
were closed, the structures were removed; therefore reconditioning
would include the installation of stream crossing structures (stringer
bridges or culverts). Table 3-57 shows the existing and proposed
stream crossings needing structures by stream class and alternative for
the Kuiu Timber Sale Area.
Table 3-57. Existing and proposed stream crossings needing
structures by stream class and alternative
Stream
Class
Alt1
Alt 2
Alts
Alt 4
Alts
I
0
3
2
3
3
II
0
3
4
5
5
III
0
1
8
14
15
IV
0
5
19
19
19
Road condition surveys assess the condition of existing roads, culverts,
and drainage features. As part of this road survey, the fish crossings
were analyzed to determine if juvenile fish can pass through the
culvert at different flows. The fish crossings are categorized red, gray,
or green. A red fish crossing is one that cannot pass juvenile fish at
some or all flows, a green fish crossing is one that can pass juvenile
fish at all flows up to the Q2 2-day flow (a two day delay from the
Kuiu Timber Sale FEIS
Chapter 3 • 155
3 Environment and Effects
mean annual flood), and a gray fish crossing needs additional analysis
to determine if it is red or green. Within the Project Area, there are six
gray culverts and 44 red culverts. Of the 44 red culverts, 1 1 are on
Class I streams. One Class 1 stream and three Class II streams need
upstream habitat analysis. Those culverts that have had upstream
habitat analysis block, or partially block, approximately 2.4 miles of
Class I habitat and 5.2 miles of Class II habitat.
An interagency group is currently working on a model that would help
make management recommendations for the red culverts. 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.
There is an opportunity to remove red culverts on roads that would be
closed after timber harvest is complete. Table 3-58 shows the NFS
road, class of stream on which structures occur, and tells if the
structure currently meets fish passage standards.
Table 3-58. Proposed fish stream structure removal
Alt
Road#
Class 1 Stream
Structures
Removed
Meets Current
Fish Passage
Standards
Class II
Stream
Structures
Removed
Meets Current
Fish Passage
Standards
2
6413
1
Yes
1
No
46096
1
Yes
0
6417
3
Yes
3
1 No
3
6413
1
Yes
1
No
46096
1
Yes
0
6418
2
Yes
0
6417
3
Yes
3
1 No
4 and 5
6413
1
Yes
1
1 No
46096
1
Yes
0
6418
2
Yes
0
6417
3
Yes
3
1 No
Marine Environment
Log transfer facilities (LTFs) and log transport are the points of
concentrated activity in the marine environment. The rest of the
156 • Chapter 3
Kuiu Timber Sale FEIS
Fisheries
shoreline is protected by a 1,000-foot buffer (Forest Plan). There are
two existing LTFs in north Kuiu that could be used for the action
alternatives (see the Timber Economics and Transportation sections of
this chapter for further details). The Rowan Bay LTF and sort yard is
approximately six miles south of the Project Area, and the Saginaw
Bay LTF and sort yard is in the Project Area. The action alternatives
would most likely use the existing administrative site at Rowan Bay or
a floating camp to house the timber operators.
Rowan Bay LTF
There are six anadromous fish streams that drain into Rowan Bay.
Rowan Creek and Browns Creek are the largest producers. Rowan
Creek has populations of coho and pink salmon, sockeye, Dolly
Varden, and cutthroat. Browns Creek has populations of pink salmon,
coho salmon, cutthroat trout, steelhead, Dolly Varden, and chum
salmon. Average annual pink salmon escapement from 1993 to 2002
was 29,000. Dungeness crab is harvested from Rowan Bay and the
surrounding area.
In 1996 Rowan Bay was placed on the Section 303(d)’ list for bark
debris accumulation from the LTF. The Alaska Department of
Environmental Conservation (ADEC) database shows that a dive on
July 15, 2002 to monitor the bark deposit had an area with continuous
bark coverage of 0.81 acres which is compliant with water quality
standards, resulting in its removal from the Section 303(d) list in 2003
(Foley 2006).
Saginaw Bay LTF
This LTF would require reconstruction, but the “footprint” of the LTF
would not change. An existing storage yard located near the LTF
would be used if necessary. In addition to the storage area, a sort yard
at the end of Road 6448, approximately one mile from the LTF site, is
proposed for log sorting prior to storage at the LTF site.
There are five cataloged anadromous fish streams entering Saginaw
Bay with Saginaw Creek and Straight Creek being the largest
producers. Saginaw Creek and Straight Creek have populations of
coho salmon, pink salmon, chum salmon, steelhead, Dolly Varden, and
cutthroat trout (Johnson et al. 2004). Dungeness crab is harvested in
Saginaw Bay. The close proximity to the community of Kake makes
Saginaw Bay an important fishing area.
In 1998 Saginaw Bay was placed on the Section 303(d) list for bark
debris accumulation from the LTF. Two dives were completed in
2002. The dive on May 30, 2002 was based on previous dives’ layouts.
’ The 303(d) list identifies impaired waterbodies which require water quality
assessments to verify the extent of pollution and what controls are in place or
needed.
Kuiu Timber Sale FEIS
Chapter 3 • 157
3 Environment and Effects
The A’DEC analyzed the dive and found the continuous bark
accumulation to be 0.74 acres which is compliant with water quality
standards, resulting in its removal from the Section 303(d) list in 2003
(Foley 2006).
3. 9.4.1 Direct and Indirect Effects
Effects Common to all Action Alternatives
Harvest units are designed so that all Class I and Class II streams that
flow directly into Class I streams receive a minimum 100-foot buffer.
Many stream channel types extend this buffer beyond the 100-foot
minimum. Class III streams have no harvest buffer within the v-notch
or to the break in side slopes (see unit cards for site-specific buffers).
All NFS roads that are reopened for this timber sale would be put back
into storage after timber harvest is completed. NFS roads would be
stored using any combination of tank traps, pulling culverts on the first
part of the road, and blocking or gating the road. NFS roads in storage
are system roads and may be reopened for future use. New NFS roads
would be placed in storage after timber harvest is complete. All
temporary roads would be decommissioned.
NFS Road 6417 is currently in storage and would have to be reopened
in all action alternatives; this would require replacing the culverts on
three Class I and three Class II stream crossings. All the streams are
tributaries of Security Creek. Placement of the structures would cause
a short-term (48 hours or less) increase in sedimentation from road
construction and reconditioning. Increased sedimentation may affect
individual fish by reducing oxygen levels to developing eggs in
spawning gravel and/or trapping of emerging fry in the gravel. The
effect is expected to be short-term and the placement of timing
restrictions would minimize impacts to fish (see the Road Cards in
Appendix B). While individual fish may be impacted, the population
as a whole is not expected to be affected.
The following actions would restore approximately 636 feet of fish
habitat in all action alternatives:
• Storage of Road 64 1 3 would remove a culvert that does not meet
current fish passage standards.
• Excess fill left on site from a prior culvert removal on Road 6417
would be removed restoring fish passage.
In all action alternatives the logs would be hauled to either the Rowan
Bay or Saginaw Bay LTF where the contractor may either barge or raft
the logs for transportation to the mill. Barging the logs would not
affect marine species. If logs are rafted one potential effect of the FTF
3.9.4
Environmental
Consequences
158 • Chapter 3
Kuiu Timber Sale FEIS
3.9.5
Comparison
by Alternative
Fisheries
on marine species may be diminished habitat for managed species and
their prey due to bark accumulation. Another potential 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.
3.9. 5.1 Alternative 1 (No-Action Alternative)
In this alternative, there would be no timber harvest, no roads would
be built, and no additional roads would be put into storage. No changes
in water yield, sediment delivery to streams, or fish passage are
expected to occur except for naturally occurring events. This does not
preclude regular maintenance of roads and the removal or replacement
of culverts that do not allow fish passage.
The removal of culverts on road 64 1 3 would not occur with this
alternative and the red culvert would not be removed, restoring
juvenile fish passage. On road 6417, the road fill would be left at the
site and it would continue to cause fish passage problems.
3.9. 5.2 Alternative 2
This alternative proposes the harvest of 9.6 mmbf of timber from 478
acres. Timber harvest in this alternative would require the construction
of 1.5 miles of temporary road and 1.8 miles of new NFS road. There
are 4.5 miles of NFS roads currently in storage that would have to be
reopened, which would require replacing the culverts or bridges on
three Class I streams and three Class II streams (Table 3-57).
This alternative would close an additional 7.8miles of NFS roads after
timber harvest is complete. The harvest would occur in six watersheds:
Security Creek, Saginaw Creek, Rowan Creek, Kadake Creek,
Watershed 109-45-10090, and Watershed 109-44-10070.
Effects
Of all the action alternatives, fewer effects to fisheries are expected
from this alternative.
This alternative has the fewest new stream crossings due to road
construction, opens the second fewest miles of currently closed NFS
roads, removes the same number of red culverts as the other action
alternatives, and would transport the least volume of wood through the
LTF. Road construction, installation of culverts and bridges, and the
removal of culverts are expected to temporarily increase sediment
delivery but are not expected to degrade fish habitat. Increased
sediment 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 placement of timing restrictions would minimize impacts to
fish (see the Road Cards in Appendix B). Alaska’s Water Quality
Kuiu Timber Sale FEIS
Chapter 3 • 159
3 Environment and Effects
Standards require that waters whieh support the propagation of fish,
shellfish and wildlife, and reereation in and on the water must be
proteeted and maintained. BMP implementation will aehieve state
water quality standards.
3.9. 5.3 Alternative 3
This alternative proposes the harvest of 15.9 mmbf of timber and the
construction of 2. 1 miles of temporary road and 5.4 miles of new NFS
road. Road construction would require a log stringer bridge across a
Class II stream to access Units 402, 403, 409, and 410 (Table 3-57).
There are 3.2 miles of NFS roads that are currently in storage that
would be reopened. Reopening NFS Road 6417 would require
replacing two Class I and three Class II culverts or bridge crossings
(Table 3-57).
With this alternative, an additional 8.0 miles of currently open road
would be put into storage at the end of this project. The harvest would
occur in five watersheds: Security Creek, Saginaw Creek, Rowan
Creek, Kadake Creek, and Watershed 109-44-10370.
Effects
This alternative has the second lowest total number of new stream
crossings due to road construction. Because this is the only action
alternative which does not harvest Units 111 or 40 1 , it would have the
fewest Class I stream crossings replaced. This alternative also opens
the fewest miles of currently closed NFS roads, and has the second
lowest volume of timber to be transported through the LTFs.
Road construction, installation of culverts and bridges, and the
removal of culverts are expected to temporarily increase sediment
delivery but are not expected to degrade fish habitat. Increased
sediment may affect individual fish by reducing oxygen levels to
developing eggs in the spawning gravels and/or trapping emerging fry
in the gravel, but the effect is expect to be short-term (48 hours or less)
and the placement of timing restrictions would minimize impacts to
fish (see the Road Cards in Appendix B). Alaska’s Water Quality
Standards require that waters which support the propagation of fish,
shellfish and wildlife, and recreation in and on the water must be
protected and maintained. BMP implementation will achieve state
water quality standards.
3. 9. 5.4 Alternative 4
This alternative proposes the harvest of 33.3 mmbf of timber and
construction of 3.9 miles of temporary road and 6.5 miles of new NFS
road. There are 6.1 miles of NFS road that are currently in storage that
would be reopened. Road construction would require two new Class II
stream crossings, and road reconditioning would require replacing
160 • Chapter 3
Kuiu Timber Sale FEIS
Fisheries
three Class I and three Class II stream crossings on Road 6417 (Table
3-57). After timber harvest is completed, an additional 10.5 miles of
currently open road would be put into storage with all structures
pulled. The harvest would occur in six watersheds: Security Creek,
Saginaw Creek, Rowan Creek, Kadake Creek, Watershed 109-44-
10370, and Watershed 109-45-10090.
Effects
This alternative, along with Alternative 5, would have the greatest
potential for increased sedimentation into streams. These alternatives
are the only ones that would construct a road to Unit 412, which would
cross a Class I stream and a road to Units 402, 403, 409, and 410,
which would cross a Class II stream. These alternatives would
construct the most miles of road for the most total stream crossings
(Table 3-57).
Although these alternatives would have the greatest potential for
increased sediment delivery into the streams due to road construction,
culvert and bridge installation, and culvert removal, the increased
sediment delivery is expected to be temporary and is not expected to
degrade fish habitat. Increased sediment 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). In addition, the placement of timing
restrictions would minimize impacts to fish (see the Road Cards in
Appendix B). Alaska’s Water Quality Standards require that waters
which support the propagation of fish, shellfish and wildlife, and
recreation in and on the water must be protected and maintained. BMP
implementation will achieve state water quality standards.
3.9. 5.5 Alternative 5
This alternative proposes the harvest of 3 1 .4 mmbf of timber and the
construction of 3.5 miles of temporary road and 6.5 miles of new NFS
road. There are 6.9 miles of road that are currently in storage that
would have to be reopened. Road construction would require two new
Class II stream crossings, and road reconditioning would require
replacing three Class I and three Class II stream crossings on Road
6417 (Table 3-57). After timber harvest is completed, an additional
10.5 miles of currently open road would be put into storage with all
structures pulled. The harvest would occur in six watersheds; Security
Creek, Saginaw Creek, Rowan Creek, Kadake Creek, Watershed 109-
44-10370, and Watershed 109-45-10090.
Effects
As discussed in Alternative 4, Alternatives 4 and 5 have the greatest
potential for increased sedimentation into streams.
Kuiu Timber Sale FEIS
Chapter 3 • 161
3 Environment and Effects
Although these alternatives would have the greatest potential for
increased sediment delivery into the streams due to road construction,
culvert and bridge installation, and culvert removal, the increased
sediment delivery is expected to be temporary and is not expected to
degrade fish habitat. Increased sediment 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-tenn (48 hours or less). In addition, the placement of timing
restrictions would minimize impacts to fish (see the Road Cards in
Appendix B). Alaska’s Water Quality Standards require that waters
which support the propagation of fish, shellfish and wildlife, and
recreation in and on the water must be protected and maintained. BMP
implementation will achieve state water quality standards.
Cumulative effects are analyzed on a watershed basis and include all
watersheds contained or partially contained within the Project Area.
The Catalog of Events for Kuiu Island was referenced in determining
cumulative effects to fish and all past, present, and reasonably
foreseeable future management activities.
Past activities considered include the Dean Creek fish pass, which
opened approximately 6.5 miles of stream for coho, pink, and chum
salmon, steelhead and Dolly Varden. The Dean Creek fish pass
increased fish populations within the Project Area. Past activities
considered also include road construction and timber harvest (see the
Catalog of Events for a complete list).
Cumulative effects for this project include the possible harvest of the
remaining units from the Crane and Rowan Mountain Timber Sales
EIS and road maintenance. Within the Project Area, the harvest units
from the Crane and Rowan Mountain Timber Sales EIS are located in
the Security Creek and Dean Creek watersheds, and an unnamed
unnumbered watershed in the north portion of the Project Area. All but
one of the units are helicopter units. Approximately 0.5 miles of new
NFS road and 0.45 miles of road would be reconditioned to access
Crane and Rowan Mountain Timber Sales Unit 399-13 which would
require three Class III crossings.
The Crane and Rowan Mountain Timber Sales EIS states that the
existing Rowan Bay LTF would be used to transport logs by barge.
With this project either the Rowan Bay or Saginaw Bay LTF could be
used. Logs could be barged or logs would be placed into the water and
rafted for towing from the bays. Barging logs would not increase bark
accumulation at either site. Log rafting would cause newly dislodged
bark to accumulate at the sites. Annual monitoring would determine
the amount of accumulation. If accumulation exceeds Environmental
Protection Agency’s National Pollutant Discharge Elimination System
3.9.6
Cumulative
Effects
162 • Chapter 3
Kuiu Timber Sale FEIS
3.9.7
Essential Fish
Habitat
Assessment
Fisheries
(NPDES) permit standards, logs will no longer be placed in the water
until monitoring determines that bark is no longer an issue.
According to the five-year timber sale schedule, there is no additional
harvest scheduled in the Project Area.
The input of sediment to streams from the above-described activities
would not be expected to effect fish populations or habitat. While there
may be incidental death of fish due to this project, cumulatively
considering all the timber and non-timber projects, the fish populations
in the Project Area are well above naturally occurring levels.
Section 305(b)(2) of the Magnuson-Stevens Fishery Conservation and
Management Act (the Act) states that all federal agencies must consult
the National Marine Fisheries Service (NMFS) for actions or proposed
actions that may adversely affect Essential Fish Habitat (EFH). In
accordance with the August 25, 2000 agreement between the Forest
Service, Alaska Region and the NMFS, consultation started when
NMFS received a copy of the draft environmental impact statement
(DEIS) which contained the EFH Assessment.
In the EFH assessment, the Forest Service determined that the Kuiu
Timber sale may adversely affect EFH; however, this risk would be
minimized or avoided through implementation of the Forest Plan
standards and guidelines and best management practices (BMPs). The
complete EFH can be found in the Fisheries Resource Report in the
Kuiu Timber Sale planning record. NMFS concurred with our findings
and made conservation recommendations. The Forest Service
responded to their comments and consultation was completed. See
Appendix C for the letter from the NMFS and the Forest Service’s
response.
Kuiu Timber Sale FEIS
Chapter 3 • 163
3.10.1
Karst
3.10.2
Soils
Soils and Geology
3.10 Soils and Geology
The following discussions are based on pre-existing data combined
with additional data collected in the field for the Kuiu Timber Sale
project, and is confined to the Project Area and proposed units.
Applicable soils direction is included in the Forest Plan, Chapter 4 and
Appendix C. General and site-specific mitigation measures are listed
in the road and unit cards.
Within the Project Area 6,624 acres of carbonate bedrock have been
identified along the northeastern boundary. Karst develops where
carbonates exist due to the action of water on soluble rock. The
dissolution of the rock results in the development of internal drainage
that can produce sinking streams, closed depressions, and other
solution landfonns such as sinkholes, collapsed channels, and caves.
The Tongass National Forest has developed management guidelines
which strive to protect and maintain the function and biological
significance of karst landscapes and caves found, per the requirements
of the Federal Cave Resources Protection Act of 1988. All proposed
alternatives have been modified so that no timber harvest, road
construction, or quarry development would occur in these areas or
along the drainages which flow to them.
Scoping comments for the Project Area did not identify any specific
soil related issues. The Forest Plan, however, has identified two
concerns pertinent to proposed timber harvests that are applicable. The
concerns are: 1) soil productivity loss due to roads, rock pits, and
detrimental soil conditions created as a result of timber harvests, and
2) erosion due to management-induced mass wasting (i.e. various
types of landslides: avalanches, debris and earth flows, soil creep,
slumps, etc.).
Soil Quality Standards have been established to ensure that managed
activities do not create significant impairment to the productivity of
the land and directs that no more than 1 5 percent of an activity area be
detrimentally disturbed through management practices (FSM 2554.03-
10). National Forest System (NFS) roads are considered a dedicated
use of the soil resource and are not included when calculating
detrimental soil conditions, whereas temporary roads are included.
Design criteria for new NFS road and the BMPs are included in
Appendix B and respond to any soils concerns.
3.10.2.1 Soil Productivity
Deep well-drained soils are the most productive for tree growth.
Maintaining soil drainage while minimizing soil erosion are both key
to soil productivity in the Project Area due to high annual precipitation
164 • Chapter 3
Kuiu Timber Sale FEIS
3.10.3
Mass
Movement
Soils and Geology
and the overall topography of the area. Tree rooting in the area is
generally shallow and soils are covered by thick matting created from
accumulating and decaying organic matter.
3.10.2.2 Soil Disturbance and Erosion
Soil disturbance is part of a natural and ongoing process within a forest
ecosystem. Erosion is considered one phase of soil disturbance,
initiated by natural processes such as heavy or consistent precipitation,
landslides, and windthrow. Soil disturbance can also be initiated by
land management activities (e.g. road construction, timber harvest, and
rock pit development (Swanston 1995). The level of disturbance varies
with management practices and site characteristics.
Mass movement ratings have been developed to assist management at
the planning level for analyzing landslide potential. The value used to
classify a rating or mass movement index (MMI) is explained in the
Soils Specialist report available in the Kuiu Timber Sale planning
record. The MMI ratings used, identified by Swanston (1995), are
generally associated with the following slope gradients:
• MMI - 1 (low): 5 to 35 percent
• MMI - 2 (moderate): 36 to 5 1 percent
• MMI - 3 (high): 52 to 72 percent
• MMI - 4 (extreme): over 72 percent
Two landslide inventories within Southeast Alaska, based on different
scales, provide a relative understanding of the relationship between
timber harvests and landslides. The first inventory, conducted by
Swanston and Marion (1991) was based on landslides over 100 cubic
yards in size that occurred between 1963 and 1983 in Southeast
Alaska. They found that landslides were 3.4 times more likely to occur
in harvested areas than in unharvested areas. Swanston (1991) noted,
“as a general rule, landslides in harvested areas are significantly
smaller, occur at lower elevations, develop on gentler gradients, and
tend to travel shorter distances [than naturally induced landslides]”.
The areas considered hazardous or most prone to landslides are those
with steep slopes or areas with distinct slip-planes. During heavy
rainfall or snowfall events these areas have a higher likelihood of
failing, especially if previously disturbed by blasting for rock pits, road
pioneering, side casting of excavated material, or ground-based
logging (Swanston and Marion 1991).
In the other landslide analysis, slides that occurred in Southeast Alaska
between 1971 and 1991 were reviewed and noted by Landwehr (1998,
unpub.) from aerial photos, regardless of their size. Landwehr’ s study
Kuiu Timber Sale FEIS
Chapter 3 • 165
3 Environment and Effects
also concluded that landslides are more likely to oceur on harvested
areas than what would oeeur naturally (Table 3-59).
Table 3-59 Landslide studies by Swanston and Marion (1991) and
Landwehr (1998 unpub.)
20-Year
Analysis
Landslides
Slides /
unharvested
acres
Slides /
unharvested
acres
Ratio between
harvested and
unharvested
Slides / mile
of road
construction
Swanston
and Marion
(1991)
1963-1983
1 slide/8,021
acres
1 slide/2,348
acres
3.42 higher in
harvested
N/A
Landwehr
(1998,
unpub.)
1971-1991
1 slide/6,239
acres
1 slide/622
acres
10.03 higher in
harvested
1 slide/19 mile
One factor associated with ground-based logging praetiees and
subsequent landslides ineludes root deterioration following a harvest.
Where steep slopes exist, slope sheer strength is provided by the
binding action of the roots in the soil. Following harvest, root systems
begin to deeay and the soil-root fabric begins to weaken. The
weakened soil-root fabrie can further reduee the slope safety faetor
when a moderate storm or an inerease in water pressure is realized
from frequent preeipitation or snow melt and may result in a landslide
(Ziemer 1981). In the ease of a elearcut harvest, root reinforeement is
delayed for ten to fifteen years until new growth (partieularly root
density or weight) restores slope sheer strength and the binding aetion
of the soil-root fabric.
At the Forest Planning level, areas with slope gradients of 72 percent
or more are initially removed from the tentatively suitable timber base
due to a higher risk of landslides; however, the Forest Supervisor or
District Ranger at the projeet level may approve timber harvest on
these slopes on a ease-by-case basis. Their decision includes the
consideration of an on-site analysis of slope stability (documented on a
Soil Stability Investigation Report), an assessment of impaets of
potentially aeeelerated erosion on downslope areas and downstream
fish habitats, as well as other affected resources and eeonomic factors.
3.10.4 3.10.4.1 Past Actions
Existing Approximately 22 pereent of the Projeet Area has been harvested in
Condition years, mostly from valley bottoms and gentle slopes (Table
166 • Chapter 3
Kuiu Timber Sale FEIS
Soils and Geology
3-60). Of the 10,393 acres already harvested, 6,91 1 were harvested
prior to 1980 and have had more than 25 years for root net
reinforcement and vegetative regrowth.
Table 3-60. Acres previously harvested in the Kuiu Timber
Sale Area by MMI Class
MMI Class
Project Area
Acres
Acres
Harvested
% Hazard Class
Harvested
1 - Low
19,284
5,273
27%
2 - Moderate
20,862
4,668
22%
3 -High
2,595
190
7%
4 - Extreme
3,361
262
8%
Totals
46,102
10,393
22%
3.10.4.2 Mass Movement
A landslide inventory specific to the Project Area was completed in
December 2003 using aerial photos taken in 1998, and Forest Service
land surveys completed in the 1960s and 1980s. Through the
inventory, 57 known landslides were identified within the Project Area
varying in size from 0.5 to 88 acres in both managed and natural non-
managed areas. The 88-acre slide was a large rotational failure that
occurred after a rain-on-snow event in December 1988. This slide
today is partially revegetated and recovering. No units are proposed on
or near this slide.
Predicting landslides is difficult due to the number of factors that are
involved and their interaction with one another. Frequent precipitation
and windthrow are two natural events, that, when combined with
excessive soil disturbance and root deterioration, can be catalysts for a
landslide.
The inventory of landslides in the Project Area found that per 1,000
acres, landslides for MMI-1 and MMI-2 soils were two times higher in
harvested areas than in unharvested areas (Table 3-61 and Chart 3-4).
For MMl-4 soils, there were almost three times as many landslides in
harvested areas compared to unharvested areas. This inventory
analysis supports previously referenced research which stated more
landslides occur in harvested areas (Swanston and Marion 1991,
Landwehr 1998, unpub.).
Kuiu Timber Sale FEIS
Chapter 3 • 167
Environment and Effects
Table 3-61. Inventory of landslides within the Project Area
Unharvested acres
Harvested acres
MMI Rating
Number of
Landslides
Number of
slides/1000
a
acres
Number of
Landslides
Number of
slides/1000
b
acres
1 - Low
1
0.07
1
0.19
2 - Moderate
23
1.42
14
2.99
3 -High
3
1.25
0
N/A
4 - Extreme
12
3.87
3
11.45
a
Ratio was developed from unharvested acres within the Kuiu Timber Sale Area Table 3-60.
Ratio was calculated from harvested acres within the Kuiu Timber Sale Area Table 3-60.
Chart 3-4. Kuiu Timber Sale Area landslide comparison
Kuiu Timber Sale Area Landslide Comparison
MMI Rating
0 2 4 6 8 10
Landslides Per 1,000 Acres
168 • Chapter 3
Kuiu Timber Sale FEIS
Kuiu Timber Sale
Figure 3-10
MMI-3 and MMI-4 Soils within the Kuiu
Timber Sale Area
Legend
MMI-4 Extreme ( >72% Slope Gradient)
MMI-3 High (52-71%)
Productive Old-Growth
Managed Stands
Lakes/Saltwater
Unit Pool
Non-National Forest
Project Area Boundary
Stream Value Class I & II
Existing Open Roads
500ft Contour Interval
Roads in Storage (Closed)
Decommissioned Roads
0 0.5 1
A
2
3 4
Miles
I
# .
Kuiu Timber Sale
Figure 3-10
MMI-3 and MMI-4 Soils within the Kuiu
Timber Sale Area
Legend
1 1 II I III! MMI-4 Extreme ( >72% Slope Gradient)
[==| MMI-3 High ( 52-71%)
Productive Old-Growth
Managed Stands
Lakes/Saltwater
Unit Pool
Non-National Forest
Project Area Boundary
Stream Value Class I & II
Existing Open Roads
500ft Contour Interval
Roads in Storage (Closed)
Decommissioned Roads
Soils and Geology
3.10.5
Environmental
Consequences
3.10.5.1 Methods
Data used for soil analysis comes from existing resources such as the
Soil Resource Inventory (SRI), the landslide inventory, and field data
collected through on-site surveys conducted throughout the summer of
2004. Road acres are based on an average road width of 40 feet (from
top of cutslope to toe of fillslope) or 4.85 acres per mile.
Effects are estimated based on the following measures:
• Estimated acres of detrimental soil conditions in harvest units
based on yarding method,
• Acres of timber harvest on slopes over 72 percent, acres of timber
harvest by MMI Class and estimated numbers of landslides, and
• Cumulative acres of soil removed from productivity by roads,
detrimental soil conditions within harvest units, and estimated
numbers of landslides.
3.10.5.2. Area of Analysis
The soils analysis area for the Kuiu Timber Sale is within the same
boundary as that used to describe the boundary for the overall project
(Kuiu Timber Sale Area Draft EIS, 1-10). The total area (46,102 acres)
is selected as the boundary area for the soils analysis because it is
naturally separated from surrounding areas by water along the
northeast and northwest shorelines and by the general topography
along the southeast, southwest and southern areas.
3.10.5.3 Soil Productivity
Detrimental soil conditions are often created by harvest activities such
as road building and yarding activities. Literature pertaining to actual
acres of soil impacted through detrimental disturbance is limited for
soils within Southeast Alaska; however, a survey was performed by
Landwehr and Nowacki (1999, unpub.) where detrimental soil
conditions were monitored as a result of a clearcut timber harvest on
northern Prince of Wales Island. They found that partial suspension
and shovel yarding within the clearcut harvest areas resulted in five
percent disturbance of the acres harvested, and helicopter yarding
resulted in three percent disturbance.
Table 3-62 shows an estimate of detrimental soil disturbance by
alternative associated with harvest. Note the estimates given in Table
3-62 are based on clearcut harvest. The partial harvest prescriptions
would likely result in less soil displacement, therefore the numbers
presented are considered to be conservative.
171 • Chapter 3
Kuiu Timber Sale FEIS
3 Environment and Effects
Table 3-62. Acres of detrimental soil disturbance from harvest
and temporary road construction by alternative
Soil disturbance
Alt 1
Alt 2
Alts
Alt 4
Alts
a,b
Ground yarding
0
24
39
62
60
a,b
Helicopter yarding
0
0
0
5
0
Temporary road
construction
0
7
10
19
17
Total acres soil
disturbance
0
31
49
86
77
a
HA = Harvest Acres
b
EDA = Estimated Disturbance Acres (5% ground yarding, 3% helicopter yarding)
The intent of the Regional Soil Quality Standards is to maintain soil
productivity within acceptable standards. The Standards allow up to 15
percent of the productive forestland to be in a detrimental condition.
No harvest or road construction is planned for Alternative 1 ; any
disturbance would be caused by natural events. All action alternatives
would maintain the soil productivity within the acceptable standards.
Alternative 4 is estimated to produce the highest number of acres of
detrimental disturbance (86 acres), followed by Alternative 5 (77
acres), Alternative 3 (49 acres) and Alternative 2 (31 acres). As stated
earlier, the acres may be overestimated for all action alternatives, with
the exception of Alternative 5 because they include partial harvest
units.
3.10.5.4 Mass Movement
Based on analysis provided by Swanston (1991) landslide potential is
projected to be higher (twice that in harvested versus unharvested
areas) for all alternatives on MMI-1 and 2 soils, and three times as
likely on MMI-4 soils. Table 3-63 shows the acres of proposed timber
harvest by alternative within each MMI Class and Figure 3-10 shows
the MMI-3 and MMl-4 soils within the Project Area. All proposed
units with MMI-4 soils were determined stable through soil stability
analyses.
172 • Chapter 3
Kuiu Timber Sale FEIS
Soils and Geology
Table 3-63. Acres^ of MMI in proposed units by alternative
MMI Class
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
1- Low
0
146
115
374
298
2 - Moderate
0
329
669
999
894
3 -High
0
2
2
0
2
4 - Extreme
0
0
0
14
14
Total Acres
0
477
786
1,387
1,208
a
Variations in acres are the result of rounding.
If Alternative 1 is implemented, landslides in old-growth are still
predicted to occur.
The landslide and MMI soils infonnation indicates that Alternative 4
has the greatest potential for landslides of all the alternatives. This is
due to the greater number of acres proposed for harvest (1,387 acres),
the amount of harvest on MMI-4 soils (14 acres), and the amount of
clearcut harvest proposed (1,024 acres).
Alternative 5 would have the second highest potential for landslides
due to the greatest amount of clearcut harvest (1,208 acres), 14 acres
of MMI-4 soils, and 2 acres of MMI-3 soils.
Alternative 3 would have the second least potential for landslides due
to the amount of acres harvested (786 acres), no MMI-4 acres, and the
low number of clearcut harvest planned (409 acres).
Alternative 2 would have the least potential for landslides due to the
fewest acres of harvest (477 acres), no MMI-4 soils, and the fewest
acres planned for clearcut (197 acres).
On-site evaluations resulted in deleting some acreage due to MMI-4
soils. For the acreage remaining, changes included specific
silvicultural prescriptions such as partial suspension of the logs, partial
to full retention of trees within the MMI area, or a recommendation
that helicopter yarding be used; all of which are documented on the
appropriate Unit Cards (Appendix B).
3.10.5.5 Roads
Table 3-64 displays the miles of proposed road construction by
alternative. As directed by the Forest Plan, no proposed new NFS and
temporary roads would occur on slopes greater than 67 percent
gradient, or on unstable soils.
Kuiu Timber Sale FEIS
Chapter 3 • 173
3 Environment and Effects
All temporary roads would be built to minimum size and width with
few turnouts. At the end of this sale the temporary roads would be
decommissioned with structures removed (culverts) and waterbars
added (refer to Issue 4 - Cumulative Effects of Logging and Road
Construction on Watersheds and the Transportation section of this
chapter for more infonnation on structures and closures). There is no
mechanism provided for future maintenance on temporary roads;
therefore, proper closure of these roads is critical for maintaining
hydrologic conditions adjacent to the road.
Reconditioning of existing National Forest System (NFS) roads is also
necessary on between 3.9 (Alternative 3) to 7.7 (Alternative 5) miles
of road. Additional effects to soil productivity are expected to be
minimal because the road prism is still in place. Sediment may be
mobilized, but it is expected to be minimal and would be mitigated
with Best Management Practices (BMPs). See Issue 4 - Cumulative
Effects on Watersheds and the Fisheries sections in this chapter and
the Unit Cards in Appendix B.
Table 3-64. Miles of NFS and temporary road by alternative and MMI class.
MMI Class
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
1 - Low
0
0.6
0.3
1.5
1.0
2 - Moderate
0
0.9
1.8
2.4
2.5
3 -High
0
0
0
0
0
4 - Extreme
0
0
0
0
0
3.10.6
Cumulative
Effects
The cumulative effects analysis area for soils was the Project Area.
The Catalog of Events for Kuiu Island was referenced in determining
cumulative effects. Cumulative effects of the proposed actions on
long-temi soil productivity are directly related to the amount of soil
disturbance that occurs through time. Because Alternative 4 impacts
soils more than any other alternative, its effects are analyzed for
cumulative effects.
Using Landwehr’s estimates to determine detrimental soil conditions
(five percent and three percent for shovel and helicopter logging,
respectively), it is estimated that 336 acres would be disturbed by
temporary road construction and harvest (Landwehr 1999). For
Alternative 4, this includes 86 acres of detrimental soil conditions, 234
acres from past activities, and 16 acres of reasonably foreseeable
future activities cleared by the Crane and Rowan Mountain Timber
Sales EIS. This equates to less than six percent disturbance from the
past, present and reasonably foreseeable acreage involved (5,751
174 • Chapter 3
Kuiu Timber Sale FEIS
Soils and Geology
acres), which is well below the 15 percent threshold stated in the
Forest Serviee Standards and Guidelines (FSM 2554.03-10).
No other actions are planned in the foreseeable future within the
Project Area. The Three Mile Timber Sale Area is on east Kuiu Island,
outside of the Kuiu Timber Sale Area.
Kuiu Timber Sale FEIS
Chapter 3 • 175
Wetlands
3.11.1
Introduction
3.11.2
Wetland Types
Wetlands are sites whieh generally have both saturated soils for at
least a portion of the growing year and vegetation that is adapted to
wet sites. They are valued for their physieal, ehemical and biological
functions. Wetlands moderate flooding, reduce runoff and
sedimentation, provide wildlife and plant habitat, and may help sustain
stream flow during dry periods.
Kuiu Island is a mosaic of forestland and wetlands. Based on the Soil
Resource Inventory, approximately 17 percent of the Kuiu Timber
Sale Area is classified with soils capable of supporting wetlands. Most
of the wetlands are at the head of Saginaw and Security Bays, and at
the top of the peninsula separating Security Bay from Saginaw Bay.
Different wetland types are found from sea level to mountain top.
Resource values associated with these wetlands vary, depending on
biological qualities, proximity to water bodies and position on the
landscape.
Detennining what constitutes high value wetlands is largely dependent
on human use or the perceived benefit of the wetland. Because human
perceptions change, the values we place on wetlands or upland
ecosystems also change over time. There are two wetland habitat types
in the Kuiu Timber Sale Area, covering approximately 200 acres, that
are currently considered high value wetlands: estuaries (60 acres) and
tall sedge fens (140 acres). No activities are proposed on these wetland
types for this project. Listed below are the types and acres of wetlands
found in the Kuiu Timber Sale Area. A detailed description of wetland
types are in the Wetlands Resource Report available in the Kuiu
Timber Sale planning record.
• Alpine/Sub Alpine Muskegs (1,027 acres or 2.2 percent)
• Alpine/Sub Alpine Forested Wetlands/ Meadow Mosaic (174 acres
or 0.4 percent)
• Estuarine Wetlands (60 acres or 0.1 percent)
• Forested Wetlands ( 1 ,757 acres or 3.8 percent)
• Muskegs (987 acres or 2.1 percent)
• Muskegs/Forested Wetlands Mosaic (3,707 acres or 8 percent)
• Sedge Fens (140 acres or 0.3 percent)
176 • Chapter 3
Kuiu Timber Sale FEIS
Wetlands
3.11.3
Affected
Environment
3.11.3.1 Guidance
Direction is available in the Forest Plan Standards and Guidelines (p.
4-111), BMP 12.5, Wetland Identification, Evaluation and Protection,
and Wetlands Executive Order 1 1988.
The Forest Service is required by Executive Order 11990 and Section
404 of the Clean Water Act to preserve and enhance the natural and
beneficial values of wetlands whenever practicable while carrying out
land management responsibilities.
Past harvest from wetland areas in the Project Area (approximately
325 acres) is minimal. Less than five percent of the previously
harvested areas were on wetlands, including forested wetlands and
wetland complexes. Less than 15 percent of the roads were built across
wetlands to access timber.
3.11.3.2 Timber Harvest
Most wetlands do not support productive forest and are not harvested;
therefore, timber harvest usually only affects forested wetlands and
some upland complex areas. The impacts that do occur are generally
caused by roads and only impact a small percentage of wetlands on the
Tongass.
Many of the forested wetland soils capable of supporting forests
suitable for timber production were included in the suitable timber
base during the analysis of the Forest Plan. 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 (Julin and D’Amore 2003).
After harvest in a wetland area, vegetation ehanges on both low
volume old-growth and young growth forest stands. A small and
temporary increase in soil moisture is expected until transpiration and
interception of rainfall is equivalent to pre-harvest conditions. These
effects are common to all the action alternatives. Table 3-65 displays
acres of timber harvested on forested wetland for each alternative.
Kuiu Timber Sale FEIS
Chapter 3 • 177
Environment and Effects
Table 3-65. Acres of wetlands previously harvested and proposed for
harvest within the Kuiu Timber Sale Area by alternative
Wetland Type
Existing
Managed
Stands
Alt 1
Alt 2
Alt 3
Alt 4
Alt 5
Alpine/Subalpine Muskegs
15
0
0
0
0
0
Forested Wetlands
216
0
15
34
62
68
Muskegs/Forested
Wetlands Mosaic
94
0
17
24
57
57
Total Harvest
325
0
32
58
119
125
3.11.3.3 Roads on Wetlands
For each action alternative, the amount of proposed NFS and proposed
temporary roads within wetlands is small in proportion to the amount
of wetlands within the Project Area and vicinity. While effects to
wetlands from road construction associated with this and foreseeable
projects may be long lasting, they are expected to be of limited extent
and of little consequence due to the abundance of wetlands.
A direct effect to wetlands is the placement of fill material during the
construction of temporary roads. Proposed temporary roads would
cross forested wetland in all of the action alternatives and cross
muskegs/forested wetlands mosaics in two of the four action
alternatives (Table 3-66). There would also be a slight alteration of soil
drainage for several feet on either side of the prism, which can be
expected to alter vegetation in these areas. Drainage ditches normally
collect and divert overland flow and shallow surface flow to the
nearest stream channel. After timber harvest, temporary roads would
be decommissioned by removing culverts from streams, bypassing
ditch relief culverts with waterbars and adding extra waterbars as
needed to control runoff.
178 • Chapter 3
Kuiu Timber Sale FEIS
Wetlands
Table 3-66. Proposed temporary road miles crossing wetlands
Wetland Type
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Forested Wetland
0.0
0.01
0.1
0.4
0.4
Muskeg/Forested
Wetland Mosaic
0.0
0.0
0.0
0.2
0.2
Total Road Miles to be
Constructed on
Wetlands
0.0
0.01
0.1
0.6
0.6
3.11.4.1 Alternative 1
Alternative 1 proposes no new road construction, no timber harvest
and no road closure. This alternative would not be expected to alter the
current wetlands state through management activities.
3.11.4.2 Effects to the Action Alternatives
All NFS roads that are reopened for this timber sale would be put back
into storage after timber harvest is completed. NFS roads would be
stored using any combination of tank traps, pulling culverts on the first
part of the road, and blocking or gating the road. NFS roads in storage
are system roads and may be reopened for future use. New NFS roads
would be placed in storage after timber harvest is complete. All
temporary roads would be decommissioned. Closing the existing roads
may restore some of the wetland functions. The prism would stay in
place but drainage would be reestablished.
There are different amounts of wetland harvest and road construction
on wetlands for each alternative (Tables 3-65 and 3-66). Among the
action alternatives, the impacts from the proposed harvest and road
building thru forested wetlands and muskeg/forested wetland mosaic
types within the Kuiu Timber Sale Area are not considered significant.
This is because there are no estuary or tall sedge fens affected and
because the amount of forested and muskeg wetlands impacted would
be relatively small in comparison to what is present on Kuiu Island.
The cumulative effects analysis area was the Project Area. The
Catalog of Events for Kuiu Island was referenced to determine
cumulative effects. Cumulative effects include the past harvest of
wetlands (approximately 325 acres), the currently proposed harvest
discussed above, and the reasonably foreseeable future harvest of 482
acres and associated road building analyzed in the Crane and Rowan
Mountain Timber Sales EIS - all within the planning area.
The predicted amount of detrimentally disturbed soil due to past,
present, and foreseeable harvest (325, 125 and 6 acres, respectively) is
3.11.5
Cumulative
Effects
3.11.4
Comparison of
Alternatives
Kuiu Timber Sale FEIS
Chapter 3 • 179
3 Environment and Effects
less thali six percent of wetland acreage for Alternative 5, the
alternative with the most wetland acreage. Impacts to the Project Area
would still be well below the Forest Plan standards and guidelines,
which state that no more than 15 percent of an activity area can be
detrimentally disturbed through management practices.
The proportion of wetlands to be impacted in all alternatives is
considerably less than the total amount of wetlands available in the
area. Many of the high value wetland habitats on the Tongass National
Forest are protected either by land use designations or by standards
and guidelines specifically addressing wetlands.
Cumulative effects to wetlands resulting from this project and
reasonably foreseeable projects are expected to be minor. Effects from
timber harvest are expected to be temporary. After timber harvest, it is
expected that wetland function and habitat characteristics would be
restored through natural processes of vegetation growth and
succession. While effects to wetlands from road construction may be
long lasting, they are expected to be limited due to the low number of
road construction miles through wetlands
180 • Chapter 3
Kuiu Timber Sale FEIS
3.12.1
Introduction
3.12 Transportation
Forest roads are classified as National Forest System (NFS) roads,
temporary roads and unauthorized roads by 36 Code of Federal
Regulations (CFR) 212.1.
• A National Forest System 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” (36
CFR 212.1). NFS roads are generally required to provide long-
term or intermittent motor vehicle access. 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.
• A temporary road or trail is “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” (36 CFR 212.1).
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.
• Unauthorized roads are not managed as part of the forest
transportation system. These include unplanned roads, abandoned
travelways, 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.
Decommissioning can occur for all three types of roads. On NFS
roads, decommissioning removes the road from the long-tenn forest
road transportation system. Otherwise, the act of decommissioning is
the same for all roads, which can range from blocking the entrance and
removing drainage structures to obliterating the road. The end result is
the stabilization and restoration of unneeded roads to a more natural
state (36 CFR 212.1). For this project, temporary roads will be
decommissioned by pulling all culverts and bridges, adding waterbars,
and blocking the entrance of the road with a tank trap.
Maintenance and reconditioning of existing National Forest System
(NFS) roads is an ongoing process that occurs on a periodic basis.
Noraially 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 from documentation
Kuiu Timber Sale FEIS
Chapter 3 • 181
3 Environment and Effects
in an EIS or an EA unless scoping indicates extraordinary
circumstances (FSH 1 909. 15,31.12, #4). The maintenance and
reconditioning of NFS roads on 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, recondition roads to comply with best management
practices, maintain the existing infrastructure for the proposed timber
sale or 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 and reconditioning
work are included in the cumulative effects analysis for this project.
Changes in road type and mileage between the DEIS and
the FEIS
The Kuiu Timber Sale DEIS proposed the construction of up to 19
miles of temporary roads. In response to public concerns about roads
across the Forest, the Interdisciplinary Team (IDT) took another look
at the classification of these proposed roads. With further analysis of
the Forest LSTA and possible future activities, the IDT reclassified
some of the miles of temporary road as new NFS road.
A second notable difference between the DEIS and the FEIS is the
total miles of roads built in each action alternative. In the DEIS,
sections of temporary roads were counted twice in the total miles of
new or reconstructed road. This error accounts for approximately 7 to
9 miles of road that are no longer in the total miles of new NFS and
temporary road construction.
Road maintenance consists of periodic repairs to an existing road
surface, in addition to 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 reconditioning is heavier maintenance of an existing road which
includes work such as culvert replacement, surface rock replacement,
and subgrade repair.
Road maintenance and reconditioning consist of performing the work
necessary to retain or restore the road’s original traffic service level.
The amount and level of maintenance and repair is dependent upon
traffic management objectives and maintenance criteria.
Roads are often built and operated at a higher maintenance level
during the timber sale than they are afterwards. The operational
maintenance level is the maintenance level assigned to a road which
considers the immediate needs, road condition, budget constraints, and
Kuiu Timber Sale FEIS
3.12.2
Road Access
Management
182 • Chapter 3
3.12.3
Road Analysis
Process
Transportation
environmental eoneems; in other words, it defines the level at which
roads would be maintained during the timber sale. The objective
maintenance level is the maintenance level assigned to the road after
timber harvest. It considers future road management objectives, traffic
needs, budget constraints, and environmental concerns.
The definitions for maintenance levels (ML) originate from the Forest
Service Handbook 7709.58. The purpose of the MLs is to define the
level of service provided by, and maintenance required for, a specific
road or segment.
• Level 1 . Assigned to intennittent service roads that are closed to
vehicular traffic. Emphasis is normally given to maintaining
drainage facilities and runoff patterns. These roads may be placed
into storage.
• Storage is a term used only for NFS roads. The physical on-the-
ground changes maybe similar to a decommissioned road;
however, roads in storage are considered part of the long-term
forest road transportation system and may be opened to vehicular
traffic in the future. The process/action of storage involves 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. Drainage structures in live drains may be
completely removed to restore natural drainage patterns. Ditch
relief culverts may be left in place and supplemented with deep
water bars in order to minimize the cost of reusing the roads in the
future.
• Level 2. Assigned to roads open for use by high clearance
vehicles. Passenger car traffic is not a consideration. Log haul
may occur at this level. Most roads within the Project Area are ML
1 or ML 2.
• 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. There are two ML 3
roads in the Project Area.
• Levels 4 and 5 are maintained to higher levels of comfort for a
driver in a standard passenger car. There are no ML 4 or 5 roads in
the Project Area.
Part of the analysis of the Project Area is to identify the minimum road
system needed for safe and efficient travel and for administration,
utilization, and management of National Forest System lands. The
minimum system is the road system determined necessary to:
• Meet resource and other management objectives adopted in the
Tongass Land and Resource Management Plan,
Kuiu Timber Sale FEIS
Chapter 3 • 183
3 Environment and Effects
3.12.4
Existing
Roads
• Meet applicable statutory and regulatory requirements,
• Reflect long-term funding expectations, and
• Ensure that the identified system minimizes adverse environmental
impacts associated with road construction, reconstruction,
decommissioning, and maintenance.
The Road Analysis Process (RAP) for the Project Area is a tiered,
science-based system of analysis. The first layer is the Forest-wide
RAP, which is an analysis of the Tongass National Forest. The second
layer is the Kuiu Road Analysis which includes the Kuiu Timber Sale
Area.
The road management objectives for roads used in this project are in
Appendix B. Each of these roads is considered necessary for long-term
management of the forest on either an intermittent or constant basis.
The current status of the NFS roads in the Project Area, including
those portions that delineate the Project Area, is listed in Table 3-67.
Changes in travel management policy and declining road maintenance
budgets may prevent some of the other proposed recommendations
from the 2001 Kuiu Road Analysis from taking place at this time. The
Petersburg Ranger District Access Travel Management Plan will be
completed in 2009 addressing transportation issues not related to this
project.
The roads in the Project Area are connected to a contiguous road
system consisting of approximately 190 miles of NFS roads on the
northern portion of Kuiu Island. These roads are not connected to any
community, other public roads, or other public transportation systems.
All of the NFS roads were constructed in support of timber sales and
connect to Log Transfer Facilities (LTFs) in Rowan Bay and Saginaw
Bay.
The Project Area has approximately 76 miles of existing NFS roads,
including 4.4 miles of Road 6404 that runs from Rowan Bay LTF to
Road 6402 outside the Project Area. Approximately 1.1 miles of Road
6402 is also outside the Project Area and connects the Project Area to
Road 6404. These roads are included in this analysis because they
could be used for administrative traffic to access the area and for log
haul to Rowan Bay LTF, if an action alternative is selected.
Due to the remote location of Kuiu Island, there is very little public
traffic. Most of the road use on the island is due to administrative use
or logging, with some traffic from outfitter/guides and subsistence
hunting.
184 • Chapter 3
Kuiu Timber Sale FEIS
Transportation
Table 3-67. Existing National Forest System Roads in the Project Area
Road
Length (Miles)
Status
Road
Length
(Miles)
Status
6402
14.5 (includes 1.1
miles outside
Project Area)
Open
6417
3.67
Closed*
6448
0.81
Open
6443
1.3
Closed*
46252
1.10
Closed*
6422
0.24
Closed*
46251
2.13
Open
6401
1.03
Open
6425
6.47
Closed* past
MP4.65
46094
1.58
Closed*
6403
0.37
Closed*
46091
1.58
Closed*
6441
1.73
Open
46152
2.05
Closed*
6442
0.75
Closed*
46154
0.54
Closed*
46098
0.42
Closed*
6415
18.51
Open
6427
3.44
Closed* past
MP 1.15
6421
0.46
Closed*
6413
2.84
Open
6419
0.39
Closed*
46096
3.80
Open
46127
1.43
Closed*
6418
1.70
Open
6411
0.80
Open
46021
1.38
Open
46420
2.27
Open
6404
4.4 miles outside
Project Area
Open
* Closed is defined as undrivable to a highway vehicle.
Closure may be due to manmade obstructions or vegetation.
This document recommends closure of the proposed new NFS roads
and many of the existing NFS roads that are related to this proposed
timber harvest. Reasons for closure to public motorized traffic include
declining road maintenance dollars and wildlife concerns. The
Petersburg Ranger District Access Travel Management Plan scheduled
for publication in 2009 will further address these issues.
All Maintenance Level 1 (ML 1) roads used or constructed for this
project would be open only for authorized activities and would not be
open at any time for public use. A range of options exist to closing
roads and meeting ML 1 standards following the timber sale activities.
However, the implementation of BMPs and effective motorized
closure is required for proper storage with all ML 1 roads to insure
Chapter 3 • 185
3.12.5
Closing
Existing NFS
Roads
Kuiu Timber Sale FEIS
Environment and Effects
appropriate resource protection, regardless of the methods used to
close the road. Given this, the actions taken to most effectively and
efficiently meet BMPs and close roads to motorized use can vary
depending on individual road characteristics. In limited situations,
effectively closing roads to motorized use may require only a
pennanent gate. Most ML 1 road closures, however, would require at
least an adequately sized tank-trap somewhere near the road’s
beginning. Commonly roads require additional deterrents for the first
quarter to a half mile, depending on circumstances. These deterrents
are usually provided by, but not limited to, removing drainage
structures such as culverts. Each road is evaluated for the most
effective and efficient closure prior to project implementation.
3.12.5.1 Road Density
The Project Area has 56.2 miles of existing open NFS roads for an
open road density of 0.78 mi/mi^. Table 3-68 lists the roads in the
Project Area and their status. The action alternatives would physically
close between 7.8 and 10.5 miles of existing NFS roads that are
currently open in the Project Area (Table 3-69). These closures were
recommended in the Kuiu Island Landscape Assessment (2005). The
closed roads would be placed into storage by various methods. These
roads could be re-opened in the future as needed. This project would
decrease the mileage and density of NFS roads left open after timber
harvest in each alternative except the No-Action Alternative, as shown
in Tables 3-68 and 3-69.
Table 3-68. Current and proposed open road density in the Project Area
Alt 1
Alt 2
Alt 3
Alt 4
Alts
Current open road
density (mi/mi^)
0.78 miles per square mile
Proposed open road
density (mi/mi^)
0.78
0.67
0.66
0.63
0.63
Open road density
during harvest
(mi/mi^)
0.78
0.87
0.90
0.96
0.97
3.12.6
Proposed NFS
and
Temporary
Roads
The action alternatives propose between 1.8 and 6.5 miles of new NFS
road construction to access timber harvest units (Table 3-69). Also, the
action alternatives propose between 1.5 and 3.9 miles of temporary
road construction to access timber harvest units (Table 3-69). All new
NFS roads would be placed in storage and all temporary roads would
be decommissioned after timber activities are complete.
186 • Chapter 3
Kuiu Timber Sale FEIS
Transportation
Table 3-69. Existing and proposed miles of open and closed NFS road and miles of
proposed temporary road construction in the Project Area
Alt 1
Alt 2
Alts
Alt 4
Alt 5
Miles of open NFS road
56.2
56.2
56.2
56.2
56.2
Miles of closed NFS road to be temporarily opened
for harvest
0
4.1
3.0
6.1
6.8
Miles of existing open NFS road to be placed into
storage
0
7.8
8.0
10.5
10.5
Miles of new NFS road construction (stored after
harvest)
0
1.8
5.4
6.5
6.5
Miles of open NFS road after harvest
56.2
48.4
48.2
45.7
45.7
Miles of temporary road construction
0
1.5
2.1
3.9
3.5
Total road cost ($1000s)
$0
$553
$1,209
$1,656
$1,764
To provide access to timber harvest units, all of the action alternatives
would recondition between 3.0 and 6.8 miles of existing NFS roads
that are currently closed and in storage. All of these roads would be
closed and put into storage after timber harvest is complete (Table 3-
70). These road miles are included in the miles of reconstruction for
cost.
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 produced by
blasting bedrock, which is then hauled and shaped into a road over
typically soft, uneven terrain. Other factors that contribute to the high
cost of constructing Southeast Alaskan roads include the higher costs
of shipping and labor, the numerous drainage structures needed and
more complex logistics.
The Kuiu FEIS proposes approximately 2.8 miles of new road
construction on decommissioned temporary roadbed. While this is
considered new construction, the actual building cost would be lower.
The adjusted cost for these segments of road is reflected in the average
new NFS road cost per mile.
All road management would follow Best Management Practices
(BMPs) and other applicable laws, regulations, and specifications.
Refer to the Road Management Objectives in Appendix B for more
information on specific BMPs.
Kuiu Timber Sale FEIS
Chapter 3 • 187
3 Environment and Effects
Table 3’-70. Existing NFS road miles that would closed after
timber harvest
Alt 1
Alt 2
Alt 3
Alt 4
Alts
Roads currently drivable and/or with structures
6413
0
2.8
2.8
2.8
2.8
46096
0
3.6
3.6
3.6
3.6
6427
0
0
0
1.1
1.1
46021
0
1.4
0
1.4
1.4
6418
0
0
1.6
1.6
1.6
Total Miles
0
7.8
8.0
10.5
10.5
Roads currently in storage to be opened to access units(s)
6417
0
2.3
1.3
2.3
2.3
6427
0
0
0
2.2
2.2
46091
0
1.0
1.0
1.0
1.0
46094
0
0.7
0.7
0.7
0.7
6422
0
0
0
0.5
0.5
6443
0
0.1
0
0.1
0.1
Total Miles
0
4.1
3.0
6.1
6.8
3.12.7.1 Log Transfer Facilities (LTFs)
The transfer of harvested timber requires that logs be hauled to a site
where they can be removed from trucks, transferred to saltwater for
rafting or loading onto barges, and then towed to a mill. These sites are
tenned “log transfer facilities,” or “marine access points.” There is one
LTF on the north end of the Project Area, Saginaw LTF, and one
approximately six miles south of the Project Area, Rowan Bay LTF.
Access to the Rowan Bay LTF would require log haul over existing
NFS roads 6402 and 6404, a distance of approximately 5.5 miles
outside the Project Area. The Rowan Bay LTF is a steel piling
bulkhead that was designed for use with a barge for loading logs.
However, logs could also be rafted from this site. The Rowan Bay LTF
is in good condition and would require no reconstruction for log
transportation or storage.
Access to the Saginaw Bay LTF would require log haul over existing
NFS roads 6402 and 6448, both of which are inside the Project Area.
The Saginaw Bay LTF was designed to place the logs in the water for
3.12.7
Other
Facilities
188 • Chapter 3
Kuiu Timber Sale FEIS
Transportation
rafting. While no reconstruction is necessary if logs are rafted, the LTF
would need to be reconstructed prior to any barge use, which would
require an amendment to the existing permit. The reconstruction would
include a shot rock fill placed at the end of the existing filled area. The
new ramp would be made of shot rock fill and would extend off the
front of the existing fill area out into deep water.
Current permits for the construction and use of the LTFs include:
• Section 10 of the Rivers and Harbors Act of 1 899 Corps of
Engineers approval for the construction of stmctures or work in
navigable waters of the United States
• Tidelands permit from the State of Alaska, Department of
Environmental Conservation
• Certification of compliance with Alaska Water Quality Standards
(Section 401 Certification) from the State of Alaska, Department
of Environmental Conservation
• Storm Water Discharge Permit and a permit for discharge of bark
and wood debris from the US EPA (Section 402 of the Clean
Water Act)
3.12.7.2 Sort Yard
There is a sort yard, approximately 12 acres in size, located on the
uplands adjacent to the Rowan Bay LTF. Due to its size and
convenient location, it is not expected that any other sort yard would
be needed for any of the action alternatives if Rowan Bay were
selected as the LTF site.
There is an existing storage yard adjacent to the Saginaw Bay LTF for
storing up to 200 mbf barge loads. In addition to the storage area, a
sort yard at the end of NFS road 6448, approximately one mile from
the Saginaw LTF site, is proposed for log sorting prior to storage at the
LTF site. This sort yard would be located at the old logging camp site.
This area is currently covered in alders, but the surface underneath is
shot rock. The sort yard site would be approximately 400 x 800 feet in
size and located on the existing flat terrain.
3.12.7.3 Logging Camp
There is an existing land camp at Rowan Bay about one mile south of
the LTF. The camp has an Alaska Department of Environmental
Conservation approved water and sewer system. This would be a
typical camp for any timber operator that worked in this area. A
floating camp could also be used during harvest activities. Appropriate
permits would need to be acquired by the operator.
Kuiu Timber Sale FEIS
Chapter 3 • 189
3 Environment and Effects
3.12.7.4 Forest Service Facilities
There is a Forest Service administrative site located near the Rowan
Bay logging camp. This site has a bunkhouse/office building and a
separate equipment/generator building. The administrative site is used
by Forest Service employees working in the Rowan Bay area.
3.12.7.5 Rock Quarries
There is a need for rock sources during the construction of new NFS
roads and temporary roads, as well as for the maintenance of existing
NFS roads within the Project Area. The rock source is preferably
within one mile of the road construction or maintenance site.
Rock quarries are usually developed on a hillside by removing any
trees and overburden above the bedrock, typically within five feet of
the surface. The bedrock is drilled and blasted to produce rock that is
one foot in diameter and less. It is used as an overlay to produce the
road surface.
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 II stream buffers, old-growth
habitat reserves, eagle and goshawk nest tree buffers and non-
developmental LUDs. With either the expansion of an existing quarry
or the development of a new one, the area footprint would not exceed
five acres.
Listed below are roads that would require rock material if an action
alternative is selected. Possible rock quarry sources are also listed.
• Construction of proposed Road 46030; An existing quarry at MP
0.1 could be expanded to provide material. A new site could be
developed in the existing clearcut between MP 0.6 and MP 1.1.
• Construction of proposed Road 4603 1 : A new quarry site could be
developed in the existing clearcut between MP 0.0 and MP 0.4 to
provide material.
• Construction of proposed Roads 46032 and 46033: The existing
quarry on Road 46096 at the intersection of proposed Road 46032
could provide material. A new site could be developed in proposed
timber Unit 208 between MP 0.2 and MP 0.8 on Road 46096.
• Construction of proposed Road 46034: The existing quarry at MP
0. 1 could provide material. A new site could be developed between
MP 0.5 and MP 0.9.
• Construction of proposed Road 6427 (MP 3.44 - MP 3.66): The
existing quarry at MP 1.7 could provide material. A new site could
be developed between MP 0.5 and MP 0.9.
190 • Chapter 3
Kuiu Timber Sale FEIS
3.12.8
Comparisons
of Alternatives
Transportation
• Construction of proposed Road 46021 (MP 1.38 - MP 1.98): The
existing quarry at MP 0.6 could provide material. A new site could
be developed between MP 1.0 and MP 1.4.
• Reconditioning of existing Road 6417: The existing quaiTies at
MP 0.5, MP 1.2, and MP 1.4 could provide material.
• Reconditioning of existing Road 6427: The existing quarry at MP
1.7 could provide material.
• Reconditioning of existing Road 6443: The existing quarry at MP
0.66 could provide material, as well as the existing quarry at MP
1.4 on Road 6417.
• Reconditioning of existing Road 6422: The existing quarries at
MP 1.2 and MP 1.4 on Road 6417 could provide material.
• Reconditioning of existing Road 46091 : The existing quarries at
MP 0.8 could provide material, as well as the existing quarry at
MP 6.3 on Road 6415.
• Reconditioning of existing Road 46094: The existing quarry at
MP 0.9 could provide material, as well as the existing quarry at
MP 12.8 on Road 6402.
The effects of the transportation system on other resources are
discussed in the specific resource sections. This section focuses on the
transportation system by alternative and discusses post-project
management.
Alternative 1
The maintenance of existing NFS roads would not change. Existing
open NFS roads would not be placed into storage and no new NFS
roads are proposed.
Actions Common to all Action Alternatives
• All new NFS roads would be placed into ML 1 and stored after
timber harvest activities.
• Reconditioning of currently closed NFS roads needed for accessing
timber units would consist of removing blowdown trees, brushing,
regrading of the existing roadbed, and clearing road ditch lines and
drainage channels. Reconditioning also involves reinstalling
culverts at drainage and stream crossings. These roads would be
placed into ML 1 and stored after timber harvest activities. All
temporary roads would be decommissioned after timber harvest.
Alternative 2
• Construct 1 .8 miles of new NFS road.
Kuiu Timber Sale FEIS
Chapter 3 • 191
3 Environment and Effects
• Construct 1.5 miles of temporary road.
• Place three existing open NFS roads, totaling about 7.8 miles, into
ML 1 and close after timber harvest activities are complete.
• Recondition 4.1 miles on four NFS roads that are eurrently elosed.
Alternative 3
• Construct 5.4 miles of new NFS road.
• Construct 2.1 miles of temporary road.
• Plaee three existing open NFS roads, totaling about 8.0 miles, into
ML 1 and elose after timber harvest activities are eomplete.
• Recondition 3.0 miles on three NFS roads that are eurrently closed.
Alternative 4
• Construet 6.5 miles of new NFS road.
• Construet 3.9 miles of temporary road.
• Place 10.5 miles on five existing NFS roads in MLl and close after
timber harvest activities are complete.
• Recondition 6. 1 miles on five NFS roads that are currently elosed.
Alternative 5
• Construet 6.5 miles of new NFS road.
• Construet 3.5 miles of temporary road.
• Plaee 10.5 miles on five existing NFS roads in ML 1 and elose
after timber harvest activities are complete.
• Reeondition 6.8 miles on six existing NFS roads that are eurrently
elosed.
Summary
All of the proposed action alternatives would reduce the amount of
open NFS road by plaeing them into storage after timber harvest
aetivities. In turn, this would reduce the amount of road maintenance
required in the Project Area. Beeause these roads reeeive little use, the
amount of use is not expected to ehange significantly as a result of
these elosures.
The eumulative effects analysis for transportation includes the entire
road system on Kuiu Island and foeuses on miles of open NFS road.
The Catalog of Events for Kuiu Island was refereneed to determine the
effeets considered in this analysis.
3.12.9
Cumulative
Effects
192 • Chapter 3
Kuiu Timber Sale FEIS
Transportation
All of the proposed alternatives would reduce the amount of open NFS
road by placing them into storage after timber harvest activities are
complete. The changes on the Kuiu road system are not expected to
effect long-term access or travel management. During the timber sale
there would be periods of time where the timber purchaser maintains
certain existing roads. Roads may also be temporarily blocked to move
equipment or due to safety concerns during logging operations. These
temporary conditions would not have a cumulative long-term effect.
All of the action alternatives and several reasonably foreseeable future
activities would add new NFS roads to the Kuiu road system. The
foreseeable future activities include: Crane and Rowan Mountain
Timber Sales and the Threemile Timber Sale. These two projects
could construct an additional 6.6 miles of new NFS roads and 3.3
miles of temporary roads. The new NFS roads would be closed and
placed in storage after timber harvest activities. Temporary roads
would be decommissioned after timber harvest. Cumulatively, open
NFS miles would decrease within the Kuiu road system.
The Petersburg Ranger District Access and Travel Management
(ATM) Plan will look at road access across the District in terms of
needs, resource use and protection, and declining road maintenance
budgets. It will consider all roads, including nonsystem roads as well
as the closure of more road miles on Kuiu Island. If the decision is
made to close more roads on Kuiu, the amount of road maintenanee
required would be reduced. Roads would be turned from ML 2 into
ML 1 resulting in considerable maintenance savings. This would
provide additional funding for maintenance on the remaining open
roads. The District ATM will be completed in 2009.
Maintenance of existing National Forest System roads has occurred
and will continue to occur in the Project Area as long as future funding
is available. On Kuiu Island major contract road maintenance (costing
over $100,000) is generally performed every three to four years on
most of the ML 3 roads and on a few of the ML 2 roads. This major
maintenance contract generally includes blading, brushing, clearing
culvert inlets and replacing failed eulverts. In addition, hand road
maintenance is performed annually on most of the ML 2 and ML 3
roads. Hand maintenance involves clearing blown down trees from the
roadway after the snow has melted in the spring..
Road maintenance and reconditioning projects since the DEIS include
the Kuiu Road Maintenance CE 2006, which included routine
reconditioning and brushing of several of the most heavily used ML 3
roads on Kuiu Island.
Kuiu Timber Sale FEIS
Chapter 3 • 193
3.13.1
Visual
Character
3.13.2
Existing
Condition
3.13 Scenery
Scenery is an important aesthetie quality of Tongass National Forest
System lands. The Forest Plan recognizes this and addresses the
degree of acceptable alteration of the landscape by assigning Visual
Quality Objeetives to eaeh land use designation. These objeetives are
based on the visibility of the landseape from identified Visual Priority
Routes and Use Areas (Appendix F of the Forest Plan) which form
Viewsheds and represent the area of analysis.
Southeast Alaska seenery encompasses mountains, glaciers, water,
sky, weather, trees, animals, boats, people, and development. While
there are an infinite number of personal interpretations of scenery, the
Forest Plan assumes general preferences based on cultural norms and
predominant soeial values. The quality of the scenic environment ean
be eategorized in terms of visual eharaeter types.
3.13.2.1 Character and Variety Class
Visual eharaeter types provide a framework for defining the quality or
distinetiveness of scenery. Each character type eontains unique
features of landforms, vegetative patterns, water forms, or geologic
features. The greater the diversity of form, line, texture, and color in a
landscape, the greater the seenic value. There are six distinct visual
character types represented on the Tongass National Forest. North
Kuiu Island lies within the Kupreanof Lowland visual character type.
The natural landscape within eharaeter type is deseribed in terms of
scenic value and placed into three variety class designations (USD A
Forest Serviee 1973). The variety classes are described below with the
acres of eaeh within the Projeet Area. For a detailed description, see
the Seenery Resource Report available in the Kuiu Timber Sale Area
planning reeord.
Variety Class A: Kupreanof Lowland, Distinctive. The amount of
Variety Class A within the Projeet Area is quite small (291 acres) and
confined to an area of shoreline in upper Security Bay.
Variety Class B: Kupreanof Lowland, Common. The amount of
Variety Class B encompasses approximately 59 pereent of the Project
Area (27,336 aeres) and consists of the forested mountain slopes.
Variety Class C: Kupreanof Lowland, Minimal. Variety Class C
encompasses approximately 41 pereent of the Project Area (18,475
aeres) and eonsists of relatively flat terrain scattered throughout the
Project Area.
194 • Chapter 3
Kuiu Timber Sale FEIS
Scenery
3.13.2.2 Visual Priority Travel Routes and Use Areas
The Forest Plan identified speeific locations from which scenery is
viewed, reflecting high visitor use and a greater public concern for
scenic quality. These Visual Priority Travel Routes and Use Areas are
used to assess scenic condition and the locations from which scenic
value is to be emphasized. Areas visible from Priority Travel Routes
and Use Areas are described in scenery resource terms as the “seen
area.” “Seldom seen” or “not seen” areas are defined as those locations
not viewed from any position along a Visual Priority Travel Route and
Use Area.
Viewing locations within the Project Area from which scenic quality is
measured in this analysis include Rowan Bay, Security Bay, Saginaw
Bay, Kadake Bay, and Kadake Creek. The Project Area is also viewed
at a distance (3-5 miles) from Frederick Sound, but is seen in closer
proximity from either Saginaw Bay or Security Bay where the
potential effects would be greater.
All the Visual Priority Travel Routes 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 passengers of the Alaska Marine
Highway System, commercial fishing vessels, fishing and whale
watching charter boats, and small recreational boats involved in
camping, hunting, fishing, or subsistence activities.
3.13.2.3 Visibility and Distance Zones
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.
The Forest Service describes visibility in terms of three distance zones:
foreground, middleground, and background (USD A FS 1974). Each
distance zone is listed in detail in the Scenery Resource Report which
is available in the Kuiu Timber Sale planning record. Project Area
visibility from Visual Priority Travel Routes and Use Areas is
displayed in Table 3-71.
Foreground: (0 - Vi mile from the viewer) -Foreground viewing
areas include a portion of the Security and Saginaw Bay shoreline and
areas within the Kadake Creek river corridor.
Middleground: {Vi - 3 to 5 miles from the viewer) - Middleground
viewing of the Project Area includes most of the prominent forested
ridges visible from saltwater.
Background: (3-5 miles and greater) - There are no background
viewing locations inventoried within the Project Area.
Kuiu Timber Sale FEIS
Chapter 3 • 195
3 Environment and Effects
Not Seen: Those landscapes within the Project Area which are not
visible from Visual Priority Travel Routes and Use Areas as a result of
topographic relief or other physical attributes.
Approximately 70 percent of the Project Area is categorized as not
seen from Visual Priority Travel Routes and Use Areas.
Table 3-71. Acres of harvest in distance zones by alternative
Distance Zone
Alt 2
Alt 3
Alt 4
Alts
Foreground
18
0
49
0
Middleground
144
246
500
455
Background
0
0
0
0
Not Seen
316
540
838
753
Total Harvest Acres
478
786
1,387
1,208
3.13.2.4 Existing Visual Condition (EVC)
Existing Visual Condition (EVC) describes the visual appearance of
the landscape at the time the assessment in conducted. 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 EVC for this analysis is to
use the present visual condition of the Project Area as a baseline to
evaluate the acceptable desired future condition and cumulative effects
outlined in the Forest Plan management prescription criteria. Six levels
are used to describe the landscape’s EVC ranging from pristine to
intensively modified:
Type I: Landscapes where only ecological change has occurred,
except for trails needed for access. Landscapes appear to be untouched
by human activities.
Type II: Landscapes where change is not noticed by the average
forest visitor unless pointed out. These landscapes have been altered
but changes are not perceptible.
Type III: Landscapes where changes are noticeable by the average
forest visitor, but they do not attract attention. Changes appear to be
minor disturbances.
Type IV: 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.
196 • Chapter 3
Kuiu Timber Sale FEIS
Scenery
Type V: 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.
Type VI: Landscapes where changes are in glaring contrast to the
landscape’s natural appearance. Changes appear as dramatic, large
scale disturbances that strongly affect the average forest visitor.
The Existing Visual Condition of the Project Area is primarily in a
Type V, as evidenced by the amount of timber harvest that has
occurred over the past 20 years. This condition however is not as
apparent when viewed from saltwater locations where regeneration of
the larger and older logging units has begun to visually recover. EVC
Type V rating is more a result of the extent of harvest than the direct
visual appearance 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 3-72. Project Area Acres by Existing Visual Condition
Existing Visual Condition
Acres
Type I
8,484
Type II
434
Type III
36
Type IV
8,023
Type V
25,020
Type VI
4,105
Kuiu Project Area
46,102
3.13.2.5 Visual Quality Objectives (VQO)
Visual Quality Objectives (VQOs) provide measurable standards to
assess the scenery resource based on landfonn characteristics and
levels of public concern. VQOs are established by incorporating the
previously defined visual resource elements of variety class, viewing
sensitivity, and distance zone. Adopted VQOs are established during
the forest planning process. Adopted VQOs help govern the location,
design, scheduling, and level of management activities, such as timber
harvest, to achieve or maintain the desired future condition. The Forest
Plan adopted the following four VQOs as management direction:
Retention - Changes in the landscape are not visually evident to the
average forest visitor.
Kuiu Timber Sale FEIS
Chapter 3 • 197
3 Environment and Effects
Partial- Retention - Changes in the landseape may be evident to the
casual observer but appear as natural occurrences when contrasted
with the appearance of the surrounding landscape.
Modification - 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.
Maximum Modification - 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.
Adopted VQOs reflect the management objectives of the Forest Plan
land use designations (LUDs) incorporating other resource objectives,
and also represent a future visual condition planned for a particular
landscape. The VQOs within the Project Area include Maximum
Modification (Timber Production LUD), Modification (Timber
Production LUD), Retention (Old-growth Habitat LUD), and Partial
Retention (Recreational River LUD within the %-mile corridor of
Kadake Creek) (Figure 3-11).
Management emphasis would reflect activities that may appear highly
evident in those areas maximizing timber production and maintaining
a natural appearance in other locations. The Old-growth Habitat
Reserve would be retained in a natural condition where the Retention
VQO is applied and no harvest would occur. The acres of Forest Plan
VQOs within the Project Area are displayed in Table 3-73.
Table 3-73. Project Area acres by Forest Plan adopted
visual quality objective
Adopted Visual Quality Objective
Acres
Retention (Old-Growth Habitat LUD)
1,245
Partial Retention (Recreational River)
1,595
Modification (Timber Production LUD)
3,365
Maximum Modification (Timber Production
LUD)
39,541
Non-National Forest System Lands
356
Kuiu Timber Sale Area Total
46,102
3.13.3
Environmental
Consequences
Timber harvest within a portion of the Project Area visible from
Visual Priority Travel Routes and Use Areas would be designed and
implemented to meet the Forest Plan adopted VQOs. The future visual
198 • Chapter 3
Kuiu Timber Sale FEIS
3.13.4
Direct and
Indirect
Effects
Scenery
condition of the affected landscape would reflect the Timber
Production LUD, where the primary goal is to manage land for the
sustained long-term yield of wood. The visual effects of management
activities in this LUD would be more noticeable than they would be in
a LUD that allows less development.
Several factors contribute to the degree of visibility of the proposed
activities. These factors include: (1) the loeation from where
development is visible, (2) the distance from which the development is
observed, (3) the vegetative composition of the surrounding landscape,
and (4) the design outcome of the activity.
Each of the action alternatives would result in some visual
modification of the landscape in the Project Area. For all of the action
alternatives, the majority of harvest units would not be visible from
Visual Priority Travel Routes Areas. The visible harvest would be
prominent for viewers entering upper Saginaw Bay under either
Alternative 3 or 5. For Security Bay the most visible change would
occur under Alternatives 4 and 5. Forest visitors also would notice one
harvest unit when entering upper Rowan Bay under implementation of
Alternatives 4 or 5. Under Alternative 2 visitors frequenting Security
Bay, Saginaw Bay, or Rowan Bay would not likely notice much
change beyond existing conditions. Harvest within the Kadake Creek
recreational river corridor would only occur under Alternatives 2 and
4. The visual change under these alternatives would resemble a natural
forest setting.
The overall scenic effect of the alternatives would vary in comparison
to the visible harvest area as seen from sensitive viewing loeations.
Alternatives 4 and 5 would create the greatest amount of visible
change to the landscape from development of harvest units.
Alternative 3 would harvest approximately 50 percent fewer acres than
would Alternatives 4 and 5. Alternative 2 would have the least effect,
harvesting approximately 1 62 acres potentially visible from priority
viewing areas.
3.13.4.1 Effects Common to all Action Alternatives
Each of the action alternatives would result in some degree of change
in the appearance of the landscape. Green tree retention within some
units would reduce the overall effects. Additionally, all of the
proposed timber harvest of any given alternative would not be seen at
one time from a single location. Impacts to scenery for all alternatives
would remain relatively constant over time as harvested areas develop
and new stands are removed. All action alternatives would achieve a
higher level of visual quality than the Adopted Visual Quality
Kuiu Timber Sale FEIS
Chapter 3 • 199
3 Environment
3.13.5
Effects by
Alternative
and Effects
Objectiv,e of Maximum Modification for the majority of the Project
Area.
Utilization of the existing LTFs either at Rowan Bay or Saginaw Bay
for log transfer, storage, and camp operations would result in the
developed appearance and modification to the seenic environment
associated with these types of aetivities. The LTFs are visible in the
foreground distance zone along the shoreline near the head of these
bays. For those traveling the inside waters of Rowan Bay or Saginaw
Bay the logging operations would not likely be noticed until within Va
to I/2 mile of the locations. The sort yard, area for log storage, and most
equipment at the sites would be partially sereened from view by
foreground vegetation and would meet the Forest Plan VQOs.
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, and would be consistent with
the VQOs. Camp operations would be required to obtain and follow
the necessary permitting requirements associated with these aetivities.
Some of the effects of temporary and new road construetion, borrow
pits, and other ground disturbing aetivities neeessary to implement the
Kuiu project would be visible from Visual Priority Travel Routes
Area; however, these effects would be far less visible than timber
harvest and would meet the Forest Plan VQOs.
Alternative 1
This alternative defers timber harvest in the Project Area and
maintains the existing visual character of the landscape. Previously
harvested units within the Projeet Area would continue to mature and
develop the visual characteristies of a more natural appearing and
undeveloped forest.
Alternative 2
Six harvest units are partially visible from Visual Priority Travel
Routes and Use Areas. However, all six are not visible from the same
location.
Portions of Units 103c and 111, which have a Maximum Modifieation
VQO, are in the seen area of upper Security Bay. The effects of partial
harvest on unit 1 1 1 would achieve a Partial Retention VQO, and meet
a higher degree of scenie quality than required by the Forest Plan.
Portions of Units 207, 208a, and 208b would be visible near the head
of Saginaw Bay, resulting in a VQO of Maximum Modification. The
effects of Unit 207 would be lessened by 50 percent basal area
retention which would achieve a higher VQO of Modification. Unit
200 • Chapter 3
Kuiu Timber Sale FEIS
Scenery
208a would achieve the Partial Retention VQO with 16 aeres of visible
harvest. Unit 208b would result in a Maximum Modification VQO
with 51 visible acres.
Unit 415 is located in the Kadake Creek drainage, and partially within
a Forest Recreational River classifieation. Visibility of harvest from
Kadake Creek itself would not be readily apparent as a result of the
steep stream bank eonfiguration and trees bordering the edge of ereek.
The portion of Unit 415 within the Reereational River corridor would
meet the adopted VQO of Partial Retention. The remainder of Unit
415 located within the Timber Production LUD would achieve a
Modifieation to Maximum Modification VQO.
Alternative 2 proposes harvesting the fewest acres visible from priority
viewing locations. The remaining units in this alternative are not
visible from any Visual Priority Travel Routes and Use Area and
achieve a Maximum Modification or higher degree of seenie quality
than adopted under the Forest Plan.
Alternative 3
Units 109, 204, 205, 207, and 208 are partially visible in the
middleground distance zone from the waters of Seeurity Bay or
Saginaw Bay. All units in this alternative have a Forest Plan VQO of
Maximum Modification.
Unit 109 would be only slightly noticeable and would meet the Partial
Retention VQO. Approximately 21 acres would be partially visible
from the head of Security Bay.
Units 204, 205, 207, and 208 are located in the seen area of upper
Saginaw Bay. Unit 204 would likely meet the Modification VQO with
approximately 69 acres of partial harvest. Units 205 and 208 would
meet the Maximum Modifieation VQO with approximately 39 and 69
acres of visible harvest respectively. Unit 207 would not be visible to
most people visiting Saginaw Bay as it can only be seen from the
extreme upper end of the bay in waters that are not usually navigable,
and would meet a Partial Retention to Modification VQO.
The remaining units in this alternative are not visible from any Visual
Priority Travel Routes and Use Area and meet a Maximum
Modification or higher degree of scenic quality than required by the
Forest Plan.
Alternative 4
Units 101, 109, 1 1 1 , 40 1 , and 503 may be completely or partially
visible in the middleground distanee from the waters of Security Bay.
The Modifieation to Maximum Modification VQOs would be aehieved
and would meet a slightly higher degree of scenic quality than required
by the Forest Plan.
Kuiu Timber Sale FEIS
Chapter 3 • 201
3 Environment and Effects
Units 20,7, 208, 302, and 303, may be completely or partially visible in
the middleground from Saginaw Bay. Unit 207 would not be visible to
most people as it can only be seen from the extreme upper end of the
bay in waters that are not usually navigable, and would meet a Partial
Retention to Modification VQO. Units 302 and 303 would have
approximately 60 acres of visible partial harvest, meeting the
Modification VQO. And Unit 208 would meet the Maximum
Modification VQO with approximately 60 acres of clearcut harvest
visible.
The upper half of the 99-acre Unit 412 would become visible to
travelers entering Rowan Bay at a point where the bay turns in a
northerly direction. The reduced visibility of Unit 412 as a result of
screening by foreground vegetation would reduce the contrast
somewhat so the unit does not appear as a dominant feature in the
landscape. As a result, the unit would meet a Modification to
Maximum Modification VQO depending upon the angle and location
of view.
Units 414 and 415 would harvest a combined total of 49 acres within
the foreground viewing distance of the Kadake Creek Recreational
River Corridor. Silvicultural treatment of 50 percent BA retention
would meet the VQO of Partial Retention. The remainder of Units 414
and 415 located within the Timber Production LUD would achieve a
Modification to Maximum Modification VQO as viewed from within
the corridor.
The remaining units in this alternative are not visible from any Visual
Priority Travel Route or Use Area and achieve a Maximum
Modification or higher degree of scenic quality than required by the
Forest Plan.
Alternative 5
All units in Alternative 5 are proposed for even-aged harvest by
clearcut. Ten of the units are completely or partially visible from
Visual Priority Travel Routes or Use Areas. Units 101, 109, 111, 401,
and 503 are within the seen area of Security Bay and identical in
effects to Alternative 4, The Modification to Maximum Modification
VQOs would be achieved and would meet a slightly higher degree of
scenic quality than required by the Forest Plan.
Units 204, 207, 208a, and 208b are located within the seen area of
Saginaw Bay, and would meet the VQO of Maximum Modification.
202 • Chapter 3
Kuiu Timber Sale FEIS
t
'
Kuiu Timber Sale
Figure 3-11
Adopted Visual Quality Objectives
Legend
Retention
Partial Retention
Modification
IH Maximum Modification
I I Non-National Forest
Recreational River
Managed Stands
I I Unit Pool
Lakes/Saltwater
Project Area Boundary
500ft Contour Interval
Stream Value Class I & I
Existing Open Roads
• Kadake Bay Cabin
A
3.6
I Miles
3.13.6
Cumulative
Effects
Scenery
Unit 412 as seen from Rowan Bay would meet a VQO of Modification
to Maximum Modification depending upon the angle and location of
view as in Alternative 4.
The remaining units in this alternative are not visible from any Visual
Priority Travel Route or Use Area and would meet a Maximum
Modification or higher degree of scenic quality than required by the
Forest Plan.
The Catalog of Events for Kuiu Island was referenced in determining
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
been extensive, modifying the scenic environment from a natural
condition to a condition where landscapes appear highly modified. The
past development considered in this analysis and listed in the Kuiu
Catalog of Events that contributes to scenery’s cumulative effects are
the Crane and Rowan Mountain Timber Sales, North and East Kuiu,
and the APC Long Term Timber Sale Contract, 1981-86 and 1986-90
Operating Periods.
Viewshed is typically the spatial scale used to consider cumulative
effects for scenery, however, for the purpose of this analysis Value
Comparison Units (VCUs), which have similar boundaries, were used.
Temporally, cumulative effects change due to the regrowth of
vegetation, and after 30 years harvested areas are no longer considered
to cumulatively impact scenery.
Implementation of any of the proposed alternatives would continue to
modify the scenic environment. Cumulative effects of future
conditions would continually change over time to a greater or lesser
extent as vegetation grows or is removed, and, in general, ultimately
present the appearance of the desired future condition outlined in the
Forest Plan.
3.13.6.1 Allowable Visual Disturbance
Allowable Visual Disturbance expresses how much visual disturbance
is acceptable for a given area during any given time period. The
proposed management activities for the Project Area may occur
adjacent to or near previously harvested locations. Even though
individual harvest units may meet a particular Visual Quality
Objective, cumulatively a greater impact may result.
Allowable visual disturbance is a means to express cumulative visual
impact that has occurred while achieving the desired future condition
of a particular landscape during the harvest rotation. During the
Kuiu Timber Sale FEIS
Chapter 3 • 205
3 Environment and Effects
effects analysis of the Forest Plan, allowable visual disturbance
thresholds were modeled (Forest Plan FEIS Appendix B, Table B-6, p.
B-18) to describe the expected visual condition for land use
designations. It was assumed that up to 50 percent of a viewshed or
VCU may be under development at any given time for areas within the
Timber Production LUD; therefore, the Timber Production LUD falls
under the Maximum Modification Visual Quality Objective.
Table 3-74. Percentage of Allowable Visual Disturbance by
VCU and Alternative
Alt1
Ait 2
Alts
Alt 4
Alts
VCU 399
(Saginaw)
10%
11%
12%
12%
14%
VCU 400
(Security)
8%
8%
8%
9%
9%
VCU 402
(Rowan)
10%
10%
10%
10%
10%
VCU 422
(Kadake)
15%
15%
15%
16%
15%
The percentage of previously harvested areas within the VCUs
currently range from 8 to 15 percent allowable visual disturbance. This
amount of disturbance is well within the 50 percent threshold
described the Forest Plan and represents a higher degree of scenic
quality than expected for timber production areas. With the addition of
the proposed alternatives, the cumulative effect on scenery also
remains below the 50 percent allowable disturbance threshold.
206 • Chapter 3
Kuiu Timber Sale FEIS
3.14 Recreation
3.14.1
Introduction
3.14.2
Recreation
Opportunity
Spectrum
(ROS)
The Kuiu Timber Sale Area is in the northern seetion of Kuiu Island.
There are three bays within or beside the Project Area boundary:
Security Bay, Saginaw Bay, and Kadake Bay. Not included in the
Project Area boundary but potentially affected by the project is Rowan
Bay where there is a LTF, evidence of a past logging camp, and a
Forest Service administrative facility. Also outside the Project Area
but potentially affected by the proposed actions is an existing
recreation cabin located in Kadake Bay. These are the areas of analysis
for this section.
Access to Kuiu Island is by boat or floatplane. Both Rowan Bay and
Saginaw Bay have LTFs, either of which may be used to transfer logs
from the Project Area to saltwater. The LTFs also provide access to
the area road system for visitors arriving by boat to hunt or recreate in
the area. These visitors may bring all terrain vehicles (ATVs) or street
vehicles to use on the road system. The road system does not connect
to any community or ferry terminal.
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
Project Area has three of the seven ROS classes: Roaded Modified,
Semi-primitive Motorized, and Semi-primitive Non-motorized (Table
3-75). The ROS classes are described in detail in the Recreation
Resource Report found in the Kuiu Timber Sale planning record.
Table 3-75. Existing Recreation Opportunity Spectrum
(ROS) Classes within the Kuiu Timber Sale
a
Area
ROS Class
Acres within
Project Area
Percent of Project
Area
Roaded Modified
38,837
85%
Semi-primitive
Motorized
3,913
9%
Semi-primitive Non-
motorized
2,996
6%
Total Acres
45,746
100%
a
Does not include 356 acres of non-national forest system lands in the
Project Area.
Kuiu Timber Sale FEIS
Chapter 3 • 207
Environment and Effects
Table 3-76. Recreation Opportunity Spectrum (ROS) class acres in the Kuiu
a
Timber Sale Area
ROS Class
Alt. 1
Alt. 2
Alt. 3
Alt. 4
Alt. 5
Roaded
Modified
38,837
38,837
38,858
38,900
38,900
Semi-primitive
Motorized
3,913
3,913
3,913
3,913
3,913
Semi-primitive
Non-motorized
2,996
2,996
2,975
2,933
2,933
Total Acres
45,746
45,746
45,746
45,746
45,746
a
Does not include 356 acres of non-national forest lands within the Project Area.
3.14.3
Recreation
Places and
Sites
Since the majority of Kuiu Island is undeveloped, it is primarily used
for dispersed recreation activities. Viewing scenery and wildlife,
boating, fishing, beaeheombing, hiking and hunting are the primary
dispersed recreation activities that take place.
Highly valued areas defined by accessibility, user preferences, and
presences of certain amenities (scenery, wildlife viewing, and good
fishing) are termed recreation places.
Recreation places are specific areas identified by the Forest Plan that
are used for recreation aetivities. The ROS setting of a recreation place
largely detenuines its attractiveness and utility. The Forest Plan
direetion for recreation places in the Modified Landscape and Scenic
Viewshed LUDs is to maintain the existing ROS setting. The Forest
Plan direction in the Timber Production LUD is to seek to minimize
impacts to recreation planes through scheduling and location of project
activities. When approved activities nearby may result in a change to
the ROS setting, the impacts should be minimized so that a Roaded
Natural or other more natural ROS setting is maintained.
A reereation site is a specifie site and/or facility occurring within a
recreation place. Recreation sites generally refer to specific points like
anchorages or developed faeilities such as recreation cabins and
trailheads.
The selection and identification of recreation places and sites was done
by noting what characteristics or qualities of a site attract and
influence visitor use.
208 • Chapter 3
Kuiu Timber Sale FEIS
3.14.4
Outfitters and
Guides
Recreation
The following discussion describes, by VCU, the recreation use and
attractors in each general area near or in the Project Area. Within these
areas there may be one or more recreation place.
3.14.3.1 Saginaw Bay - VCU 399
There are three recreation places within this VCU: the head of
Saginaw Bay, Halleck Harbor, and the Cool/Ledge Lake area. Saginaw
Bay itself is outside the Project Area, but an LTF on the south side of
the bay (within the Project Area) provides access to the road system.
Most of the activities in this VCU provide Semi-primitive Motorized
experiences.
3.14.3.2 Security Bay - VCU 400
The two recreation places in this area include the head of the bay and
the shoreline around the bay. Recreational use is generally water-
oriented, and secure anchorages exist at numerous points along the
bay’s shoreline. While Security Bay is outside the Project Area, it is
being analyzed because of its proximity to the Project Area.
3.14.3.3 Rowan Bay - VCU 402
The two recreation places in this VCU include the estuary at the head
of Rowan Bay, and the anchorage on the south shoreline. A Log
Transfer Facility (LTF) exists on the north shore of Rowan Bay. An
adjacent dock provides access to the internal road system for boaters
and floatplane passengers. There is also a large area that supported a
major logging camp and sort yard located in the vicinity. Rowan Bay
is outside of the Project Area boundary, but the LTF in Rowan Bay
may be used to transport logs with this project, so it is being analyzed
from a recreation perspective.
3.14.3.4 Kadake Bay - VCU 421
The three recreation places in this VCU include Kadake Bay, a portion
of Kadake Creek, and Gil Harbor. All three are outside the Project
Area boundary, but because of their proximity to the area and their
important recreation values (fishing and black bear hunting), they are
included in this analysis.
Several outfitters and guides do business on Kuiu Island including the
at north end where the Project Area is located. The two main
categories for outfitters and guides are black bear hunting and
sightseeing.
3.14.4.1 Black Bear Hunting
Black bear hunting on North Kuiu Island is an important activity for
outfitters and guides. Since 2004 eight to ten outfitters and guides have
had special use permits for this area. Actual Use Reports show the
number of black bear hunts on northern Kuiu Island ranged from 59-
69 during the 2004-2006 seasons. One hunt constitutes one client who
Kuiu Timber Sale FEIS
Chapter 3 • 209
3 Environment and Effects
spends any amount of time on National Forest land. Eaeh elient pays
$4,000-6,000 per hunt, so the eeonomie benefits of outfitters and
guides using North Kuiu are substantial.
Some outfitters and guides who blaek bear hunt on North Kuiu also
take their elients sightseeing, freshwater fishing and hiking on
National Forest lands.
While the outfitter/guide use for bear guiding on Kuiu remains well
below the amount alloeated in the 1997 Outfitter/Guide EA, that
eapaeity was based on reereation experienee, not on the eapaeity of the
bear population to sustain hunting pressure. Other faetors have limited
the level of guided blaek bear hunting on North Kuiu. A deeision in
2001 by the Alaska State Board of Game limited the annual non-
resident harvest on Kuiu to 120 blaek bears per year. The Forest
Serviee took complementary action by “freezing” the amount of use
authorized in special use permits. No new guides have been authorized
to operate on Kuiu since 2002 and no use increase of authorized guides
from historical levels has occurred.
Black bear populations on Kuiu Island appear to be stable after
ADF&G set harvest limits for nonresident hunters. There is no
evidence that the black bear population on Kuiu Island is over-
harvested at this time. However, the Forest Service and ADF&G agree
that it would be prudent to use a conservative approach in managing
black bear on Kuiu Island, and will cooperatively monitor the island’s
harvest and population of black bear.
In 2000, 17 outfitters and guides held Special Use Pennits to guide for
bear hunting on northern Kuiu Island. The number has decreased since
then to only 8 in the past 3 years (2005-2007). These businesses are
generally based out of boats and their clients hunt the shorelines and
estuaries. Four outfitters and guides have had pennits for the Kuiu
Island road system and use ATVs or vehicles to hunt farther inland.
The number of hunts on the Kuiu road system decreased from 25 in
2004 to 13 in 2005 and to 8 in 2006.
Approximately three percent of successful hunters use vehicles to hunt
black bear on Kuiu Island. This has ranged from 0 to 14 percent since
the 1989 hunting season. Using boats and hunting from the beach are
the most successful means for taking black bear on Kuiu Island (mean
84 percent, range 73 to 91 percent).
Although little is known about black bear populations in Southeast
Alaska, the estimated densities occurring on Kuiu Island seem very
high. Peacock (2004) estimates the population density on north Kuiu
Island to be 1.5 bear/km^, which is one of the highest recorded bear
densities in North America.
210 • Chapter 3
Kuiu Timber Sale FEIS
3.14.5
Environmental
Consequences
Recreation
While numbers vary from year to year, the management objectives set
by Alaska Department of Fish and Game (ADF&G) for black bear
harvest in Game Management Unit 3 (GMU 3), which includes Kuiu
Island, have been met or exceeded. The objectives include an average
18.5 inch skull size of harvested black bear, with males being 75
percent of the harvest. On Kuiu Island the average skull measurement
is 18.6 inches with the harvest being 79 percent male.
3.14.4.2 Sightseeing
Guided sightseeing on north Kuiu Island includes small cruise ships
and tour boats, as well as private boats and yachts. These boats often
visit the unique fossil bluffs and limestone cliff areas in Halleck
Harbor and Saginaw Bay. If the clients go ashore for hiking or fishing
on National Forest Land, the operators are required to get a Special
Use Permit for that use. There are several outfitter/guides that use
Saginaw Bay for those activities.
A few outfitters and guides with special use permits for North Kuiu
rely exclusively on sightseeing, freshwater fishing and hiking for their
clients. Also, two kayak outfitter and guides have used the shoreline of
North Kuiu Island for their trips.
3.14.5.1 Direct and Indirect Effects to the ROS
Very minor changes would occur to the ROS in any of the proposed
alternatives. Less than one percent of the acres would change from a
Semi-primitive Non-motorized setting to a Roaded Modified setting in
Alternatives 3, 4, and 5. No change would occur in Alternatives 1 and
2 (Table 3-74).
Alternatives 1 and 2 would have no effects to existing ROS.
Alternative 3 would change 21 acres from a Semi-primitive Non-
motorized setting to a Roaded Modified setting through the location of
Unit 210. This alternative would not introduce roads or harvest into the
Semi-primitive area, but the location of Unit 2 1 0 would change the
conditions and experiences in this part of the Semi-primitive area.
Alternatives 4 and 5 would change 63 acres of a Semi-primitive Non-
motorized setting to Roaded Modified setting through the location of
Units 210, 21 1, and 212. About a quarter acre of Unit 212 would
actually fall into the existing Semi-primitive area. This overlap and the
proximity of the other units would change the conditions and
experiences in this part of the Semi-primitive area.
3.14.5.2 Direct and Indirect Effects to Outfitters and Guides
None of the alternatives propose timber harvest or road building within
any recreation places. The effects to scenery are described in detail in
the Scenery section. Other effects to the recreation places would be
temporary (lasting during the duration of the logging activity) such as
Kuiu Timber Sale FEIS
Chapter 3*211
3 Environment and Effects
the use of the LTF site at either Rowan Bay or Saginaw Bay which
would affect recreationists in those areas.
During timber harvest, log truck traffic and other traffic associated
with the timber sale would increase and could negatively affect the
few recreationists and the six outfitter/guides that currently use the
road system.
Some currently open roads would be closed after the timber sale is
complete. Alternatives 2 and 3 propose to close 7.8 and 8.0 miles
respectively; Alternatives 4 and 5 propose to close 10.5 miles of
currently open road. For all action alternatives, the longest length of
road proposed for closure is Road 46096 (3.6 miles), which has road
cracks and slumps and minor non-catastrophic failures. This road is
expected to become undrivable in about five years. However, since
current use of the roads is very low, closure of this road and others is
not expected to significantly affect recreationists or the four black bear
hunting outfitters and guides currently permitted to use the Kuiu road
system.
The Catalog of Events for Kuiu Island was referenced in determining
cumulative effects. The area analyzed for cumulative effects includes
the Project Area plus the larger area on north Kuiu Island that has been
heavily harvested in the past. Recreation settings on north Kuiu Island
have changed drastically since timber harvest activities began in the
1960s (Kuiu 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.
Past projects that have enhanced recreation on North Kuiu include the
Kadake cabin, kayak portage trails and the Bay of Pillars shelter.
These projects are not within the Project Area itself, but encourage
people to come to North Kuiu for recreation. The proposed timber
harvest would not affect these recreation opportunities.
The remaining unharvested units in the Crane and Rowan Mountain
Timber Sales EIS could be harvested. Within the Project Area, there
are two units on Road 6425 near Cool and Ledge Lakes, and four units
on Road 6402 east of the head of Security Bay. Outside the Project
Area, but nearby, there are several small units on an extension of Road
46041 north of Rowan Bay. The proposed activities would not
significantly affect existing recreation, since roads and harvest units
already modify the north Kuiu area. The nature of the current
3.14.6
Cumulative
Effects
212 • Chapter 3
Kuiu Timber Sale FEIS
Recreation o
recreation opportunities would remain the same. Outfitter and guides
are concerned about maintaining the recreation experience for their
hunts. The proposed timber harvest would add more harvest units to an
already roaded and harvested area. It would not noticeably change
their experience from the current condition.
One of the major recreation activities on north Kuiu Island is black
bear hunting. The effects of continued logging on black bear are not
well understood. Changes in habitat and road densities may affect
black bear numbers within the areas of activity. Reductions to black
bear populations are not expected from the implementation of any
alternative.
The Petersburg Ranger District has developed the Kuiu Island Road
Analysis, which includes Road Management Objectives (RMOs) for
all the roads on Kuiu Island. These objectives describe the current
condition and proposed future maintenance level for each road. The
long-temi plan for many of these roads is to put them in storage, which
means they would be closed to motorized traffic. Specific dates have
not been determined yet. Many of the roads planned for storage,
however, already exclude motorized traffic because they have grown
closed with alder. Roads in storage would still be accessible by foot.
Closing roads that are currently drivable could affect those
recreationists who drive the roads for hunting. This would include
mostly black bear hunters and outfitter/guides that use the road system.
At this time, there are relatively few hunters who drive the roads, so
the effects would not be significant.
Kuiu Timber Sale FEIS
Chapter 3*213
3.15 Socioeconomics
3.15.1
Introduction
3.15.2
Social and
Economic
Setting
Approximately 70,600 people live in towns, eommunities, and villages
loeated on islands and eoastal lands of Southeast Alaska. Federal lands
eomprise about 95 pereent of Southeast Alaska, 80 pereent within the
Tongass National Forest. Southeast eommunities are within or
adjacent to the Tongass and are largely dependent on the Forest to
provide natural resources for commercial fishing, timber harvest,
recreation, tourism, mining, and subsistence.
River and stream systems on the Tongass contribute to a healthy
salmon fishery for commercial and sport fishing. About one third of
the timber harvested in Southeast Alaska is from the Tongass.
A summary of the community of Kake is provided below, and detailed
information of all local communities can be found in the
Socioeconomics and Subsistence Resource Reports available in the
planning record. For a complete discussion of community descriptions
and the regional economy, please see the Forest Plan EIS, Part 2,
Chapter 3.
3.15.2.1 Kake
Kake is the nearest community to the Project Area and is 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, Point Baker, Port
Protection, and Wrangell. The information gathered for the community
profiles came from the Alaska Department of Commerce Community
and Economic Development web page (ADCCED 2004).
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.
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
214 • Chapter 3
Kuiu Timber Sale FEIS
Socioeconomics
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. Subsistence
is covered in Issue 2 - Deer Habitat and Subsistence Use in this
chapter and in the Subsistence Resource report available in the Kuiu
Timber Sale planning record.
The population in 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 2006 the population was
estimated to be 598, which is a 16 percent decline in six years. 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 pemiits. 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 its 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 1 50 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 U.S. poverty rate and either ( 1 ) or (3) above.
Based on 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
Kuiu Timber Sale FEIS
Chapter 3 • 215
3 Environment and Effects
3.15.3
Effects to
Economic
Activity
employment. Kake is eurrently pursuing tourism ineome and
opporlunities, but has not experienced the increase in tourism that
larger communities in the region have.
3.15.2.2 Other Communities
Point Baker and Port Protection are on the northwest end of Prince of
Wales Island, approximately 40 miles southeast of the Project Area.
According to a 2005 state demographic estimate, Point Baker had a
population of 22 and Port Protection had a population of 54.
Petersburg is situated on the northwest shore of Mitkof Island at the
north end of Wrangell Narrows, approximately 35 miles east of the
Project Area. The 2005 population estimate for Petersburg was 3,155.
Wrangell is on the northern tip of Wrangell Island, approximately 60
miles southeast of the Project Area. The 2005 population estimate was
1,974. The community began as an important Tlingit village primarily
because of its proximity to the Stikine River. Today timber, fishing,
and fish processing dominate Wrangell’s economy and tourism has
been a growing economic sector in recent years.
Meyers Chuck is located on the Cleveland Peninsula approximately 80
miles to the southeast of Kuiu Island. Most of use is by commercial
fishermen and is incidental in nature. The 1995 population was 35, and
by 2005 the population had fallen to 15.
Residents of these communities may use Kuiu for some subsistence
resources. Subsistence is covered in Issue 2 - Deer Habitat and
Subsistence Use in this chapter and in the Subsistence Resource report
available in the Kuiu Timber Sale planning record.
3.15.3.1 Outfitter and Guide Use
See the Recreation section in this chapter.
3.15.3.2 Commercial Fishing
Local economies are largely based on commercial fishing and fish
processing. Fishermen use some of the waters around the Project Area
but are not specifically dependent on this area. Riparian standards and
guidelines. Best Management Practices and estuary and beach fringe
protection were developed and initiated to protect salmon populations,
regardless of the alternative selected. Effects to the fish populations
and anadromous fish habitat would not likely be noticeable. These
effects are discussed in Issue 4- Cumulative Effects on Watersheds and
Essential Fish Habitat sections in this chapter.
3.15.3.3 Tourism, Recreation and Scenery
Tourism is a significant industry that continues to grow throughout
Southeast Alaska and relies on several different resource bases. Some
216 • Chapter 3
Kuiu Timber Sale FEIS
3.15.4
Effects of the
Alternatives
Socioeconomics
tourism activities depend upon the wildness of Alaska in attracting and
engaging visitors to partieipate in outdoor adventures. Other tourism
activities cater to visitors who enjoy the scenery of Alaska while being
provided the comforts associated with development. Currently, the
waters around the Kuiu Timber Sale Area support some tourism
activities in the form of outfitter and guides. Fishing, black bear
hunting, and wildlife viewing are the main activities. The analysis of
changes in recreation is discussed in the Recreation section of this
chapter.
The Project Area is visible from public travel routes and use areas and
the scenery is subject to change as a result of the proposed activities.
See the Scenery section of this chapter for detailed information
regarding seenic impacts.
3.15.4.1 Direct and Indirect Effects
Alternative 1, the No-Action alternative, would maintain the current
level of opportunities for resource use. All action alternatives would
cause changes to the current situation. These changes are described as
increases or decreases in opportunities, benefits, or costs.
Many of the benefits and costs are short-term, lasting only as long as a
proposed timber sale would be active. Wood products employment
assoeiated with the sale, temporary road development, noise, logging
camp use, log transfer facility activity, and increased traffic are
examples of short-term impacts. Landscape changes are effects that
would remain after timber harvest is complete. The time frame of
individual impacts should be considered when evaluating the impacts
of each alternative and when looking at cumulative effects.
3.15.4.2 Cumulative Effects
Most socioeconomic issues are not quantifiable because they rely on
individual perceptions and values. In general, a stable timber industry
would benefit the local economies of Kake, Petersburg and Wrangell
mainly through support businesses like grocery and fuel. The timber
economics resource report estimates the direct and indirect
employment levels likely to result from the action alternatives. The
basic premise is that the higher the volume of timber available and
sold, the more jobs and income would likely result. A sustainable
timber industry would continue to provide economic stimulus.
Tourism and recreation are on the rise across southeast Alaska. Many
seek ecosystem related activities such as fishing, hunting, wildlife
viewing and other outdoor recreation activities. The Project Area and
adjaeent lands continue to be used for tourism related aetivities
(Recreation Resource Report, Appendix B, Figure 1). Continued
timber harvest and related activities impact ecosystems and affect the
potential for wilderness experiences. The no action alternative would
Kuiu Timber Sale FEIS
Chapter 3 • 217
3 Environment and Effects
preserve passive values that inelude habitat preservation for posterity
or loeal use.
Seleetion of any of the alternatives, regardless of the action, would not
likely affect the major economic base, which is commercial fishing.
218 • Chapter 3
Kuiu Timber Sale FEIS
3.16.1
Introduction
3.16.2
Affected
Environment
3.16 Heritage Resources
Heritage resources include an array of historic and prehistoric cultural
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 the Alaska State Historic Preservation Officer
(SHPO), the Advisory Council on Historic Preservation (ACHP),
Federally-recognized Tribal Governments, and other parties with an
interest in the effects of the proposed action on historic properties,
commencing at the early stages of project planning. One of the goals
of consultation is to identify historic properties that potentially may be
affected by the proposed action, assess potential effects and seek ways
to avoid, minimize, or mitigate any adverse effects on historic
properties. The Forest Service consulted with the Organized Village of
Kake, the tribal group that is culturally affiliated with the Project Area.
To ensure that the procedural requirements of 36 CFR 800 were met, a
heritage resource investigation of the project’s Area of Potential Effect
was conducted (Figure 3-12). In accordance with the Programmatic
Agreement (2002) among the Forest Service Alaska Region, the
ACHP, and the SHPO, the resource report was submitted under
modified 36 CFR 800 regulations implementing Section 106 of the
National Historic Preservation Act. The heritage resource survey did
not result in the identification of any new sites, and made a
determination of no historic properties affected. The Organized
Village of Kake, the Petersburg Indian Association, Sealaska
Corporation, and the Tlingit-Haida Central Council were provided
copies of the Forest Service Heritage Resource Report for review and
comment. We received no response regarding our report and
recommendations from any of these groups.
According to oral tradition and various ethnographic accounts, the
Tlingit are the dominant native group of Southeast Alaska. The Project
Area lies within the traditional territory of the Kake Tlingit, who
occupied the northern half of Kuiu Island and the western portion of
Kupreanof Island, with some occupation along the mainland shore of
Frederick Sound as well as parts of Baranof Island and Prince of
Kuiu Timber Sale FEIS
Chapter 3 • 219
3 Environment and Effects
Wales Island. Prehistoric archaeological site types common to the
region hiclude villages, seasonal camps, gardens, rock art sites, and
both wood and stone fish traps and weirs. The earliest known
archaeological site in Southeast Alaska is on Prince of Wales Island,
where investigations suggest people have been living in the region for
close to 10,000 years.
Trapping, fur farming, fishing, timber harvest, mineral exploration,
and homesteading are some of the historic endeavors that have drawn
people to Southeast Alaska and helped shape it into what it is today.
Many of these activities are represented in the archaeological record in
the form of historic period cabins, mines, fur farms, canneries,
salteries, and culturally modified trees (CMTs).
3.16.2.1 Known and Reported Cultural Resources
Previous archaeological investigations have provided insight into some
of the early human activity on Kuiu Island. Many village sites,
prehistoric fish traps and weirs, midden sites, burials, pictographs,
petroglyphs, rock shelters, fort sites, historic trappers’ cabins, CMTs,
and evidence of beach logging illustrate the wide array of cultural
activity that has taken place on Kuiu Island. A review of the Heritage
Program site files and atlases reveals 1 6 sites that were previously
recorded within the Project Area, all of which are on the coastal terrain
of Saginaw Bay or Security Bay and not within the APE. No activities
associated with the proposed action have the potential to impact these
sites.
3.16.3.1 Direct and Indirect Effects
Heritage resource surveys identified no new sites and no known
historic properties would be affected with project implementation.
None of the proposed action alternatives would have a direct or
indirect effect upon known sites in the Project Area and no sites are
located in the APE. All of the nearby archaeological sites and
culturally modified trees are within a protected buffer established
along the beach and estuary fringe defined in the Forest Plan Standards
and Guidelines (Forest Plan p. 4-4). All of the planned timber harvest
units and proposed roads are inland and on relatively steep terrain,
within the low probability zone for cultural resources (Programmatic
Agreement 2002). The use of existing LTFs at Rowan Bay and
Saginaw Bay would not affect any known archaeological sites.
3.16.3
Environmental
Consequences
220 • Chapter 3
Kuiu Timber Sale FEIS
Kuiu Timber Sale
Figure 3-12
Area of Potential Effect for
Heritage Resources
m Area of Potential Effect
V///\ Non-National Forest
Managed Stands
I I Lakes/Saltwater
I I Unit Pool
Project Area Boundary
500ft Contour Interval
Stream Value Class I &
Existing Open Roads
A
0.5 1
3 4
Miles
Heritage
3.16.3.2 Cumulative Effects
Current and past use of the Project Area centers around timber-related
activities, hunting, and recreation. No known historic properties were
affected by past activities that have occurred in the Project Area.
Logging occurs inland while most of the recreation activities take
place along the beach. Some of the existing logging roads allow inland
hunter access as well. Over the years these activities have had little
known effect on historic properties. This trend would likely continue
unless new uses develop. Future expanded use of the beach and
estuary fringe could eventually affect historic properties, but would not
be a result of any of the project alternatives.
Kuiu Timber Sale FEIS
Chapter 3 • 223
3.17 Non-National Forest System Lands
and Uses
Approximately 45,746 acres of the land within the Kuiu Timber Sale
Area are National Forest System land. There are two acres of private
land, seven acres of BLM land, and 347 acres of State of Alaska land
within the Project Area boundary. There would be no effects to other
land owners as a result of this project.
A float house in Saginaw Bay has a special use permit for a waterline.
There is one water line permit issued for water use from National
Forest lands within the Project Area.
224 • Chapter 3
Kuiu Timber Sale FEIS
3.18.1 National
Forest
Management
Act
3.18 Findings and Disciosures
3.18.1.1 Tongass National Forest Land and Resource
Management Plan
All project alternatives fully comply with the Tongass Land and
Resource Management Plan (1997, as amended). This project
incorporates all applicable Forest Plan Forest-wide standards and
guidelines and management area prescriptions as they apply to the
Kuiu Timber Sale Area, and complies with Forest Plan goals and
objectives. All required interagency review and coordination has been
accomplished.
3.18.1.2 RIO Supplement 2400-2002-1
The Kuiu project fully complies with Alaska Region Supplement
2400-2002-1 to Forest Service Manual 2400. This supplement became
effective on May 7, 2002, replacing the Alaska Regional Guide, which
was withdrawn on April 16, 2002. Specifically, the Supplement
provides direction for the management standards and guidelines for:
appropriate harvest cutting methods; forest type standards; maximum
size of created openings (a requirement of the National Forest
Management Act, discussed below); dispersal and size variation of tree
openings; management intensity; utilization standards; sale
administration; project monitoring; and competitive bidding and small
business.
The Forest Plan complies with all resource integration and
management requirements of 36 CFR 219 (219.14 through 219.27).
Application of Forest Plan direction for analysis of the Kuiu Timber
Sale Area ensures compliance at the project level.
3.18.1.3 Even-aged management as the Optimal Method of
Harvesting
The Forest Plan gives guidance on when to use even-aged
management. Clearcutting (an even-aged harvest method) is used in
this project to preclude or minimize mistletoe infestation, yellow-cedar
decline, logging damage, windthrow, or other factors affecting forest
health. Specific information for use of this prescription is shown in the
silvicultural prescriptions, which are filed in the planning record.
Where used, this prescription has been deemed optimal related to site-
specific considerations as described above.
The National Forest Management Act limits the size of even-aged
management harvested openings that may be created based on the
forest type. For the coastal Alaska western hemlock/Sitka spmce forest
type, the maximum created even-aged management opening size
allowed is 100 acres. No proposed even-aged management harvest
Kuiu Timber Sale FEIS
Chapter 3 • 225
3 Environment and Effects
3.18.2
Roads Rule
3.18.3
Endangered
Species Act
3.18.4 Bald
Eagle
Protection Act
units in the Kuiu Timber Sale Area would result in openings greater
than IQO aeres. During layout of the unit, if ehanges are made to the
boundary a ehange analysis must be done. The change analysis
includes mapping and documenting the actual layout and rationale for
those changes. No change that may lead to units with even-aged
opening sizes over 100 acres would be approved.
3.18.2.1 Forest Service Transportation; Final Administrative
Policy
The Tongass National Forest has prepared the Kuiu Timber Sale Final
EIS to be consistent with the Forest Service Transportation; Final
Administrative Policy (Roads Rule).
None of the action alternatives are anticipated to have a direct,
indirect, or cumulative effect on any threatened or endangered species
in the Kuiu Timber Sale Area or elsewhere. The National Marine
Fisheries Service and the U.S. Fish and Wildlife Service have been
consulted. No terrestrial threatened or endangered species are known
to occur within the Kuiu Timber Sale Area. A Biological Evaluation is
included in the planning record.
Management activities are restricted within 330 feet of an eagle nest
site by a Memorandum of Understanding (MOU) between the Forest
Service and the U.S. Fish and Wildlife Service. None of the action
alternatives is anticipated to have a significant direct, indirect, or
cumulative effect on any bald eagle habitat. If the nest at the Rowan
Bay LTF is active or any other nests are found that may be affected,
the MOU and Forest Plan Standards and Guidelines would be
followed.
3.18.5 Tongass
Timber Reform
Act
Harvest units were designed and located to maintain a minimum 1 00-
foot buffer zone for all Class I streams and Class II streams that flow
directly into Class I streams as required in Section 103 of the TTRA.
As discussed in Appendix B, the actual widths of these buffer strips
are often greater than the 100-foot minimum. The design and
implementation direction incorporates Best Management Practices
(BMPs) for the protection of all stream classes. If an action alternative
is selected, the timber from this proposed project would provide part of
the timber supply to the Tongass National Forest’s program to seek to
meet market demand.
3.18.6 National
Historic
Preservation
Act
Heritage resource surveys of various intensities have been conducted
in the Kuiu Timber Sale Area, following inventory protocols approved
by the Alaska State Historic Preservation Officer. These surveys
include background and existing literature searches and fieldwork
complete with subsurface testing. Native communities have been
contacted, and public comment encouraged. During analysis for this
project, the Organized Village of Kake, the tribal group culturally
226 • Chapter 3
Kuiu Timber Sale FEIS
3.18.7 Federal
Cave
Resource
Protection Act
of 1988
3.18.8 Alaska
National
Interest Lands
Conservation
Act (ANILCA)
3.18.9
Magnuson-
Stevens
Fishery
Conservation
Act of 1996
Findings and Disclosures
affiliated with the Project Area, was consulted regarding known or
suspected heritage resources in or near the Project Area. The State
Historic Preservation Officer has been consulted.
Forest Plan Karst and Caves Standards and Guidelines are applied to
areas known or suspected to contain karst resources. Within the
Project Area there are 6,624 acres of carbonate bedrock. No proposed
timber harvest, road construction, or quarry development would occur
on these areas or along the drainages which flow to them. Therefore,
the action alternatives are not expected to affect any significant karst
resources.
A subsistence evaluation was conducted for the alternatives considered
in detail, in accordance with ANILCA Section 810. The evaluations in
the Subsistence section of this chapter on abundance and/or
distribution, access and competition for harvested resources in the
Kuiu Timber Sale Area, indicate that there would not be a significant
possibility of a significant restriction to the customary and traditional
subsistence uses of wildlife, fish and shellfish, marine mammals, other
foods, or timber resources as a result of this project. However, the
Forest Plan addressed the long-term consequences on subsistence and
concluded that there may be a significant possibility of a significant
restriction to subsistence use of deer in the future due to the combined
potential effects of projects implementing the Forest Plan and the
predicted human population growth on the abundance and distribution
of deer and on competition for deer. Subsistence hearings were held
during the 45-day public comment period for the EIS. The first hearing
was in Petersburg on March 16, 2006, in which three people testified,
and the second hearing was in Kake on March 2 1 , 2006 in which one
person testified. The hearing testimonies are in the planning record.
The Magnuson-Stevens Fishery Conservation Act (1996) requires that
all federal agencies consult with NMFS when any project “may
adversely affecf’ essential fish habitat. The Forest Service’s position is
that harvesting timber near Class I streams and wetlands, and the use
of the Rowan Bay or Saginaw Bay LTFs may have an adverse affect
on Essential Fish Habitat. However, by following the standards and
guidelines in the Forest Plan and implementing the Best Management
Practices (BMPs), the effects on EFH would be minimized.
According to the agreement between the National Marine Fisheries
Service and the USDA Forest Service dated August 25, 2000, this
Final EIS includes the following:
• A description of the proposed action
• An analysis of individual and cumulative effects of the proposed
action on the essential fish habitat, the managed species, and
Kuiu Timber Sale FEIS
Chapter 3 • 227
3 Environment and Effects
associated species such as major prey species, including affected
lifejiistories
• The Forest Service’s views regarding effects on essential fish
habitat
• A discussion of proposed mitigation, if applicable
A copy of the Draft EIS, which included the above assessment, was
sent to the National Marine Fisheries Service for review. NMFS
reviewed the Draft EIS and concurred in a letter dated March 20, 2006
with the Forest Service’s detemiination that “the Kuiu Timber Sale
may adversely affect Essential Fish Habitaf’ with conservation
recommendations (see the NMFS comment letter and the Forest
Service response in Appendix C).
3.18.10 CiGan Congress intended the Clean Water Act of 1972 (Public Law 92-500)
WatGP Act amended in 1977 (Public Law 95-217) and 1987 (Public Law 100-
4) to protect and improve the quality of water resources and maintain
their beneficial uses. Section 313 of the Clean Water Act and
Executive Order 12088 of January 23, 1987 address Federal agency
compliance and consistency with water pollution control mandates.
Agencies must be consistent with requirements that apply to "any
governmental entity” or private person. Compliance is to be in line
with “all Federal, State, interstate, and local requirements,
administrative authority, and process and sanctions respecting the
control and abatement of water pollution.”
The Clean Water Act (Sections 208 and 319) recognized the need for
control strategies for nonpoint source pollution. The National
Nonpoint Source Policy (December 12, 1984), the Forest Service
Nonpoint Strategy (January 29, 1985), and the USDA Nonpoint
Source Water Quality Policy (December 5, 1986) provide a protection
and improvement emphasis for soil and water resources and water-
related beneficial uses. Soil and water conservation practices (BMPs)
were recognized as the primary control mechanisms for nonpoint
source pollution on National Forest System lands. The Environmental
Protection Agency supports this perspective in their guidance,
"Nonpoint Source Controls and Water Quality Standards" (August 19,
1987).
The Forest Service must apply Best Management Practices that are
consistent with the Alaska Forest Resources and Practices Regulations
to achieve Alaska Water Quality Standards. The site-specific
application of BMPs, with a monitoring and feedback mechanism, is
the approved strategy for controlling nonpoint source pollution as
defined by Alaska’s Nonpoint Source Pollution Control Strategy
(October 2000). In 1997, the State approved the BMPs in the Forest
Service’s Soil and Water Conservation Handbook (FSH 2509.22,
228 • Chapter 3
Kuiu Timber Sale FEIS
Findings and Disclosures
October 1996) as consistent with the Alaska Forest Resources and
Practices Regulations. This Handbook is incorporated into the Tongass
Land and Resource Management Plan.
A discharge of dredge or fill material from normal silviculture
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 to assure that flow and
circulation patterns and chemical and biological characteristics of the
waters are not impaired (404)(f)(l)(E). The BMPs that must be
followed are specified in 33 CFR 323.4(a). These specific BMPs have
been incorporated into the Forest Service’s Soil and Water
Conservation Handbook under BMP 12.5.
The design of harvest units and proposed roads for this project are in
accordance with standards and guidelines, and direction contained in
the Forest Plan, Best Management Practices and applicable Forest
Service manual and handbook direction. The Unit Cards in Appendix
B contain specific practices prescribed to prevent or reduce non-point
sediment sources. Monitoring and evaluation of the implementation
and effectiveness of Forest Plan standards and guidelines and Best
Management Practices would occur. Project activities are expected to
meet all applicable State Water Quality Standards.
All roads, landings, and roek pits for this project would be constructed
in accordance with Best Management Practices listed in 33 CFR
323.4(a). Site specific BMPs are listed on the Unit Cards in Appendix
B. All roads, landings and rock pits would be designed to minimum
standards to aecommodate timber harvesting and silvicultural
activities.
3.18.11
Clean Air Act
3.18.12
Coastal Zone
Management
Act and the
Alaska Coastal
Zone
Management
Program
(ACMP)
Emissions expected from implementation of any of the action
alternatives would be of short duration and are not expected to exceed
State of Alaska Ambient Air Quality Standards (Alaska Administrative
Code, Title 18, Chapter 50).
The Coastal Zone Management Act of 1972 (CZMA), while
specifically excluding federal lands from the coastal zone, requires that
a federal agency’s activities be consistent with the enforceable
standards of a state’s coastal management program to the maximum
extent feasible when the agency’s activities affect the coastal zone.
The State of Alaska developed the Alaska Coastal Management Plan
(ACMP) in 1977 to evaluate any projects within the coastal zone.
The enforceable standards for timber harvest activities are found in the
Alaska Forest Resource and Practices Act of 1993. The standards and
guidelines for timber management activities in the Kuiu Timber Sale
Kuiu Timber Sale FEIS
Chapter 3 • 229
3 Environment
3.18.13
Alaska Forest
Resources and
Practices Act
3.18.14
Executive
Order 11593
and Effects
Area meet or exceed the standards in the State Forest Resources and
Practices Act.
A Memorandum of Understanding specifies ACMP review procedures
between the Forest Service and the State of Alaska. The State agencies
involved are the Department of Fish and Game, the Department of
Natural Resources, and the Department of Environmental
Conservation. This memorandum serves to describe the process and
expedite the review of whether a proposed project is consistent with
the Alaska Coastal Management Program.
The Forest Service developed the Proposed Action and alternatives to
the Proposed Action to be consistent, to the maximum extent feasible,
with the enforceable policies of approved State management programs.
The Forest Service has detennined that all the alternatives for the Kuiu
Timber Sale Area are consistent, to the maximum extent feasible, with
the Alaska Coastal Management Program, as outlined in the
Memorandum of Understanding.
The fonnal ACMP consistency review process for this project was
initiated upon publication of the Draft EIS. The Alaska Department of
Natural Resources Office of Project Management and Permitting
coordinated a review of the Draft EIS and responded with a letter
dated April 26, 2006 in which they concurred with the determination
submitted by the Forest Service that “the project is consistent with
ACMP and affected coastal district’s enforceable policies, to the
maximum extent practicable. (See the NMFS comment letter and the
Forest Service response in Appendix C).
The Alaska Forest Resources and Practices Act (1993) affects National
Forest management through its relationship to the ACMP and the
CZMA.
This Act is the standard used for evaluating timber harvest activities
on federal lands for purposes of detemiining consistency to the
maximum extent practicable with the ACMP. The Act recognizes that
consistency is attainable for timber harvest on federal land using
procedures different from those required by the Act or its
implementing regulations.
Executive Order 11593 directs federal agencies to provide leadership
in preserving, restoring and maintaining the historic and cultural
environment of the Nation. The work accomplished in accordance with
Section 1 06 of the National Historic Preservation Act for the Kuiu
Timber Sale Area meets the intent of this Executive Order.
The Heritage Resource Report in the planning record discusses the
cultural environment of the area and addresses the Forest Service’s
responsibilities according to historic preservation laws and regulations.
230 • Chapter 3
Kuiu Timber Sale FEIS
3.18.15
Executive
Order 11988
3.18.16
Executive
Order 11990
Findings and Disclosures
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.
Our analysis shows that native populations are not likely to be
disproportionately impacted under any alternative.
Executive Order 11988 directs federal agencies to take action to avoid,
to the extent possible, the long and short-term adverse impacts
associated with the occupancy and modification of floodplains. A
floodplain is defined as the lowland and relatively flat areas adjoining
inland and coastal waters including flood prone areas of offshore
islands, including at a minimum that area subject to a one percent or
greater chance of flooding in any given year.
Forest Plan standards and guidelines for riparian areas exclude most
commercial timber harvesting from floodplains. Roads may be
constructed in or through floodplains subject to the design
requirements of Best Management Practices. Effects on floodplains
from project activities have been avoided or minimized as much as
possible.
Executive Order 1 1 990 requires federal agencies to avoid, to the extent
possible, the long-term and short-term adverse impacts associated with
the destruction or modification of wetlands.
This project avoids impacting wetlands whenever practicable, but it is
not feasible to avoid all wetland areas. Effects would be minimized by
avoiding the use of wetlands as sites for overburden disposal, avoiding
temporary road construction through wetlands whenever practicable,
and by decommissioning new temporary roads after timber harvest.
Implementation of BMPs, minimizing ditching, and providing
adequate cross drainage would also help minimize the amount of
wetlands affected.
In certain instances, crossing a wetland area can reduce the overall
environmental impacts of a particular road because it facilitates
avoidance of steep slopes and alignment of roads perpendicular to
stream crossings. The Kuiu Timber Sale Area action alternatives
propose up to 2.8 miles of temporary road construction across
wetlands.
To reduce any road impacts to the hydrology at these sites, frequent
road cross-drains would be constructed. To avoid artificial interception
of water by roads, free-draining, coarse-textured rock would be used in
road foundations, and installation of an adequate size and number of
culverts would be required. Drainage structures would be removed on
all temporary roads.
Kuiu Timber Sale FEIS
Chapter 3 • 231
3 Environment and Effects
3.18.17
Executive
Order 12898
3.18.18
Executive
Order 12962
As required by law Executive Order 12898, all federal actions consider
potentially disproportionate effects on minority or low-income
communities. Where possible, measures should be taken to avoid
impact to these communities or mitigate the adverse effects. Potential
impacts or changes to low-income or minority communities in the
Project Area, due to the proposed action, were considered.
Kake, though not within the Project Area, is nearby, and its residents
have a long history of using the Project Area. Kake’s population is
about 75 percent Native and has been considered in the analysis of the
proposed alternatives for disproportionate impacts. Several public
meetings were held in Kake to assist people in understanding the
alternatives and how issues were addressed. Some of the concerns
voiced were that the declining economy of Kake has increased the
community’s reliance on subsistence and they are concerned that the
Kuiu Timber Sale may reduce the availability of deer and salmon on
and around Kuiu Island. The proposed project would not worsen the
economy nor would it reduce the availability of subsistence deer or
salmon (see the Issue 2 - Deer Habitat and Subsistence Use section in
this chapter).
Implementation of the action alternatives for the Kuiu Timber Sale
Area would not cause adverse health, social, or environmental effects
that disproportionately impact minority and low-income populations.
See also the ANILCA Section 810 findings.
Executive Order 12962 directs Federal agencies to conserve, restore,
and enhance aquatic systems to provide for increased recreational
fishing opportunities nationwide. Section 1 of the Executive Order is
most pertinent to the Kuiu Timber Sale Area. Section 1 directs Federal
agencies to evaluate effects on aquatic ecosystems and recreational
fisheries, develop and encourage partnerships, promote restoration,
provide access, and promote awareness of opportunities for
recreational fishery resources.
The effects of this project on freshwater and marine resources were
evaluated during the analysis. With the application of Forest Plan
standards and guidelines, including those for riparian areas, no
significant adverse effects to freshwater or marine resources are
expected to occur.
Partnerships continue to be used to leverage federal project funds to
address water quality concerns in areas of the Tongass National Forest,
although none have been proposed for recreational fisheries in
conjunction with this project.
232 • Chapter 3
Kuiu Timber Sale FEIS
3.18.19
Executive
Order 13007
3.18.20
Executive
Order 13186
Findings and Disclosures
Executive Order 13007 directs federal agencies to accommodate
access to and ceremonial use of American Indian sacred sites by
Indian religious practitioners and to avoid adversely affecting the
physical integrity of such sacred sites. There are no known sacred
Indian sites in the Kuiu Timber Sale Area. Consultation with local
federally recognized tribes, including the Organized Village of Kake,
Petersburg Indian Association, Tlingit/Haida Central Council, and
Sealaska Corporation occurred during the analysis of this project.
Executive Order 13186 directs federal agencies to evaluate the effects
of actions and agency plans on migratory birds, with emphasis on
species of concern. The sections on Wildlife and Threatened and
Endangered Species in this chapter provide information on anticipated
effects to selected bird species in the Project Area. None of the
proposed activities are expected to have a measurable negative effect
on migratory bird populations, although individuals or small groups
and their nests may be affected.
Kuiu Timber Sale FEIS
Chapter 3 • 233
3
Environment and Effects
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234 • Chapter 3
Chapter 4
References and
Lists
Chapter 4
Table of Contents
Chapter 4 1
References and Lists 1
Glossary 1
References 19
List of Preparers 26
List of FEIS Recipients 28
List of FEIS Notification Letter Recipients 32
Index for Chapter 1 34
Index for Chapter 2 36
Index for Chapter 3 38
Glossary
Adfluvial fish
Species or populations of fish that do not go to sea, but live in lakes, and enter
streams to spawn.
Adopted VQO
The VQO to be achieved as a result of management direction identified in the
approved Forest Plan. Adopted VQOs represent the visual resource objective for the
planning period, normally 10 years. (FSH 2309.22, R-10 Landscape Management
Handbook.)
Alaska Heritage Resource Survey (AHRS)
The official list of cultural resources in the State of Alaska, maintained by the Office
of History and Archaeology, Alaska Division of Parks and Outdoor Recreation.
Alaska National Interest Lands Conservation Act (ANILCA)
The Alaska National Interest Lands Conservation Act of December 2, 1980. Public
Law 96-487, 96th Congress, 94 Stat. 2371-2551. Passed by Congress in 1980, this
legislation designated 14 National Forest wilderness areas in Southeast Alaska.
Section 810 requires evaluations of subsistence impacts before changing the use of
these lands.
All-terrain Vehicle (ATV)
A motorized four-wheeled vehicle less than 40 inches wide that is restricted by law
from operating on public roads for general motor vehicle traffic.
Allowable Sale Quantity (ASQ)
The maximum quantity of timber that may be sold each decade from suitable lands on
the Tongass National Forest as identified from the Forest Plan. A ceiling, not a
requirement.
Alluvial Fan
A fan-shaped landform comprised of alluvium deposited at the mouth of a steep
valley, canyon, or ravine.
Alluvium
Mineral material such as boulders, cobbles, gravel, sand, silt and clay transported or
deposited by flowing water.
Alpine/subalpine habitat
Terrain located at elevations too high to support tree growth, such as on mountain
peaks or ridges, generally above 1,500 feet in elevation in southeast Alaska.
Anadromous Fish
Fish (such as salmon and steelhead) that spend part of their lives in fresh water and
part of their lives in salt water. Anadromous fish ascend from the sea to spawn in
freshwater streams.
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4 References and Lists
Aquifer
A unit of rock or gravel that stores and transmits enough water to be
hydrologically significant.
Background
The distant part of a viewed landscape, located from three or five miles to
infinity from the viewer.
Bark lechates
Soluble organic compounds released into water from bark. Lechates cause the
water to have a yellow to brown color.
Basal Area
Total cross-sectional area of a tree or a stand of trees. This is measured at
breast height and can be expressed in either square feet per acre or square
meters per hectare.
Beach Fringe
The area, typically forested, that is inland from saltwater shorelines.
Best Management Practices (BMPs)
Practices specified in the Soil and Water Conservation Handbook (FSH
2509.22), and used during the planning, design, and implementation of timber
sale projeets, for the protection of water quality from non-point source
pollution in accordanee with the Clean Water Act.
Biogeographic Provinces
Twenty-one ecologieal subdivisions of Southeast Alaska that are identified by
generally distinct ecological, physiogeographic, and biogeographic features.
Plant and animal species composition, climate, and geology within eaeh
provinee are generally more similar within than among adjacent provinees.
Historical events (sueh as glaciers and uplifting) are important to the nature of
the province and to the barriers that distinguish eaeh province.
Biodiversity
The variability among living organisms, including the variability within and
between speeies, and within and between eeosystems.
Biological Assessment
A “biological evaluation” conducted for major Federal construction projects
requiring an environmental impact statement, in accordance with legal
requirements under section 7 of the Endangered Species Act (16 U.S.C.
1536(c)). The purpose of the assessment and resulting document is to
determine whether the proposed action is likely to affect a species that has
been listed or proposed as an endangered or threatened species.
Biological Evaluation
A documented Forest Serviee review of Forest Service programs or activities
in sufficient detail to determine how an action or proposed action may affect
any species that has been listed or proposed as threatened, endangered, or
sensitive.
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Biological Opinion
An official report by the Fish and Wildlife Serviee (FWS) or the National Marine
Fisheries Service (NMFS) issued in response to a formal Forest Service request for
consultation or conference. It states whether an action is likely to result in jeopardy
to a speeies or adverse modification of its critical habitat.
Board foot
A unit of timber measurement equaling the amount of wood contained in an
unfinished board one inch thick, 12 inches long, and 12 inches wide.
Buffer
An area of undisturbed or lightly disturbed forest reserved to isolate activity areas
from sensitive areas.
Carrying Capacity
The estimated maximum number of individuals within a wildlife species that ean be
sustained over the long-term within a specified area. Carrying capacity is often used
interchangeably with the term habitat capability.
Channel Type
A means of defining stream sections based on landform relief, geology, and channel
eharaeteristies such as width, gradient, and ineision. For descriptions, see “Channel
Type Field Guide,” Forest Serviee publieation RlO-MB-6.
Clearcut
Harvesting method in which all trees are cleared in one cut. It prepares the area for a
new, even-aged stand. The area harvested may be a patch, strip, or stand large
enough to be mapped or recorded as a separate age elass in planning.
Climax Plant Community
An assemblage of plants and that is relatively stable over time and which represents
the late stages of succession under the current elimate and soil eonditions.
Closed Roads
Roads that have been placed in Maintenance Level 1 and are not open to motorized
vehieles, although they may be aceessible to non-motorized users. Road drainage
struetures may or may not be removed.
Coarse Canopy Old-growth forest
Old-growth forest that has lower crown density (number of trees) and non-uniform
crown sizes and heights, ineluding large crowns and many canopy gaps. Coarse
canopies are usually found on aspects where the forest is proteeted from winds that
result in catastrophie blowdown events.
Colluvium
Mineral material that is weathered in place or transported as a result of gravity.
Connectivity
A measure of the extent that forest areas between or outside habitat reserves provide
wildlife habitat for breeding, feeding, dispersal, and movement.
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4 References and Lists
Cubic Foot
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 measure of wood volume
than board foot.
Culturally Modified Tree (CMT)
Trees that have been altered by human use, usually for the exploitation of bark
and wood products.
Cumulative Effects
The impacts on the environment resulting from the addition of the 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.
Decommissioning
Activities that result in the stabilization and restoration of unneeded roads to a
more natural state (36 CFR 212.1), (FSM 7703).
Deer Winter Habitat
Locations that provide food and shelter for Sitka Black-tailed deer under
moderately severe to severe winter conditions. Usually associated with high
volume old-growth stands at low elevation and with south aspects.
Designated Road
A National Forest System road, a National Forest System trail, or an area on
National Forest System lands that is designated for motor vehicle use pursuant
to CFR 212.51 on a motor vehicle use map (36 CFR 212.1).
Desired Future Condition
A statement of the ultimate goal for resources and uses of an area.
Developed Recreation
Recreation that requires facilities that, in turn, result in concentrated use of an
area, such as campgrounds and picnic areas. Facilities in these areas might
include roads, parking lots, picnic tables, toilets, drinking water, and
buildings. See also Dispersed Recreation.
Diameter at Breast Height (DBH)
The diameter of a standing tree at a point four feet, six inches from ground
level.
Direct Employment
The jobs that are immediately associated with a given activity.
Dispersed Recreation
Recreational activities that are not confined to a specific place and are
generally outside developed recreation sites. This includes activities such as
scenic driving, hiking, backpacking, hunting, fishing, snowmobiling, cross-
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country skiing, and recreation in primitive environments. See also Developed
Recreation.
Distance Zones
Areas of landscapes visible from priority travel routes and use areas categorized by
distance criteria. (Foreground: 0 to 'A- 'A mile, Middleground: 14 - 14 to 3-5 miles,
or Background; greater than 3-5 miles). Used as a frame of reference in which to
discuss landscape characteristics and management activities.
Ecological Subsections
Eighty-five terrestrial ecosystems mapped and described for Southeast Alaska and
adjoining areas of Canada in Nowacki et al. 2001 . These mid-sized terrestrial
ecosystems (10-1,000 mP) embody similar ecologieal eharacteristics (e.g.,
landforms, streams, vegetation, soils, and wetlands) and provide a practical basis for
ecosystem management, planning, and research.
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 are identified by the
Secretary of the Interior as endangered in accordance with the 1973 Endangered
Species Act.
Endemic
Peculiar to a particular locality; indigenous.
Estuary
A landform characterized by the presence of, and the mixing of fresh water and salt
water at the mouth of a stream, and where salt marshes and intertidal mudflats are
present. The landward extent of an estuary is the limit of salt-intolerant vegetation,
and the seaward extent is a stream’s delta at mean low water.
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 the age of the stand at harvest rotation age. Clearcut, shelterwood, or
seed tree cutting methods produce even-aged stands.
Fluvial
Of, or pertaining to, streams and rivers.
Forbs
A category of herbaceous plants that are not included in the grass, shrub or tree
categories; generally smaller flowering plants.
Foreground
A term used to describe the area immediately adjacent to a viewer, typically located
less than % mile in distance.
Forest Land
Land at least 10 percent occupied by forest trees of any size or formerly having had
sueh tree cover and not currently developed for non-forest use.
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4 References and Lists
Forest Plan
Source of management direction for an individual Forest specifying activity
and output levels for a period of 10-15 years. Management direction in the
plan is based on 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 detennines is necessary for the
protection, administration, and utilization of the National Forest System and
the use and development of its resources.
Forest-wide Standards and Guidelines
A set of rules and guidance that directs management activities and establishes
the environmental quality, natural renewable and depletable resource
requirements, conservation potential, and mitigation measures that apply to
several land use designations.
Gap Phase Dynamics
The processes by which the death of one or a few overstory trees acts like a
small minor disturbance and pemiits a small, single-even-aged stand to grow
from existing vegetation or seed germination.
Geographic Infonnation System (GIS)
A computerized map database that is used to store and evaluate site-specific
infonnation.
Habitat
The sum total of environmental conditions of a specific place that is occupied
by an organism, population, or community of plants or animals.
Habitat Capability
Estimated maximum number of fish or wildlife that can be supported by the
amount and distribution of suitable habitat in an area. Habitat capability is
often used interchangeably with the term carrying capacity.
Habitat Suitability Index (HSI)
A measure of the capability of the habitat to support specific wildlife, based
on a variety of environmental factors such as slope, elevation, aspect, and
forest type.
Heritage Resources
The prehistoric or historic district, site, building, structure, or object included
in, or eligible for inclusion in, the National Register of Historic Places. The
term includes artifacts, records, and remains that are related to and located
within such properties.
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High Hazard Soil
Soil that is prone to mass movement. Soil type, geologie bedding, and slope angle
are factors considered when establishing which sites are high hazard.
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.
Hydrologic Recovery
A return to natural conditions of water collection, storage, and discharge.
Indirect Employment
The jobs in service industries that are associated with or support a given activity.
Interdisciplinary Team (IDT)
A group of individuals with different training assembled to solve a problem or
perfonn a task. The team is assembled out of recognition that no one scientific
discipline is sufficiently broad to adequately solve the problem. Through
interaction, participants bring different points of view and a broader range of
expertise to bear on the problem or task.
Intermediate Stand Treatment
A stand management treatment that manipulates stand growth, composition,
structure, or tree quality. Intermediate treatments include thinning, pruning, release,
salvage, and sanitation cutting. These stand treatments do not attempt to obtain new
tree regeneration. Some treatments such as salvage cutting or commercial thinning
result in the harvest of forest products.
Inventoried Roadless Areas
National Forest System lands identified as 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. These areas are identified by the Roadless Conservation Area Rule.
Irretrievable Commitments
Eoss of production or use of renewable natural resources for a period of time. The
production or use lost is irretrievable, but not irreversible.
Irreversible Commitments
Decisions causing changes that cannot be reversed. Often applies to nonrenewable
resources such as minerals and cultural resources.
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.
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4 References and Lists
Land Use Designation (LUD)
A defined area of land, identified by the Forest Plan, to which specific
management direction is applied.
Large Woody Debris (LWD)
Any large piece of relatively stable woody material having a least diameter of
greater than 10 centimeters and length greater than one meter than intrudes
into the stream channel.
Log Transfer Facility (LTF)
The site and structures which are used for moving logs and timber products
from land-based transportation forms to water-based transportation fonns.
Low-productive Forest Land
Forested land that does not support enough timber volume to meet the criteria
for productive forest land.
Management Indicator Species (MIS)
Vertebrate or invertebrate wildlife species whose response to land
management activities can be used to predict the likely response of other
species with similar habitat requirements. The National Forest Management
Act regulations prescribe the use of management indicator species.
Mass Movement
General term for a variety of processes by which large masses of soil and
rock material are moved down slope by gravity either slowly or quickly.
Mass movement is often used interchangeably with the term landslide.
Mass Movement Index (MMI)
Rating used to group soil map units that have similar properties with respect
to the stability of natural slopes.
Middleground
The visible terrain beyond the foreground where individual trees are still
visible but do not stand out distinctly from the landscape. The area is located
from % mile to 3-5 miles from the viewer.
Mitigation
Measure designed to counteract or reduce environmental impacts. These
measures 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.
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 confinn whether mitigation measures were carried out in
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the matter called for (Implementation Monitoring); to confirm whether mitigation
measures were effective (Effectiveness Monitoring); or, to validate whether overall
goals and objectives were appropriate (Validation Monitoring).
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
A bog, often dominated by sphagnum moss, frequently with deep accumulations of
organic material, occurring in wet, poorly drained northern regions. Peatland.
National Environmental Policy Act of 1969 (NEPA)
An act declaring it a national policy to encourage productive harmony between
humans and their environment and to promote efforts to better understand and
prevent damage to ecological systems and natural resources important to the nation.
Requires agencies to prepare detailed environmental impact statements for any
major federal action significantly affecting the environment.
National Forest Management Act (NFMA)
A law passed in 1976 that amends the Forest and Rangeland Renewable Resources
Planning Act, requires the preparation of Forest plans, requires the identification of
management indicator species, and defines parameters for timber suitability.
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, county, or local public road authority (36 CFR 212.1).
National Register of Historic Places
A register of historic properties of national, state, or local significance, maintained
by the Department of the Interior.
Non-interchangeable Component (NIC)
Non-interchangeable components (NICs) are defined as increments of the suitable
land base and their contribution to the allowable sale quantity (ASQ) that are
established to meet Forest plan objectives. NICs are identified as parcels of land
and the type of timber thereon which are differentiated for the purpose of Forest
plan implementation. The total ASQ is derived from the sum of the timber volumes
from all NICs. The NICs cannot be substituted for each other in the timber sale
program.
Old-growth Forest
Ecosystems distinguished by the later stages of forest stand development that differ
significantly from younger forests in structure, ecological function, and species
composition. Old-growth forests are characterized by a patchy, multi-layered
canopy; trees that represent many age classes; large trees that dominate the
overstory; large standing dead (snags) or decadent trees; and higher accumulations
Kuiu Timber Sale FEIS
Chapter 4*9
4 References and Lists
of large down woody material. The structure and function of an old-growth
ecosystem will be intluenced by its stand size and landscape position and
context.
Old-growth Habitat Reserve
A contiguous unit of old-growth forest habitat to be managed to maintain the
integrity of the old-growth forest ecosystem.
Interior Old-growth
Old-growth habitat (high, medium, and low volume strata) excluding a
distance or buffer of two to three tree lengths (an average of 300 feet) around
its inside perimeter.
Open Road Density
The length of NFS roads open for public access and use per unit area of land;
usually expressed as miles of open road per square mile of land.
Overstory
The portion of trees in a forest that forms the uppermost layer of foliage.
Canopy.
Palustrine
Non-tidal wetlands dominated by trees, shrubs, persistent emergents,
emergent mosses or lichens, and all such wetlands that occur in tidal areas
where salinity is below 0.50 percent.
Plant Association
Climax forest plant community type representing the endpoint of succession.
Pole Timber
An immature tree between 5 and 9 inches diameter breast height.
Polychaetes
A class of worms.
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.
Practicable
In reference to the Alaska Coastal Management Program, consistent with
enforceable policies of approved management programs unless compliance is
prohibited based upon the requirements of existing law applicable to the
Federal agency’s operations.
Process Group
A combination of similar stream channel types based on major differences in
landform, gradient, and channel geometry.
Productive Forest Land
Forest land that is capable of producing at least 20 cubic feet of annual tree
growth per acre or contains at least 8,000 board feet of net timber volume per
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acre. This includes second-growth stands that have regenerated with conifer
species after natural or human disturbance.
Productive Old-growth
Old-growth stands capable of producing 20 cubic feet per acre per year with 8,000
or more board feet of timber per acre.
Programmed Commercial Timber Harvest
Timber harvest that occurs on suitable forested lands that contributes to the Tongass
National Forest Allowable Sale Quantity.
Recreation Opportunity Spectrum (ROS)
A system for planning and managing resources that categorizes recreation
opportunities into seven 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 area and the relative density of
recreation use.
Recreation Places
Identified geographical areas having one or more physical characteristics that are
particularly attractive to people in recreation activities. They may be beaches,
streamsides or roadside areas, trail corridors, hunting areas or the immediate area
surrounding a lake, cabin site, or campground.
Recreation Sites
A specific site and/or facility occurring within a Recreation Place. Some examples
of Recreation Sites are: recreation cabins, Railheads, picnic areas, and wildlife
viewing blinds.
Redd
A nest made in gravel, consisting of a depression hydraulically dug by a fish for egg
deposition and then refilled with gravel.
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 fresh water on a pennanent basis.
Resident fish include cutthroat trout and Dolly Varden char.
Riparian Management Area
The area including land, water, and plants in and adjacent to streams and lakes that
is managed according to specific standards and guidelines prescribed for each
stream process group.
Road
A motor vehicle route over 50 inches wide, unless identified and managed as a
trail.(36CFR 212.1)
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4 References and Lists
Road Construction
Supervising, inspecting, actual building, and incurrence of all costs
incidental to the construetion of a road. (36 CFR 212.1)
Road Decommissioning
Activities that result in restoration of unneeded roads to a more natural state.
These roads are not part of the National Forest System Roads. (36 CFR
212.1)
Road Maintenance
Ongoing upkeep of a road necessary to maintain or restore the road in
accordance with its road management objectives. (FSM 7714)
Road Reconditioning
Heavier maintenance of an existing road such as culvert replacement,
surface rock replacement, and subgrade repair. Renovation or restoration of
an existing fixed asset or any of its components in order to restore the
functionality or life of the asset. Reeonditioning involves no signifieant
expansion or ehange of purpose for the fixed asset. (Finaneial Health -
Common Definitions for Maintenance and Construction Terms, July 22,
1998)
Road Management Objective (RMO)
Defines the intended purpose of an individual road based on Management
Area direction and access management objectives. Road management
objectives contain design eriteria, operation eriteria and maintenance
eriteria. Long-term and short-term roads have RMOs.
Rotation
The planned number of years between the time that a forest stand is
regenerated and its next cutting at a specified stage of maturity.
Sawtimber
Trees that are suitable in size and quality for the production of dimensional
lumber.
Scoping Process
Early and open activities used to determine the scope and significance of a
proposed aetion, 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 aetion and the range of actions, alternatives,
and impacts to be considered in an EA or EIS.
Second Growth
Forest growth that has come up naturally or has been planted after
disturbance (for example, harvest, serious fire, or insect attack).
Seen Landscape
Those areas visible from the most frequently used travelways (boat route,
reereation road, or trail) or use area (recreation eabin or anchorage).
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Seldom-seen, or Not-seen, Landscape
Those areas not visible from the most frequently used travelways (boat route,
reereation road, or trail) or use area (reereation cabin or anchorage).
Sensitive Species
Animal and plant species identified by the Regional Forester as potentially
susceptible or vulnerable to activity impacts or habitat alterations and, therefore, in
need of special considerations during land management activity planning.
Shell Midden
A term referring to shell and bone that have been discarded after harvest and
processing for subsistence use.
Side-slope Break
The abrupt change (usually decreases) in slope gradient defining the upper limit of
stream channel incision.
Silviculture
The theory and practice of managing forest vegetation. Silviculture involves the
appropriate application of ecological, social, and economic principles of vegetative
management to achieve resource management objectives and desired future forest
conditions.
Silvicultural Prescription
Detailed direction about methods, techniques, timing, and monitoring of vegetative
treatments. A prescription is prepared by a silviculturist who uses interdisciplinary
input to best achieve established objectives, direction, and requirements for land
managed by the Forest Service.
Silvicultural System
A management process whereby forests are tended, harvested, and replaced
resulting in a forest of distinctive form. Systems are classified according to the
method of carrying out the process.
Site Index
A measure of the relative productive capacity of an area for growing wood.
Measurement of site index is based on height of the dominant trees in a stand at a
given age.
Soil Productivity
Capacity of soil to produce plant growth due to the soil’s chemical, physical, and
biological properties.
Sortyard
A location used to sort grades, types, and size of logs.
Stand
A group 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.
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4 References and Lists
State Selection
Application by Alaska Department of Natural Resources to the Bureau of
Land Management for conveyance of a portion of the 400,000-acre State
entitlement from vacant and unappropriated National Forest System lands in
Alaska under the Alaska Statehood Act.
Storage
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.
Stream Discharge
Flow rate of water in a stream channel.
Stream Value Class
A means to categorize stream channels based on their fish production
values. There are four stream classes defined by the Forest Plan. They are:
Class I. Streams and lakes with anadromous or adfluvial fish habitat; or
high quality resident fish waters listed in Appendix 68.1, Region 10 Aquatic
Habitat Management Handbook (FSH 2609.24), June 1986; or habitat above
fish migration barriers known to be reasonable enhancement opportunities
for anadromous fish.
Class II. Streams and lakes with resident fish populations and generally
steep (6-15 percent) gradient (ean also include streams from 0-5 pereent
gradient) where no anadromous fish occur, and otherwise not meeting Class
I criteria. These populations have limited fisheries values and generally
oecur upstream of migration barriers or have other habitat features that
preclude anadromous fish use.
Class III. Perennial and intermittent streams with no fish populations but
which have sufficient flow or transport sediment and debris to have an
immediate influence on downstream water quality or fish habitat capability.
These streams generally have bankfull widths greater than five feet and are
highly ineised into the surrounding hillslope.
Class IV. Intermittent, ephemeral, and small perennial channels with
insuffieient flow or sediment transport eapabilities to have an immediate
influence on downstream water quality or fish habitat capability. These
streams generally are shallowly incised into the surrounding hillslope.
Structural Diversity
The diversity of forest strueture, both vertically and horizontally, which
provides for variety of forest habitats such as logs and multi-layered forest
canopy for plants and animals.
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Subspecies
An aggregate of similar populations of a species generally inhabiting a geographic
subdivision of the range of the species and differing taxonomically (e.g. different
size or color) from other populations of the species.
Subsurface Flow
Water moving laterally through and beneath the soil mantle.
Succession
The ecological progression of plant community change over time, characterized by
displacements of species leading to a relatively stable climax community.
Suitable Forest Land
Forest land that is producing or is capable of producing crops of industrial wood
and: a) has not been withdrawn by Congress, the Secretary of Agriculture, or the
Chief of the Forest Service, b)existing technology and knowledge is available to
ensure timber production without irreversible damage to soils productivity, or
watershed conditions, c)existing technology and knowledge, as reflected in current
research and experience, provides reasonable assurance that it is possible to restock
adequately within five years after final harvest, d)adequate information is available
to project responses to timber management activities, and e) where timber harvest is
allowed under the Forest Plan.
Sustained Yield
The amount of renewable resources that can be produced continuously at a given
intensity of management.
Temporary Road or Trail
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. (36 CFR 212.1)
Threatened Species
Any species which is likely to become an endangered species within the foreseeable
future throughout all or a significant portion of its range and which has been
designated in the Federal Register by the Secretary of the Interior as a threatened
species.
Tiering
Elimination of repetitive discussions of the same issue by incorporating by
reference the general discussion in an environmental impact statement of broader
scope. For example, this EIS is tiered to the Forest Plan EIS.
Timber Appraisal
Establishing the fair market value of timber by taking the selling value minus
manufacturing cost, the cost of getting logs from the stump to the manufacturer, and
an allowance for profit and risk.
Tongass Resource Use Cooperative Survey (TRUCS)
A study done to gather information on subsistence uses of the Forest.
Tongass Timber Reform Act (TTRA)
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Chapter 4*15
4 References and Lists
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.
Transpiration
Evaporation from within the leaves of plants.
Travel Management Atlas
An atlas that consists of a forest transportation atlas and a motor vehiele use
map or maps.
Two-aged Management
A silvicultural method designed to maintain and regenerate a stand with two
age classes. The resulting stand may be two-aged or trend toward the
uneven-aged eondition as a consequenee of both an extended period of
regeneration establishment and retention of reserve trees that may represent
one or more age classes. The reserve trees provide struetural diversity and a
biologieal legacy. Two-aged management regimes can produce stands of
greater structural diversity than even-aged management.
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. (36 CFR 212.1)
Understory Vegetation
Grass, small trees, shrubs, and other plants found beneath the overstory (the
trees eomprising the forest).
Utility Volume
Logs that do not meet minimum requirements for sawtimber but are suitable
for other commereial uses.
V-notch
A deeply eut valley along some waterways, generally in steep, mountainous
terrain, that would look like a “V” from a frontal view.
Value Comparison Unit (VCU)
A distinct geographic area that generally encompasses a drainage basin
eontaining one or more large stream systems. Boundaries usually follow
easily reeognizable watershed divides. These units were established in the
Forest Plan to provide a eommon set of areas for which resource inventories
could be conducted and resouree value interpretations made.
Viable Population
For forest planning purposes a fish or wildlife population which has the
estimated number and distribution of reproductive individuals to ensure its
continued existence is well distributed in the National Forest.
Viewshed
A distinet area of land visible from identified travelways (boat route,
reereation road, or trail) or use areas (recreation eabin or anchorage).
16 • Chapter 4
Kuiu Timber Sale FEIS
References and Lists
Visual Absorption Capacity (VAC)
An estimate of the relative ability of a landseape to absorb alteration yet retain its
visual integrity.
Visual Quality Objective (VQO)
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.
Volume Class
Term used to describe the average volume of timber per acre in thousands of board
feet (MBF).
Volume Strata
Divisions of old-growth timber volume derived from the aerial photo interpreted
timber type data (TIMTYP) and the soils data (CLU). Three volume strata (low,
medium, and high) are recognized in the Forest Plan.
Watershed
That area that contributes water to a drainage or stream; portion of a forest in
which all surface water drains to a common point. 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.
Water Yield
The total amount of water draining from a watershed within a year.
Wetlands
Areas that are inundated by surface or ground water with a frequency sufficient,
under normal circumstances, to support a prevalence of vegetative or aquatic life
that requires saturated or seasonally saturated soil conditions for growth and
reproduction. Wetlands generally include muskegs, marshes, bogs, sloughs,
potholes, river overflows, mud flats, wet meadows, seeps, and springs.
Wild and Scenic River
Rivers or sections of rivers designated by congressional action under the 1968
Wild and Scenic Rivers Act or by an act of the Legislature of the state or states
through which they flow.
Wilderness
Areas designated under the 1964 Wilderness Act. Wilderness is defined as
undeveloped federal land retaining its primeval character and influence without
permanent improvements or human habitation. Wilderness areas are protected and
managed to preserve their natural conditions. In Alaska, wilderness also has been
designated by TTRA and ANILCA.
Wildlife Analysis Area (WAA)
A division of land used by the Alaska Department of Fish and Game for wildlife
analysis.
Kuiu Timber Sale FEIS
Chapter 4 • 17
4 References and Lists
Windtirm
Configuration of harvest units so as not to create an opening that exposes the
adjacent stahd of timber to the direction of the major prevailing storm wind
(southeast).
Windthrow (Blowdown)
The process by which trees are uprooted, blown down, or broken off by
storm winds. Three types of windthrow include: endemic, where individual
trees are blown over; catastrophic; where a major windstorm can destroy
hundreds of acres of trees; and management related, where the clearing of
trees in an area makes the adjacent standing trees vulnerable to windthrow.
Winter Range
An area, usually at lower elevations, used by big game during the winter
months; usually smaller and better defined than summer ranges.
Yarding
Hauling timber from the stump to a collection point.
18 • Chapter 4
Kuiu Timber Sale FEIS
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;
Corvallis, OR: Forest Research Laboratory, Oregon State University.
Alarid, S. Primaky, G. May, 15, 2007. GIS Marten Model Run. Wildcomb04. USDA
Forest Service, Petersburg Ranger District.
Alaska Department of Environmental Conservation. 2000. Alaska’s Nonpoint Pollution
Control Strategy. Juneau, AK. 100 pp.
http://ww^v. dec. state. ak.us/water/wnpspc/pdfs/npsstrategv%20fmal. pdf.
Accessed July 6, 2005.
Alexander, S. Housley, R. Vaughan, K. 2007. Impact on Indicated Advertised Value of
Limited Interstate Shipments of Unprocessed Sitka Spruce and Western
Hemlock Timber. USDA. Regional Office.
Beier, Paul and Reed F. Noss. 1998. Do habitat corridors provide connectivity?.
Conservation Biology 12:6. pp. 1241-1252. December 1998. 12 pp.
Beschta, R.L., Bilby, R.E., Brown, G.B., Holtby, L.B., Hofstra, T.D. 1987. Streamside
Management, Forestry and Fisheries Interactions. Chapter 6: Stream
Temperature and Aquatic Habitat: Fisheries and Forestry Interactions. Salo,
E. O. and T. W. Cundy (Editors). Institute of Forest Resources, University of
Washington, Seattle WA, pp. 191-232.
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.
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 3pp.
Brardinoni, F., Hassan, M.A., Slaymaker, H.O. 2002. Complex mass wasting response
of drainage basins to forest management in coastal British Columbia.
Geomorphology. 49: 109-124.
Campbell, T. M. 1979. Short-Term Effects of Timber Harvest on Pine Marten Ecology.
M. S. Thesis. Colorado State University, Ft. Collins. 71pp.
Caouette, J.P.; M.G. Kramer; and G.J. Nowacki. 2000. Deconstructing the timber
volume paradigm in management of the Tongass National Forest. USDA
Forest Service Pacific Northwest Research Station. General Technical
Report PNW-GTR-482. March 2000. 28pp.
Kuiu Timber Sale FEIS
Chapter 4*19
4 References and Lists
Code of Federal Regulations. Washington, D.C.: Office of Federal Register National
Archives and Records Administration.
36 CFR Subtitle B Protection of Inventoried Roadless Areas
36 CFR 219.1 10 Parks, Forests, and Public Property: Planning
36 CFR 800 Parks, Forests, and Public Property: Protection of Historic and
Cultural Properties
40 CFR 1501.7 Protection of Environment: NEPA and Agency Planning,
Scoping
40 CFR 1502.14 Protection of Environment: Environmental Impact Statement,
Alternatives including the proposed action
40 CFR 1502.22 Protection of Environment: Environmental Impact Statement,
Incomplete or unavailable information
Cole, F. 2005. Timber Harvest Project Environmental Analysis. File Code:
1920/2430. May 25, 2005, 4pp.
Cook, J.A. 2001. Conroy, C.J. Demboski, J. Fleming, M.A., Runck, A.M., Stone,
K.D., Macdonald, S.O. A phylogeographic perspective on endemism in the
Alexander Archipelago of Southeast Alaska. Biological Conservation
97(2001)215-227.
Deal, R.L. 2001. The effects of partial cutting on forest plant communities of
western hemlock-Sitka spruce stands in southeast Alaska. Can. J. For. Res.
31: 2067-2079 (2001). November 8, 2001.
Deal, R.L. and J.C. Tappeiner. 2000. The effects of partial cutting on stand structure
and growth of western hemlock - Sitka spruce stands in southeast Alaska.
Forest Ecology and Management 5486 (2001) 1-14.
DeGayner, E. J. October 1992. The role and reliability of habitat capability models.
USDA Forest Service, Alaska Region, P. O. Box 21628, Juneau, AK 99802.
DeGayner, E. J. 1996a. Black-tailed Deer Assessment Panel Summary. Letter to
TLMP Revision Planning File dated February 5, 1996, 8 pp plus attachments.
DeGayner, E. J. 1996b. Black-tailed Deer Habitat model Review Meeting Notes and
Model Outputs. Letter to TLMP Revision Planning File dated June 17, 1996,
4 pp plus attachments.
Doerr, J.G., E.J. DeGayner and G. Ith. 2005. Winter habitat selection by Sitka black-
tailed deer. Journal of Wildlife Management 69 (1): 322-331.
Flynn, R. W., T. V. Schumacher and M. Ben-David. 2004. Abundance, prey
availability and diets of American martens: implications for the design of old
growth reserves in Southeast Alaska. Alaska Department of Fish and Game,
Division of Wildlife Conservation. Final Report U. S. Fish and Wildlife
Service Grant DCN 70181-1-G133. December
Foley, Chris. 2006. Personal communication. Juneau, Alaska: Alaska Department of
Environmental Conservation, Environmental Program Specialist.
20 * Chapter 4
Kuiu Timber Sale FEIS
References and Lists
Geier, T.W. 1998. A Proposed Two-Tiered Sediment Risk Assessment for Potential Fish
Habitat Impacts from Forest Management in Southeast Alaska. Supervisors
Office Ketchikan Area, USDA Forest Service, Ketchikan, Alaska. 22 pp.
Harr, R.D., Harper, W.C., Krygier, J.T., Hsieh, F. 1975. Changes in storm hydrographs
after road building and clear-cutting in the Oregon Coast Range. Water
Resources Research 1 1(3): 436-444.
Hicks, B.J., Beschta, R.L., Harr, D.R. 1991(a). Long-temi changes in streamflow
following logging in western Oregon and associated Fisheries implications.
Water Resources Bulletin. 27(2): 217-226.
Hicks, B.J., Hall, J.D., Bisson, P.A., and Sedell, J.R. 1991(b). Influences of Forest and
Rangeland Management on Salmonid Fishes and Their Habitats - Responses
of Salmonids to Habitat Changes. American Fisheries Society Special
Publication 19, pages 483-518.
Jacobson, M. 2006. Personal correspondence regarding Bald eagle nest located by
Rowan Bay LTF outside the Kuiu Project Area. Juneau, Alaska. United
States Department of the Interior. Wildlife Biologist.
Johnson, J., Weiss, Ed, and Maclean, Scott. 2004. 2004 Catalog of Waters Important for
Spawning, Rearing, or Migration of Anadromous Fishes - Southern Region.
Effective January 15, 2005. ADF&G, November 2004, 465 pp..
Jones, J.A., and G.E. Grant. 1996. Peak flow responses to clear-cutting and roads in
small and large basins, western Cascades, Oregon. Water Resources
Research. 32(4): 595-974.
Jones, J.A. 2000. Hydrologic processes and peak discharge response to forest removal,
regrowth, and roads in 10 small experimental basins, western Cascades,
Oregon. Water Resources Research 36(9): 2621-2642.
Julin, K. R. and D. V. D’Amore. 2003. Tree growth on forested wetlands of
Southeastern Alaska following clearcutting. Western Journal of Applied
Forestry 18:30-34.
Kramer, M. 1997. Abiotic Controls on Windthrow and Forest Dynamics in a Coastal
Temperate Rainforest, Kuiu Island, Southeast Alaska. Master’s thesis,
Montana State University, Bozeman, Mt.
Kruse, J. and R. Frazier. 1988. Report to the community of I I: Tongass resource use
cooperative survey (TRUCS). A report series prepared for 3 1 communities in
southeast Alaska. Institute of Social and Economic research. University of
Alaska in Anchorage in cooperation with the USDA Forest Service and the
Alaska Department of Fish and Game Division of Subsistence, Juneau.
Landwehr, D.J. 1998. The Effectiveness of Standards and Guidelines in Preventing
Additional Mass Movement. An 89-94 KPC FEIS Monitoring Report
Ketchikan Area Watershed Group Final. February. Unpublished report.
Kuiu Timber Sale FEIS
Chapter 4 • 21
4 References and Lists
Landwehr, DJ. and G. Nowacki. 1999. Statistical Review of Soil Disturbanee
Transeet Data Collected on the Ketchikan Area, Tongass National Forest.
February. Unpublished Report.
Lowell, Richard E. 2002. Unit 1 A black bear management report. Pages 24-34 in C.
Healy, editor. Black bear management report of survey and inventory
activities 1 July 1998-30 June 2001. Alaska Department of Fish and Game.
Proj. 17.0. Juneau, Alaska.
Lowell, Richard. 2006. Personal Communication. Petersburg, Alaska. Alaska
Department of Fish and Game. October 12, 2006.
Lyons, J.K., Beschta, R.L. 1983. Land use, floods, and channel changes: Upper
Middle Fork Willamette River, Oregon (1936-1980). Water Resources
Research. 19(2): 463-471.
Madej, M.A., 1999. Temporal and Spatial Variability in Thalweg ProFdes of a
Gravel Bed River. Earth Surface Processes and Landforms 24: 1 153-1 169.
Montgomery, D.R., Buffington, J.M. 1997. Channel-reach morphology in mountain
drainage basins. Bulletin of the Geological Society of America 109(5): 596-
611.
Montgomery, D.R., Buffington, J.M. 1998. Channel Processes, Classification and
Response. In: River Ecology and Management, Lessons from the Pacific
Coastal Ecoregion. Naiman, R.J., Bilby, R.E., and Kantor, S. eds. Springer-
Verlag, New York.
Nowacki, G., et al. 2001. Ecological Subsections of Southeast Alaska and
Neighboring Areas of Canada. Juneau, Alaska: U.S. Department of
Agriculture, Forest Service, Alaska Region. RlO-TP-75
Oliver, C. D. and B. C. Larson 1990. Forest Stand Dynamics: Updated Edition. John
Wiley & Sons, Inc.
Pardini, Renata, Sergio Marques de Souza, Rieard Braga-Neto, and Jean Paul
Metzger. 2005. The role of forest structure, fragment size and corridors in
maintaining small mammal abundance and diversity in an Atlantic forest
landscape. Biological Conservation. 124 (2005) 253-266.
Peacock, E. 2004. Population, Genetic and Behavioral Studies of Black Bears
Ursus americanus in Southeast Alaska. PhD thesis. University of Nevada,
Reno. December 2004, 230pp.
Person, D..K.; M. Kirchhoff, V. Van Ballenberghe, G.C. Iverson and E. Grossman.
1996. The Alexander Archipelago Wolf: A Conservation Assessment.
USD A Forest Service, Pacific Northwest Research Station, General
Technieal Report PNW-GTR-384. November 1996, 42 pp.
22 • Chapter 4
Kuiu Timber Sale FEIS
References and Lists
Person, D.; M. Kirchhoff; V. Van Ballenberghe and R. T. Bowyer. 1997. A letter to
Beth Pendleton Leader of the Tongass Land Management Planning Team
concerning the basic population ecology relevant to the wolf conservation
assessment. September 19, 1997.
Person, D.K. August 2001. Alexander Archipelago Wolves: Ecology and Population
Viability in a Disturbed, Insular Landscape. Ph.D. Thesis, University of
Alaska Fairbanks. 174 pp.
Ruth, R.H., and A.S. Harris. 1979. Management of Western Hemlock-Sitka Spruce
Forests for Timber Production. GTR-PNW-88. Portland, OR: U.S.
Department of Agriculture, Forest Service, PNW Forest and Range
Experimental Research Station.
Schoen, J. 1985. Kirchoff, M. Seasonal Distribution and Home-Range Patterns of
Sitka Black-Tailed Deer on Admiralty Island, Southeast Alaska. Journal of
Wildlife Management 49(1):96-103.
Small, M.P., K.D. Stone and J.A. Cook. 2003. American marten (Martes americana) in
the Pacific Northwest: population differentiation across a landscape
fragmented in time and space. Molecular Ecology 12, 89-103.
Soutiere, E. C. 1979. Effects of timber harvesting on marten in Maine. Journal of
Wildlife Management. 43:850-860.
Stone K.D. and J.A. Cook. 2002. Molecular evolution of Holarctic martens (genus
Martes, Mammalia: Carnivora: Mustelidae). Molecular Phylogenetics and
Evolution 24 (2002) 169-179.
Sullivan, K., Lisle, T., Dolloff, C., Grant, G., and Reid, L. 1987. Streamside
Management, Forestry and Fisheries Interactions. Chapter 3 : Stream
Channels: The Link Between Forests and Fishes. Salo, E. O. and T. W.
Cundy (Editors). Institute of Forest Resources, University of Washington,
Seattle WA, pp. 39-97.
Suring L. H., R. W. Flynn and E. J. DeGayner. 1992. Habitat Capability Model for
Marten in Southeast Alaska: Winter Habitat. Version 5.0. US DA Forest
Service, Alaska Region, PO Box 21628, Juneau, AK.
Suring, L.H., D.C. Crocker-Bedford; R.W. Flynn, C.S. Hale, G.C. Iverson, M.D.
Kirchhoff, T.E. Schenck, L.C. Shea, and K. Titus. 1994. Response to the
Peer Review of: A Proposed Strategy for Maintaining Well-distributed,
Viable Populations of Wildlife Associated with Old growth Forests in
Southeast Alaska. Report of an Interagency Committee. May 1 994. 1 1 pp.
Swanston D. N., 1995. Overview of controlling stability characteristics of steep terrain
in Southeast Alaska with discussion of needed standardization for mass
movement hazard indexing on the Tongass National Forest. Unpublished
paper on file in Kuiu Timber Sale Area planning record, Petersburg, Alaska.
Kuiu Timber Sale FEIS
Chapter 4 • 23
4 References and Lists
Swanston, D. N. and D. A. Marion, 1991. Landslide Response to Timber Harvest in
Southeast Alaska. In: Proceedings of the Fifth Federal Interagency
Sedimentation Conference, Fan S. S. and Y. H. Kuo (Editors).
Tischendorf, Lutz and Lenore Fahrig. 2000. How should we measure landseape
eonnectivity? Landscape Ecology Vol.l5: 633-641.
Thompson, I.D. 1988. Habitat needs of furbearers in relation to logging in boreal
Ontario. For. Chron. 64:251-261. in Suring, H. L., R.W. Flynn, and E.J.
DeGayner. 1992. Habitat Capability Model for Marten in Southeast Alaska:
Winter Habitat.
USDA Forest Service. 1973. Visual Character Types. Series No. RlO-63. U.S.
Forest Service, Alaska Region, Division of Recreation, Soils, and
Watershed, Juneau, Alaska.
USDA Forest Service. 1974. National Forest Landscape Management, Volume 2.
Agriculture Handbook Number 462. Washington, D.C.: U.S. Department of
Agriculture, Forest Service.
USDA Forest Service. 1995. Report to Congress: Anadromous Fish Habitat
Assessment. Alaska Region: RlO-MB-279.
USDA Forest Service. 1997. Tongass National Forest Land and Resource
Management Plan. Juneau, Alaska: U.S. Department of Agriculture, Forest
Service, Alaska Region, Tongass National Forest. R10-MB-338dd.
USDA Forest Service. 1997. Tongass Land Management Plan Revision: Final
Environmental Impact Statement. Juneau, Alaska: U.S. Department of
Agriculture, Forest Service, Alaska Region, Tongass National Forest. RIO-
MB-338b.
USDA Forest Service. 1997(d). Tongass Land Management Plan Revision:
Appendices to Appendix N Juneau, Alaska: U.S. Department of
Agriculture, Forest Service, Alaska Region, Tongass National Forest. RIO-
MB-338h
USDA Forest Service. 1998. Tongass Land and Resource Management Plan
Implementation Policy Clarification.
USDA Forest Service. 1998. Crane and Rowan Mountain Timber Sales. Tongass
National Forest. R-lO-MB-362. Juneau. July 1998.
USDA Forest Service. 2000. Annual Monitoring and Evaluation Report for Fiscal
Year 2000. Tongass National Forest. U.S. Department of Agriculture.
RlO-MB-431.
USDA Forest Service. 2003a. Forest Health Protection: Forest Insect and Disease
Conditions in the United States 2001. Washington, D.C.: U.S. Department
of Agriculture, Forest Service.
24 • Chapter 4
Kuiu Timber Sale FEIS
References and Lists
USDA Forest Service. 2003b. Tongass Land Management Plan Revision, Final
Supplemental Environmental Impact Statement. Roadless Area Evaluation
for Wilderness Recommendations. Juneau, Alaska: U.S. Department of
Agriculture, Forest Service, Alaska Region, Tongass National Forest. RIO-
MB-481b. February 2003.
USDA Forest Service. 2003c. Tongass Land Management Plan Revision, Final
Supplemental Environmental Impact Statement. Roadless Area Evaluation
for Wilderness Recommendations. Record of Decision Juneau, Alaska: U.S.
Department of Agriculture, Forest Service, Alaska Region, Tongass
National Forest. R10-MB-481g. February 2003.
USDA Forest Service. 2005. Kuiu Island Landscape Assessment. Petersburg, Alaska:
U.S. Department of Agriculture, Forest Service, Alaska Region, Tongass
National Forest, Petersburg Ranger District. RlO-MB-545.
USDA Forest Service. 2006. Kuiu Timber Sale Area Draft Environmental Impact
Statement. Tongass National Forest. RlO-MB-570. January.
USDA Forest Service. Forest Service Manuals.
FSM 2400 Timber Management
RlO-Supp 2400-2005-1, Region 10 Supplement to FSM 2400, Timber
Management
FSM 2500 Watershed and Air Management
RlO-Supp 2500-92-1, Region 10 Supplement to FSM 2500, Chapter 50, Soil
Management. Region 10 Soil Quality Standards.
USDA Forest Service. Forest Service Handbooks.
FSH 2409.18 Timber Sale Preparation Handbook
FSH 2609.25 Subsistence Management and Use Handbook (1985)
FSH 2090.21 Aquatic Habitat Management Handbook
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 Proceeding-Referate-Exposes. Japan.
Kuiu Timber Sale FEIS
Chapter 4 • 25
List of Preparers
Justin
Anderson
Position:
Experience:
Education:
Hydrologist (until September 2006)
3 years with the Forest Service
BS Forestry Resources Management
MS Forest Science/Water Resources Management
Tiffany Benna
Position:
Experience:
Education:
Interdisciplinary Planning Team Leader (from April
2007)
IVi years with the Forest Service
BA English/Creative Writing and Poetry
Jim Brainard
Position:
Experience:
Education:
Wildlife Biologist
27 years with the Forest Service
BS Forest Management
Ben Case
Position:
Experience:
Education:
Forester (2003-04)
14 years with the Forest Service
BS Forest Management
Mary Clemens
Position:
Experience:
Education:
Recreation Planner
25 years with the Forest Service
BS Forest Management
Crystal Harlan
Position:
Experience:
Education:
Fish Biologist
4V2 years with the Forest Service
BS Biology with a Concentration in Marine Science
Bob Moniz
Position:
Experience:
Timber Appraiser (until 2005)
30 years with the Forest Service
Alan Murph
Position:
Experience:
Education:
Transportation Planner
28 years professional experience (8 years with the
Forest Service)
BS Civil Engineering
Kent
Nicholson
Position:
Experience:
Education:
Forester (2004-present)/ Interdisciplinary Planning
Team Leader (Dec 2006-March 2007)
23 years professional experience (3 years with the
Forest Service)
AAS Forestry, Certificate of Forestry, BA Business
Kelly O’Soup
Position:
Experience:
Detail Writer/Editor (Jan 2007- April 2007)
4 years with the Forest Service
Madonna
Parks
Position:
Experience:
Geographic Information Systems Technician
16 years with the Forest Service
26 • Chapter 4
Kuiu Timber Sale FEIS
References and Lists
R.D. Parks
Position:
Experience:
Education:
Silviculturist
27 years professional experience, 17 years with the
Forest Service
BS Forestry
Gene Primaky
Position:
Experience:
Education:
Geographic Information Systems Technician
15 years with the Forest Service
Certificate of Forestry, AV Tech
Kris Rutledge
Position:
Experience:
Education:
Interdisciplinary Planning Team Leader/Writer Editor/
Wildlife Biologist (2003-06)
17 years with the Forest Service
BS Wildlife Biology
Linda Slaght
Position:
Experience:
Education:
Writer/Editor (until March 2006)
18 years with the Forest Service
BA Geology
Jane Smith
Position:
Experience:
Education:
Archaeologist
23 years professional experience ( 1 5 years with the
Forest Service)
BS Anthropology
Tani Stenfjord
Position:
Experience:
Education:
Detail Writer/Editor (March - October 2006)
5 years professional experience (6 months with the
Forest Service)
BA in Elementary Education, MED
Jim Steward
Position:
Experience:
Landscape Architect
18 years with the Forest Service
Kristin
Whisennand
Position:
Experience:
Education:
Writer/Editor assistant
3 years of experience
BA Anthropology, BS Resource Conservation
Management
Heath
Whitacre
Position:
Experience:
Education:
Hydrologist (Dec 2006 - present)
6 years with the Forest Service
BA Environmental Biology, MS Watershed Science
Marina
Whitacre
Position:
Experience:
Education:
Writer/Editor (April 2007 - present)
3 years with the Forest Service
BA Biology, MS Range Science
Kuiu Timber Sale FEIS
Chapter 4 • 27
Agencies
List.of FEIS Recipients
Agencies, organizations, and individuals to whom the Kuiu Timber
Sale Area Final Environmental Impact Statement was sent.
Alaska Department of Fish and Game, Division of Wildlife
Conservation
Admiralty National Monument
Alaska Department of Environmental Conservation
Alaska Department of Environmental Conservation/Division of Water
Alaska Department of Natural Resources, Office of Habitat
Management and Permitting
Alaska Department of Natural Resources, Office of Project
Management and Permitting
Alaska Department of Fish and Game
Alaska Division of Forestry
Department of the Army
NO A A Office of Policy and Strategic Planning
Southeast Region, DOT&PF
US Advisory Council on Historic Preservation
US Army Engineer District
US Army Engineers
US Environmental Protection Agency- Region 10
US Department of Energy
US Geological Society
USCG Environmental Management
USDA APHIS PPD/EAD
USDA Forest Service Alaska Regional Office
USDA Forest Service, Chugach National Forest
USDA Forest Service, Tongass National Forest, Craig Ranger District
USDA Forest Service, Tongass National Forest, Hoonah Ranger
District
USDA Forest Service, Tongass National Forest, Juneau Ranger
District
USDA Forest Service, Tongass National Forest, Ketchikan-Misty
Ranger District
USDA Forest Service, Tongass National Forest, Ketchikan
Supervisor's Office
USDA Forest Service, Tongass National Forest, Petersburg Ranger
District
USDA Forest Service, Tongass National Forest, Petersburg
Supervisor's Office
USDA Forest Service, Tongass National Forest, Sitka Ranger District
USDA Forest Service, Tongass National Forest, Thome Bay Ranger
District
28 • Chapter 4
Kuiu Timber Sale FEIS
References and Lists
USDA Forest Service, Tongass National Forest, Wrangell Ranger
District
USDA Forest Service, Tongass National Forest, Yakutat Ranger
District
USDA Forest Service, Tongass Supervisor's Office
USDA Natural Resources Conservation Service
USDA Office of Civil Rights
USDI Bureau of Land Management
USDI Fish and Wildlife Service
USDI Office of Environmental Policy and Compliance
USDI Office of the Secretary
USDI National Park Service
USDOC National Marine Fisheries Service
USDOT Federal Aviation Administration
US Navy
Libraries
Craig Public Library
Petersburg Public Library
Haines Public Library
Quinney Library
Hollis Public Library
Sheldon Jackson Library
Hyder Public Library
Skagway Public Library
Juneau Public Library
Tenakee Springs Public Libr
Kake Public Library
Thome Bay Community
Kasaan Community Library
Library
Ketchikan Public Library
University of Minnesota
Kettleson Memorial Library
Forestry Library
Pelican Public Library
Wrangell Public Library
Media
KFSK Public Radio
Petersburg Pilot
KNHS-FM
Wrangell Sentinel
Organizations
and
Businesses
Acupuncture Center PC
Alaska Center for the
Environment
Alaska Charter & Adventures
Alaska Fibre
Alaska Forest Association
Alaska Peak & Seas
Alaska Rainforest Campaign
Alaska Sea Adventures
Alaska Yacht Charters
Alpine Expeditions
Atterbury Consultants, Inc.
Baranof Wilderness Lodge
Bluewater Adventures, Ltd.
Buchanan General Contracting
Co.
Cascadia Wildlands Project
Center for Biological Diversity
Chamber of Commerce
Chico Area Flyfishers
The Committee for
Conservation of Forests and
Wildlife
Dolphin Charters
Earthjustice
Family Charters
The Fishermen's Inn
Forest Dwellers
Forest Industry Consulting
Glacier Guides
Green Peaee
Island Point Lodge, Inc.
Kuiu Timber Sale FEIS
Chapter 4 • 29
4 References and Lists
Jordan Creek Center
Juneau - John Rishel Minerals
Information Center
Land Serviees
Laughing Raven Lodge
Lindblad Expeditions
Maple Leaf Adventures
Narrows Conservation
Coalition
National Audubon Society
National Outdoor Leadership
School
Natural Resource Defense
Council
The Nature Conservancy of
Alaska
Paden Timber Services
Parker Guide Service
Robertson, Monagle, &
Eastaugh
Salmon Falls Resort
SEACC
Sealaska Corporation
Secretary of TBPA
See Alaska Tours
Public
Officials and
Offices
City of Kupreanof
City of Petersburg
City of Port Alexander
City of Wrangell
Govenor Sarah Palin
Kake Tribal Corporation
Ketchikan Gateway Borough
OVK
Sierra Club Juneau Group
Silver Bay Logging, Inc.
Sitka Conservation Society
Smayda Environmental
Associates, Inc
Southeast Alaska Regional
Advisory Council
Southeast Conference
Sportsman's Alliance for
Alaska
Stikine Guide Service
Stikine River Song Charters
Thuja Plicata Lumber
Company
Tongass Kayak Adventures
Walk Softly Adventures
Wild Rockies Field Institute
The Wilderness Society
Wilderness Watch
The Wilderness Society
Wild Rockies Field Institute
Wilderness Watch
Washington Wilderness
Coalition
Petersburg Indian Association
Senator Bert Stedman
Senator Ted Stevens
State Representative Don
Young
State Representative Peggy
Wilson
University of Alaska Land
Management
30 • Chapter 4
Kuiu Timber Sale FEIS
References and Lists
Individuals
Kris Aceveda
Bertrand Adams
John Ashenfelter
Dave Beebe
Marc Berens
Dave and Nancy Berg
Anissa Berry
Harry Brouillette
Wesley Brown
Terry Buness
Jessica Campbell
Beth Campbell
Emil and Daniel Churchill
Harry M. Churchill
Mary Ellen Clark
Dick Coose
Donald A. Cornelius
David Crown
Natalie Dawson
Paul Demmert
Lou Anna Denison
Susan Erickson
Katie Fearer
Barney Freedman
Mary Friburg
Xavier Friday
Michelle Friday
John Geddie
Harvey Gilliland
G. Goldstein
Marina Gonchar
Robert Grant
Dave Grebe
David Greer
Eric Grundberg
Jill Guidry
Rebecca H.
Eric Hanson
Kim Hastings
Karen R. Hegyi
Judy Henderson
Molly Hogan
R.W. Holsinger
Scott Hursey
Glen Ith
Edna Jackson
Clarence Jackson
Mike Jackson
Raymond Jackson
Ken Jackson
Mike Jackson
John Jensen
Marvin Kadake
Delbert Kadake
Susan Kauffman
Joan Kautzer
Emily Kemdt
Harvey Kitka
Bemie Klemanek
Becky Knight
John Krober
Dan LaCrosse
Roxane Lee
Peter Litsheim
Dick Longworth
Tim Ludlow
Steve Lustgarden
Carl Mach
Tony Mach
Stu Mach
Steve Mashuda
Sigurd Mathisen
Donald McAdams
Karin McCullough
Gerry Merrigan
Brian Merritt
Kevin Merry
Tim Moore
Amanda Noonan
Jean Norheim
Paul Olson
Craig Olson
Helmer Olson
Brian Paust
Elizabeth Peacock
James Phillips
Jay and Carolyn Pritchett
William B. Privett
Kuiu Project Area FEIS
Chapter 4 • 31
4 References and Lists
Elizabeth Ray
Jamie Reid
Chuck'Ressler
Dave and Sally Riemer
Tom Rockne
Pat Roppel
Irene Roundtree
Dorothy Roundtree
Gregory Scheff
Kathryn Schneider
Lindon Schultz
Steve Seley
Cynthia Sever
Jeff Shivley
Ronald Simpson
Martha Smith
Mike Stainbrook
Helen Stokes
Joe Stratman
John R. Swanson
Travis Tanasse
Ed Ule
Ken Vaughan
Tiffany Vue
Rhonda Waston
Ralph Wells
John Wigren
Gary E. Williams
Joshua Wodton
E.F. Wood
George Wortiska
Chris Zimmer
List of FEIS Notification Letter
Recipients
Individuals who were sent notification letters on the availability of the
Kuiu Timber Sale Area Final Environmental Impact Statement. These
individuals submitted modified comment form letters from either The
Wilderness Society or Natural Resource Defense Council.
George and Frances Alderson
Yovonne Autrey-Schell
Anne and Richard Baron
Janet Baron
Kimberly Baron
John K. Bates
Rick Bawor
Jackie M. Bell
C. Blue
Brian Bodah
Brent Bollick
Erika Bjorum
Elizabeth Boylston
Susan Bradfield
J. Capozzelli
Diane Carney
Helen Caswell
Jan Charvat
Kevin Clement
Theodore S. Cochrane
Linda Coleman
Marvin Corbett
Helen M. Comeli
Chris DesJardins
Mary Faith Dominque
Mary Lee Duffy
Lesleigh Ellinger
Brian Franklin
Linda Gibson
Sue Golden
Dennis P. Graham
Sharon Guidry
Dellie Guidry
Richard Hamilton
Scott Harris
Randy Harrison
Gerald Hoffman
Anne Hollier
Ann Holt-Harris
J. Kinley
Sterling Kinnell
Maria Klein
32 • Chapter 4
Kuiu Project Area FEIS
References and Lists
Mathew Kopietz
Mr. and Mrs. Richard H
Nancy Kops
Plerpont
Renee Larkin
Juan Carlos Pogan
A1 Larson
Bob Raab
Judith Le Blanc
Neville Sue Rapp
Janet Lyons-Fairbanks
Robinson Family
Melladee Makelacy
John A. Rothermich
David L. Marshall
Alexandra Scott
George Marzluf
Jessie Seller
Michael V. Mattison
Dave Shreffler
Darrell McClanahan
Rebecca B. Smith
Frank and Nancy Miles
Kevin Spath
Lillian Miller
Richard Stanley
Jacqueline Miller
Jim Sweeney
Judy Mouton
Dennis Thomas
Jennifer Orrigo
Kathryn Thornton
Roy Petitfils
Mary Townsager
George L. Pettit
Maria Tregre
Carly S. Wier
Candie Zarodi
Kuiu Project Area FEIS
Chapter 4 • 33
Index for Chapter 1
A
Alaska Coastal Zone Management
Act(CZMA) • 1-19
Alaska Department of Fish and Game
(ADF&G) • l-ll, 1-12, 1-15
Alaska Department of Natural
Resources • l-ll, I -1 9
Alaska National Interest Lands
Conservation Act (ANILCA) • 1-6,
1-13, 1-20
Alaska Water Quality Standards • 1-
19
Alternative 4 1-1
Army Corps of Engineers ■ 1-11, 1-18
Army Corps of Engineers (ACOE) •
1-11, 1-18
B
Bald and Golden Eagle Protection
Act - 1-19
beach and estuary buffers • 1-5, 1-14,
1-17
beach fringe • 1 -5
biodiversity • 1 -6
biological diversity • 1-6
C
Clean Air Act 1-19
Clean Water Act • 1-18, 1-19
clearcut 1-10
clearcutting 1-10
Coastal Zone Management Act
(CZMA) • 1-19
Council on Environmental Quality
(CEQ) • 1-9
cultural resources • 1 -20
cumulative effects • 1-9, 1-10, 1-13,
1-15, 1-16
D
deer - 1-10, 1-12, 1-14, 1-15
deer habitat capability - 1-15
deer, Sitka black-tailed - 1-10
Deer, Sitka black-tailed deer - 1-15
desired condition - 1-2, 1-10
desired future eondition - 1 -4
E
ecological processes - 1-6
economics - 1-14, 1-16, 1-18
employment - 1-2, 1-16
Environmental Protection Agency
(EPA) - 1-11, 1-12, 1-18, 1-19
estuary - 1-5, 1-17
F
fish habitat - 1-12, 1-14
fishing - 1-5
forest habitat - 1 -6
Forest Plan ■ 1-1, 1-2, 1-4, 1-5, 1-7, 1-
9, 1-0, 1-12, 1-13, 1-14, 1-15, 1-16,
1-17, 1-18
Forest Plan SEIS • 1-14, 1-15
Forest Plan standards and guidelines •
1-17
fragmentation 1-10
H
habitat capability • 1-6
heritage resources -1-12
high value -1-16
hunting ■ 1-5, 1-15
/
income -1-16
Inventoried Roadless Area • 1-14, 1-
15
inventoried roadless areas ■ 1-14, 1-
15
K
Kake, city of - 1-9, 1-10, 1-11, 1-12,
1-13
karst -1-5
Kuiu Island ■ 1-1, 1-3, 1-4, 1-7, 1-8,
1-9, 1-10, 1-11, 1-12, 1-13, 1-14,
1-17
Kuiu Landscape Assessment (Kuiu
LA) • 1-10
Kupreanof Island • 1-9
L
Land Use Designation (LUD) • 1-4,
1-5, 1-6, 1-7, 1-8, 1-17
log transfer facility -1-1
34 • Chapter 4
Kuiu Project Area FEIS
log transfer facility (LTF) ■ 1-1, 1-18,
1-19
Management Indicator Species (MIS)
• 1-15
Marine Mammal Protection Act ■ 1-
19
mitigation ■ 1-2, 1-13, 1-14
Modified Landscape LUD • 1-7, 1-18
monitoring ■ 1-2, 1-14
National Environmental Policy Act
(NEPA) • 1-19
National Forest Management Act
(NFMA) ■ 1-4, 1-17, 1-19
National Forest System Roads 1-1,
1-10, 1-16
National Historic Preservation Act
(NHPA) ■ 1-19
Notice of Intent (NOI) -1-11
old-growth • 1-1, 1-4, 1-6, 1-7, 1-10,
1-12, 1-15, 1-17
old-growth forest
productive 1-6
old-growth habitat • 1-1, 1-10, 1-12,
1-15, 1-17
old-growth habitat reserve 1-1
old-growth habitat reserves • 1-1, 1-2,
1-12, 1-17
old-growth habitat reserves (OGR) •
1-2, 1-12
Organized Village of Kake ■ 1-12, 1-
13
permit • 1-18, 1-19
Petersburg, city of - 1-1, 1-9, 1-11, 1-
12, 1-13
planning record -1-13
Point Baker 1-10
Point Protection, city of - 1-10
productive forest - 1 -5
productive old growth - 1 -6
productive old growth (POG) - 1-6, 1-
15
proposed action - 1-1, 1-2, 1-4, 1-9,
1-11, 1-14
public involvement - 1-9, 1-10, 1-13,
1-16, 1-17
purpose and need - 1-1, 1-2, 1-1 1
References and Lists
R
Record of Decision (ROD) - 1-5, 1-17
riparian area - 1-5, 1-14, 1-17
Riparian area - 1-5, 1-14, 1-17
riparian management area (RMA) - 1-
5
road construction - 1-10, 1-15, 1-16
road reconstruction 1-1
roadless • 1-4, 1-14, 1-15
roadless area 1-14
roads • 1-4, 1-5, 1-10, 1-13, 1-15, 1-
16, 1-17
Roads
classified roads • 1-16
temporary roads • 1-1, 1-2, 1-16
Rowan Bay • 1-1, 1-18, 1-19
5
Saginaw Bay • 1-1, 1-9, 1-18, 1-19
Scenic Viewshed LUD -1-18
scoping • 1-9, 1-10, 1-13, 1-16, 1-17
second growth ■ 1 -5
second-growth ■ 1 -5
sediment 1-16
Sediment Risk Index (SRI) • 1-16
Semi-remote Recreation LUD • 1 -7,
1-17
shellfish 1-10
significant restriction ■ 1-2, 1-15
soil • 1-12, 1-16
Special Interest Area LUD • 1-7
subsistence • 1-2, 1-6, 1-10, 1-12, 1-
13, 1-14, 1-15
suitable land • 1-2, 1-5, 1-6
suitable timber • 1 -5
sustained yield • 1-2, 1-5, 1-17
T
temporary road • 1-1, 1-2, 1-16
thinning ■ 1-5
timber economics -1-12
timber harvest ■ 1-2, 1-4, 1-5, 1-6, 1-
10, 1-14, 1-15, 1-16, 1-17
timber management • 1 -5
timber production • 1 -5
Timber Production LUD • 1-4, 1-5, 1-
7, 1-17, 1-18
Tlingit- 1-12
Tongass Land and Resource
Management Plan (Forest Plan) • 1-
1, 1-2, 1-4, 1-5, 1-7, 1-9, 1-10, 1-
12, 1-13, 1-14, 1-15, 1-16, 1-17, 1-
18
Tongass National Forest • 1-1, 1-4, 1-
9, 1-17
Kuiu Project Area FEIS
Chapter 4 • 35
4 References and Lists
Tongass Timber Reform Act (TTRA)
• 1-20
tribal government - 1-10, 1-12
U
U.S. Fish and Wildlife Service
(USFWS) • 1-11, 1-12
unroaded • 1-14, 1-15
V
Value Comparison Unit (VCU) • 1-9
viable population • 1-6
viewshed -1-18
visual quality • 1-6
Visual Quality Objective (VQO) • 1-6
W
water quality • 1-10, 1-12
waterfowl 1-13
watershed • 1-5, 1-14, 1-16, 1-17
wetlands • 1-18, 1-20
Wild and Scenic Rivers • 1-6, 1-7, 1-
19
wilderness • 1-7, 1-12, 1-14, 1-15, 1-
17
Wildlife Analysis Area (WAA 5012)
• 1-15
wildlife habitat • 1-5, 1-15
winter range -1-15
Index for Chapter 2
A
Alaska Department of Fish and Game
(ADF&G) • 2-6, 2- 7
B
beach fringe • 2-6
Best Management Practices (BMPs) •
2-6, 2- 17
C
Clean Water Act -2-17
clearcut with reserves • 2-7
clearcutting • 2-5, 2- 7, 2- 9, 2- 11, 2-
12
cumulative effects -2-11,2- 13
D
Dean Creek Watershed -2-15
deer -2-1 1,2- 14, 2- 15
E
economics • 2-2, 2- 4, 2- 12,2- 1 5, 2-
17
employment • 2-12, 2- 13
Environmental Protection Agency
(EPA) • 2-7
estuary • 2-6
even-aged management • 2-5
F
Forest Plan • 2-1, 2- 3, 2- 4, 2- 5, 2- 6,
2- 7, 2- 10, 2- 11,2- 15,2- 17, 2-
18
Forest Plan standards and guidelines •
2-6, 2- 17
G
ground-based logging ■ 2-3, 2- 5
H
helicopter logging • 4, 2- 17
high value • 11,2- 16
hunting ■ 11,2- 15
hydrology • 3
/
Inventoried Roadless Area • 10, 2- 14
K
Kadake Creek -2-16
Kadake Creek Watershed -2-16
Kuiu Island • 2-1, 2- 4, 2- 9, 2- 10, 2-
11
L
Land Use Designation (LUD) • 2-3,
2- 4, 2- 7, 2- 17
log transfer facility (LTF) • 2-3, 2- 8,
2- 12, 2- 13,2- 15
logging camp ■ 2-8
logging system • 2-4, 2- 9
M
management prescription -2-17
marten -2-16
Mass Movement Index (MMI) -2-15
mitigation -2-1,2- 17, 2- 18
monitoring -2-1,2- 17, 2- 18
36 • Chapter 4
Kuiu Project Area FEIS
N
National Environmental Policy Act
(NEPA) -2-12
National Forest Management Act
(NFMA)-2-l,2- 18
National Forest System Roads ■ 2-3,
2-4, 2-5,2- 6, 2- 9,2- 10, 2- 11,
2- 13,2- 14, 2- 18
NEPA Economics Analysis
Tool Residuals (NEAT_R) • 2-2,
2- 12,2- 17
Northern goshawk • 2-8
O
old-growth ■ 2-2, 2- 6, 2- 8, 2- 16
old-growth habitat ■ 8
old-growth habitat reserves (OGR) •
2-6, 2- 14
P
partial harvest -2-13
pennit ■ 2-7
planning record • 2-7
preferred alternative -2-14
productive old growth (POG) • 2-6, 2-
11.2- 14, 2- 16
purpose and need • 2-1
R
Record of Decision (ROD) ■ 2-2
riparian area • 2-6, 2- 7
riparian management area (RMA) • 2-
6
road construction ■ 2-2, 2- 3, 2- 4, 2-
5.2- 8, 2- 10, 2- 12,2- 13,2- 17,2-
18
road maintenance • 8, 2- 9
Road Management Objective (RMO)
•2-2, 2-7,2- 18
roadless • 2-3, 2- 10, 2- 11,2- 14
roads • 2-2, 2- 3, 2- 4, 2- 5, 2- 7, 2- 8,
2- 9, 2- 10, 2- 11,2- 12,2- 13,2-
15.2- 16, 2- 17, 2- 18
Rowan Bay • 2-3, 2- 4, 2- 5, 2- 7, 2-
8.2- 12,2- 13,2- 15
Rowan Creek Watershed -2-16
5
Saginaw Bay ■ 2-3, 2- 4, 2- 5, 2- 6, 2-
7, 2- 8, 2- 12,2- 13,2- 15
References and Lists
Saginaw Creek Watershed -2-15
scoping ■ 2-1
Security Creek -2-15
significant restriction -2-15
silvicultural prescription • 2- 1
soil • 2-2, 2- 7
stream buffer -2-8
stream crossing • 2-7, 2- 16
subsistence -2-11,2- 12, 2- 14, 2- 15
T
temporary road • 2-2, 2- 3, 2- 4, 2- 5,
2- 7, 2- 9, 2- 10, 2- 11,2- 14, 2- 16
timber economics -2-12
timber harvest • 2-1, 2- 2, 2- 3, 2- 4,
2-5,2- 6, 2- 7, 2- 9, 2- 10, 2- 11,
2- 12, 2- 13,2- 15,2- 16, 2- 18
Tongass Land and Resource
Management Plan (Forest Plan) • 2-
1,2-3, 2-4, 2-5,2- 6,2- 7, 2- 10,
2- 11,2- 15,2- 17,2- 18
Tongass National Forest -2-18
Tongass Timber Reform Act (TTRA)
• 2-6
transportation ■ 2-1, 2- 8
two-aged management ■ 2-9
U
U.S. Fish and Wildlife Service
(USFWS) • 2-6, 2- 17
uneven-aged management • 2-7
unroaded • 2-3, 2- 10, 2- 11,2- 14
V
visual quality • 2-7
W
water quality • 2-6, 2- 7
watershed • 2-13, 2- 15
western hemlock • 2-2, 2- 13
wetlands ■ 2-7, 2- 16
wilderness -2-11,2- 14
Wildlife Analysis Area (WAA 5012)
■ 2-11,2- 14, 2- 16
wildlife habitat • 2-3, 2- 4
windthrow • 2-7
winter habitat -2-12
winter range -2-11,2- 14
Kuiu Project Area FEIS
Chapter 4 • 37
References and Lists
Index for Chapter 3
Alaska Coastal Zone Management
Act (CZMA) • 3-232
Alaska Department of Fish and Game
(ADF&G) ■ 3-5, 3-27, 3-31, 3-33,
3-51, 3-52, 3-57, 3-75, 3-76, 3-80,
3-90, 3-93, 3-94, 3-96, 3-109, 3-
1 10, 3-123, 3-124, 3-125, 3-126, 3-
128, 3-132,3-155,3-156,3-212,
3-213
Alaska Department of Natural
Resources • 3-232
Alaska Marine Highway • 3-126, 3-
128, 3-197
Alaska National Interest Lands
Conservation Act (ANILCA) • 3-
48, 3-229, 3-234
Alaska Water Quality Standards • 3-
71, 3-191, 3-230
all-terrain vehicles (ATVs) • 3-209
anadromous fish • 3-153, 3-154, 3-
159, 3-218
bald eagle • 3-118, 3-119, 3-127, 3-
228
beach and estuary buffers • 3-143
beach fringe ■ 3-55, 3-107, 3-1 18, 3-
119.3- 127,3-152,3-218
Best Management Practices (BMPs) •
3-53,3-162,3-163,3-164,3-165,
3-176, 3-179, 3-184, 3-189, 3-218,
3-228, 3-229, 3-230, 3-231, 3-233
biogeographic province • 3-6, 3-52, 3-
125.3- 126,3-133
biological diversity • 3-7, 3-27, 3-118,
3-119,3-134,3-144
black bear ■ 3-27, 3-33, 3-49, 3-52, 3-
53.3- 57,3-1 18,3-125,3-21 1,3-
212, 3-213,3-214,3-215,3-219
black bear hunting • 3-119, 3-21 1, 3-
212.3- 214,3-215,3-219
brown creeper ■ 3-118
cabin-3-84, 3-209, 3-214
channel type • 3-154, 3-160
Chinook salmon • 3-103
Chum salmon -3-155,3-1 56, 3- 1 59,
3-164
Clean Air Act - 3-231
Clean Water Act - 3-1 79, 3-191, 3-
230
clearcut with reserves - 3-63
clearcutting - 3-13, 3- 19, 3- 20, 3-
21.3- 29, 3- 30,3- 31,3-35,3- 36,
3-41,3-42,3-43,3- 56,3- 63,3-
64.3- 67, 3- 70,3- 83,3- 90,3- 91,
3- 94,3- 96,3- 120,3- 129,3- 130,
3- 131,3- 134,3- 135,3- 136,3-
137.3- 145,3- 147,3- 148,3- 149,
3- 151, 3- 168, 3- 173, 3- 175, 3-
192.3- 204,3- 227
Coastal Zone Management Act
(CZMA) • 3-231, 3-232
Coho salmon • 3-155, 3- 156, 3- 159,
3- 164
commercial fishing • 3-48, 3- 197, 3-
216.3- 217,3-218,3-220
Council on Environmental Quality
(CEQ) • 3-6
crab • 3-153, 3- 159
cultural resources • 3-222, 3- 233
cumulative effects • 3-3, 3- 4, 3- 6, 3-
24.3- 25,3-43,3-44,3- 55,3- 57,
3- 73,3- 84,3- 89,3- 90,3- 91,3-
92.3- 94,3- 95,3- 101,3- 107,3-
108.3- 131,3- 132,3- 133,3- 136,
3- 154, 3- 164, 3- 176, 3- 181, 3-
182.3- 184,3- 194,3- 198,3-207,
3-214,3-219,3-229
Dean Creek Watershed • 3-77, 3- 84,
3- 85,3- 88,3- 89,3- 91,3- 95,3-
101.3- 155,3- 164
decommissioned roads • 3-90, 3- 185
deer • 3-12, 3- 26, 3- 27, 3- 28, 3- 29,
3- 30,3- 31,3- 32,3- 33,3- 35,3-
36.3- 37,3-41,3-42,3-43,3-44,
3-47,3-48,3-49,3- 50,3- 51,3-
52.3- 55,3- 56,3- 57,3- 1 1 1,3-
112.3- 117,3- 119,3- 124,3- 125,
3- 128,3- 129,3- 133,3-217,3-
218, 3- 229, 3-234
deer habitat capability • 3-30, 3-31,
3- 32, 3-47,3-49,3- 52,3- 56,3-
57, 3- 125
38 • Chapter 4
Kuiu Project Area FEIS
deer winter habitat • 3-125
Deer, Sitka black-tailed deer • 3-26,
3- 27,3- 30,3- 33,3-49,3- 57,3-
118.3- 124
desired condition ■ 3-68, 3- 144, 3-
149.3- 199
desired future condition • 3-145, 3-
146.3- 198,3- 199,3-207
diversity ■ 3-145, 3- 146, 3- 150, 3-
151, 3- 196
Dolly Varden • 3-155, 3- 156, 3- 159,
3- 164
economics • 3-7, 3- 58, 3- 59, 3- 145,
3- 146, 3- 159
employment • 3-49, 3- 58, 3- 59, 3-
66.3- 69,3- 217,3- 218,3- 219
endangered species • 3-102, 3- 228
Environmental Protection Agency
(EPA)-3-6, 3- 164,3- 191,3-230
erosion • 3-71, 3- 89, 3- 166, 3- 167,
3- 168
Essential Fish Habitat (EFH) • 3-165,
3-218, 3-229, 3-230
estuary ■ 3-35, 3- 54, 3- 109, 3- 127,
3- 181,3- 211,3-218,3-222,3-
225
even-aged management ■ 3-56, 3- 63,
3- 129,3- 130,3- 131,3- 135,3-
147.3- 149,3- 150,3- 151,3- 227
F
Federal Cave Resource Protection
Act ■ 3-229
fish habitat • 3-53, 3- 71,3- 75, 3- 83,
3- 90,3- 91,3- 94,3- 95,3- 153,
3- 154,3- 155,3- 160,3- 161,3-
162.3- 163,3- 164,3- 168,3- 229,
3-230
fish passage • 3-83, 3- 89, 3- 157, 3-
158.3- 160,3- 161
fishing ■ 3-48, 3- 53, 3- 159, 3- 197,
3-210,3-211,3-212,3-213,3-
216.3- 217,3-218,3-219, 3- 222,
3-234
floodplain • 3-233
forest habitat • 3-34
forest health ■ 3- 1 49, 3- 1 50, 3- 1 5 1 ,
3-227
Forest Plan • 3-3, 3- 4, 3- 7, 3- 8, 3- 9,
3- 10,3- 11,3- 13,3- 14,3- 15,3-
16.3- 20,3- 24,3- 25,3-26,3- 30,
3- 31,3- 32,3- 34,3- 35,3- 36,3-
44.3- 47,3- 51,3- 53,3- 54,3- 56,
3- 57,3- 58, 3- 61,3- 66,3-67, 3-
References and Lists
68.3- 71,3- 72,3- 75,3- 83,3-
103.3- 104,3- 107, 3- 108,3-
109.3- 110,3- 117,3- 118,3- 119,
3- 124,3- 125,3- 126,3- 127,3-
129.3- 132,3- 133,3- 138,3- 140,
3- 143,3- 144,3- 147,3- 152,3-
154.3- 159,3- 165,3- 166,3- 168,
3- 175,3- 179,3- 182,3- 196,3-
197.3- 198,3- 199,3- 200, 3- 201,
3-202,3- 203, 3- 204,3-207,3-
208.3- 210,3- 216,3- 222,3- 227,
3- 228, 3- 229,3- 231,3- 233,3-
234
Forest Plan standards and guidelines •
3-4,3- 53,3- 103,3- 104,3- 110,
3- 157,3- 165,3- 182,3- 218,3-
227, 3- 229, 3-231, 3- 233, 3- 234
fragmentation • 34, 3- 107, 3- 110, 3-
138
furbearer • 3-55, 3-119
Game Management Unit (GMU) • 3-
27.3- 33,3- 52,3- 213
geology • 3-6, 3- 28, 3- 83, 3- 90, 3-
94.3- 96,3- 166
ground-based logging • 3-167, 3- 168
habitat capability ■ 3-31, 3- 32, 3- 52,
3- 56,3- 102,3- 119,3- 129,3-
130, 3- 154
helicopter logging -3-13
heritage resources • 3-7, 3-221, 3-
222, 3-223, 3-228
high value ■ 3-36, 3- 47, 3- 53, 3- 71,
3- 111,3- 112,3- 117,3- 119,3-
120.3- 128,3- 129,3- 130,3- 131,
3- 132, 3- 178, 3- 182
humpback whale • 3-103
hunter demand ■ 3-51, 3- 52, 3- 56, 3-
125
hunting • 12, 3- 19, 3- 20, 3-21,3-
22, 3- 27,3- 33,3- 36,3-41,3-
42.3- 43,3-48,3-49,3- 50,3- 51,
3- 55,3- 57,3- 126,3- 128,3- 186,
3- 197,3-210,3-211,3-212,3-
215.3- 219,3-225
hydrology • 3-84, 3- 233
income • 3-49, 3- 66, 3- 217, 3- 218,
3-219,3-234
Inventoried Roadless Area ■ 3-5, 3- 9,
3- 11,3- 22,3- 23,3-24
Kuiu Project Area FEIS
Chapter 4 • 39
4 References and Lists
j
job ■ 3-66
K
Kadakc Creek • 3-4, 3- 16, 3- 73, 3-
76, 3- 82, 3- 83, 3- 84, 3- 87, 3- 88,
3- 89, 3- 90,3- 91,3- 92,3-93,3-
94.3- 96,3- 154,3- 155,3- 161,3-
162.3- 163,3- 197,3- 200,3- 201,
3- 203,3- 204,3- 211
Kadake Creek Watershed • 3-4, 3- 73,
3- 82,3- 84,3- 87,3- 89,3- 91,3-
92, 3- 155
Kake, city of - 3-5, 3- 12, 3- 16, 3- 33,
3-47, 3-48,3-49,3- 51,3- 52,3-
55.3- 56,3- 57,3- 159,3- 216,3-
217, 3-218,3-219,3-221,3-
229, 3- 234
karst -3-16, 3- 106,3- 166,3-229
Kuiu Island • 3-3, 3- 5, 3- 6, 3- 9, 3-
10.3- 11,3- 12,3- 13,3- 14,3- 15,
3- 16,3- 19,3-21,3- 22,3- 24,3-
25.3- 26,3- 27,3- 31,3- 33,3-36,
3-41,3-42,3-43,3-44,3-47,3-
48.3- 49,3- 50,3- 51,3- 52,3- 53,
3- 55,3- 56,3- 57,3- 59,3- 61,3-
67.3- 68,3- 70,3- 71,3- 73,3- 74,
3- 75, 3- 77, 3- 78, 3- 79, 3- 80, 3-
81.3- 82,3- 84,3- 85,3- 87,3-
102.3- 103,3- 104,3- 105,3- 107,
3- 109,3- 110,3- 112,3- 118,3-
119.3- 123,3- 124,3- 125,3- 126,
3- 127,3- 128,3- 131,3- 132,3-
133.3- 137,3- 141,3- 143,3- 144,
3- 145,3- 146,3- 147,3- 151,3-
152.3- 154,3- 155,3- 156,3- 157,
3- 159,3- 164,3- 165,3- 166,3-
167.3- 169,3- 170,3- 171,3- 173,
3- 176, 3- 177, 3- 178, 3- 180, 3-
181.3- 184,3- 186,3- 188,3- 189,
3- 194,3- 195,3- 196,3- 197,3-
199, 3- 200, 3- 202, 3- 207, 3- 209,
3-210,3-211,3-212,3-213,3-
214.3- 215,3-217,3-218,3-219,
3-221,3- 222,3- 226,3- 227,3-
228, 3- 229, 3- 230, 3- 231, 3- 232,
3-233,3- 234,3- 235
Kupreanof Island • 3-5, 3-1 1, 3-12, 3-
47, 3-67, 3-118, 3-221
L
Land Use Designation (LUD) • 3-4,
3- 12,3- 25,3- 35,3- 77,3- 78,3-
79.3- 80,3- 1 12,3- 136,3- 138,3-
149, 3- 152, 3- 155, 3- 182, 3- 196,
3- 199, 3- 200,3- 201,3- 203,3-
204.3- 208,3-210
landslide • 3-72, 3- 75, 3- 76, 3- 83, 3-
85.3- 167,3- 168,3- 169,3- 170,
3- 173, 3- 174, 3- 175
large woody debris (LWD) • 3-75, 3-
84
log transfer facility (LTF) • 3-53, 3-
59, 3- 61, 3- 62, 3- 68, 3- 69, 3- 70,
3- 84, 3- 123, 3- 127, 3- 158, 3-
159.3- 160,3- 161,3- 164,3- 186,
3- 190,3- 191,3- 209,3- 211,3-
214.3- 219,3-228
logging camp ■ 3-55, 3- 128, 3- 133,
3- 191,3- 192,3- 209,3- 211,3-
219
logging system • 3-59, 3- 147
long-term productivity ■ 3-7
Management Indicator Species (MIS)
• 3-26,3-44,3- 53,3- 118,3- 119,
3- 124,3- 128,3- 131
management prescription • 3-152, 3-
198
marbled murrelet ■ 3-1 1 1, 3- 1 12, 3-
117.3- 138
marine environment • 3-156, 3- 158
marine mammal ■ 3-54, 3- 57, 3- 229
market demand • 3-61, 3- 65, 3- 70, 3-
149.3- 228
marten • 3-28, 3- 34, 3- 49, 3- 50, 3-
53.3- 111,3- 112,3- 117,3- 118,
3- 119,3- 120,3- 123,3- 124,3-
125.3- 128,3- 129,3- 130,3- 131,
3- 132
Mass Movement Index (MMI) ■ 3-28,
3- 59, 3- 90, 3- 92, 3- 94, 3- 96, 3-
167.3- 169,3- 170,3- 171,3- 173,
3- 174, 3- 175, 3- 176
mass wasting ■ 3-140, 3- 166
Memorandum of Understanding
(MOU)- 3-31, 3- 228, 3- 232
minerals • 3-222
mitigation • 3-7, 3- 53, 3- 166, 3- 230
Modified Landscape LUD ■ 3-9, 3-
210
monitoring • 3-7, 3- 31, 3- 125, 3-
148.3- 164,3- 227,3- 230,3-231
moose • 3-49, 3- 50, 3- 52, 3- 57, 3-
124
muskeg • 3-16, 3- 34, 3- 140, 3- 181
National Environmental Policy Act
(NEPA) • 3-6, 3- 58, 3- 59, 3- 67
40 • Chapter 4
Kuiu Project Area FEIS
National Forest Management Act
(NFMA) • 3-7, 3- 227
National Forest System Roads • 3-7,
3- 15,3- 19,3- 20,3- 21,3- 23,3-
25, 3- 44, 3- 62, 3- 76, 3- 83, 3- 84,
3- 89,3-90,3- 91,3- 92,3- 93,3-
94.3- 95,3- 96,3- 101,3- 111,3-
112.3- 117,3- 123,3- 128,3- 132,
3- 149,3- 158,3- 160,3- 161,3-
162.3- 163,3- 164,3- 166,3- 181,
3- 183,3- 184,3- 185,3- 186,3-
187.3- 188,3- 189,3- 190,3- 191,
3- 192, 3- 193, 3- 194, 3- 195
National Historic Preservation Act
(NHPA)-3-221,3- 228, 3- 232
National Register of Historic Places
(NRHP) ■ 3-221
NEPA Economics Analysis
Tool Residuals (NEAT_R) -3-58,
3- 62, 3- 63, 3- 66
Northern goshawk • 3-28, 3- 103, 3-
104.3- 107,3- 108,3- 111,3- 112,
3- 117,3- 118,3- 119,3- 138,3-
192
old-growth • 3-4, 3- 10, 3- 12, 3- 16,
3- 26,3-27, 3-28,3- 30, 3- 34,3-
35.3- 104,3- 107,3- 109, 3- 110,
3- 111,3- 112,3- 113,3- 115,3-
117, 3- 118, 3- 119, 3- 129, 3- 130,
3- 134, 3- 136, 3- 144, 3- 148, 3-
149.3- 150,3- 151,3- 152,3- 175,
3- 179,3- 192,3-200
old-growth habitat • 3-34, 3- 104, 3-
107.3- 111,3- 112,3- 117,3- 119,
3- 192
old-growth habitat reserves (OGR) •
3-109,3- 110,3- 111,3- 112,3-
117.3- 132,3- 138
Organized Village of Kake • 3-51, 3-
217.3- 221,3- 228,3-235
outfitters and guides ■ 3-186, 3- 21 1,
3-212,3-213,3-214,3-215
partial harvest • 3-13, 3- 20, 3- 30, 3-
33.3- 35,3- 36, 3-41,3-42,3-47,
3- 58, 3- 64, 3- 65, 3- 67, 3- 129, 3-
130.3- 132,3- 134,3- 135,3- 136,
3- 137,3- 148,3- 173,3- 174,3-
202, 3- 203, 3- 204
past timber harvest • 3-34
patch ■ 3-138
permit • 3-71, 3- 165, 3- 183, 3- 191,
3-213,3-226
References and Lists
Petersburg, city of • 3-4, 3- 5, 3- 6, 3-
12, 3- 27, 3- 48, 3- 49, 3- 57, 3- 60,
3- 65,3- 67,3- 105,3- 106,3- 109,
3- 140,3- 186,3- 187,3- 195,3-
215.3- 216,3-218, 3-219,3-221,
3- 229,3-235
pink salmon • 3-155, 3- 156, 3- 1 59
planning record • 3-3, 3- 6, 3- 8, 3-
12.3- 31,3- 33,3-43,3-48,3-49,
3- 58,3- 71,3- 72,3- 102,3- 104,
3- 105,3- 109,3- 118,3- 131,3-
137.3- 140,3- 154,3- 165,3- 167,
3- 178, 3- 196, 3- 197, 3- 209, 3-
216.3- 217,3-218,3- 227,3-228,
3- 229, 3- 232
Point Baker ■ 3-48, 3- 49, 3-216, 3-
218
preferred alternative • 3-108
productive forest • 3-60, 3-61,3-
140.3- 141,3- 142,3- 143,3- 144,
3- 174,3- 179
productive old growth (POG) • 3-16,
3- 26,3- 27,3- 28, 3- 29,3- 30,3-
34, 3- 35, 3- 42, 3- 43, 3- 44, 3- 47,
3- 108,3- 109,3- 110,3- 111,3-
112, 3- 117, 3- 132, 3- 134, 3- 136
proposed action • 3-6, 3- 10, 3- 30, 3-
57.3- 66, 3- 67,3- 83,3- 104,3-
150, 3- 165, 3- 176, 3- 184, 3- 194,
3- 209,3- 221,3-222,3- 229,3-
234
pruning ■ 3-30, 3- 35, 3- 44, 3- 131,
3- 145, 3- 147
public involvement • 3-4, 3- 67
purpose and need • 3-68
R
Record of Decision (ROD) ■ 3-10, 3-
25, 3- 44, 3- 56, 3- 65, 3- 84, 3- 86,
3- 87, 3- 89,3- 132
Recreation Opportunity Spectmm
(ROS)-3-209, 3-210, 3- 213
regeneration ■ 3-145, 3- 146, 3- 149,
3- 151, 3- 179, 3- 199
renewable resource • 3-7, 3- 48
reserve trees ■ 3-138, 3- 145, 3- 151
resident fish • 3-153, 3- 154
riparian area • 3-35, 3- 53, 3- 54, 3-
77.3- 78,3- 79,3- 80,3- 81,3- 82,
3- 84,3- 106,3- 107,3- 109,3-
118.3- 119,3- 127, 3- 132,3- 138,
3- 139,3- 143,3- 144,3- 148,3-
152, 3-218,3- 233,3-234
riparian management area (RMA) • 3-
109
Kuiu Project Area FEIS
Chapter 4 • 41
4 References and Lists
road construction • 3-4, 3- 9, 3- 10, 3-
13.3- 14,3- 15,3- 19,3-20, 3-21,
3- 22, 3- 23,3- 25,3- 53,3- 55,3-
58.3- 59,3- 69,3-96,3- 107, 3-
156.3- 160,3- 161,3- 162,3- 163,
3- 164,3- 166,3- 167,3- 168,3-
174.3- 175,3- 180,3- 181,3- 182,
3- 184,3- 186,3- 189,3- 192,3-
202, 3- 229
road maintenance • 3-83, 3- 89, 3-
164.3- 184,3- 186,3- 187,3- 192,
3- 194, 3- 195
Road Management Objective (RMO)
• 3-55,3- 126,3- 185,3- 186,3-
189.3- 215
roadless • 3-5, 3- 9, 3- 10,3- 11,3-
12.3- 13,3- 14, 3- 15,3- 16,3- 17,
3- 19,3- 20,3-21,3- 22,3-24,3-
25
Roadless Area Conservation Rule • 3-
10
roads • 3-4, 3- 7, 3- 9, 3- 10, 3- 1 1, 3-
12.3- 13,3- 14,3- 15,3- 19,3-20,
3-21,3- 22,3- 23,3-25,3- 33,3-
35.3- 36,3-41,3- 44,3- 53,3- 54,
3- 55,3- 58, 3- 59,3- 61,3- 62, 3-
65.3- 67,3- 68,3- 69,3- 71,3- 72,
3- 73,3- 74,3- 76,3- 77,3- 78,3-
79.3- 80,3- 81,3- 82,3- 83,3- 84,
3- 86,3- 87,3- 88,3- 89,3- 90,3-
91.3- 92,3- 93,3- 94,3- 95,3- 96,
3- 101,3- 105,3- 106,3- 107,3-
123.3- 124, 3- 126,3- 127,3- 128,
3- 129,3- 132,3- 133,3- 136,3-
138.3- 148,3- 155,3- 156,3- 157,
3- 158,3- 159,3- 160,3- 161,3-
162.3- 163,3- 164,3- 166,3- 167,
3- 168,3- 173,3- 174,3- 175,3-
176.3- 180,3- 181,3- 182,3- 183,
3- 184,3- 185,3- 186,3- 187,3-
188.3- 189,3- 192,3- 193,3- 194,
3- 195,3-202,3- 209,3-211,3-
212.3- 213,3- 214,3- 215,3-229,
3-233
Roads Rule ■ 3-228
Rowan Bay • 3-12, 3- 33, 3- 47, 3- 53,
3- 54,3- 59,3- 61,3- 62,3- 63,3-
69.3- 70,3- 71,3- 104,3- 119,3-
127.3- 159,3- 160,3- 164,3- 186,
3- 190,3- 191,3- 192,3- 197,3-
201, 3- 202, 3- 204, 3- 207, 3- 209,
3- 211,3- 214,3-222,3-228,3-
229
Rowan Creek Watershed • 3-81, 3-
82.3- 84,3- 89,3- 156
Saginaw Bay • 3-5, 3- 59, 3-61, 3-
62.3- 63,3-69,3- 70,3- 71,3-
156, 3- 159, 3- 160, 3- 164, 3- 178,
3- 186, 3- 190, 3- 191, 3- 197, 3-
201, 3- 202, 3- 203, 3- 204, 3- 209,
3-211,3- 213,3- 214,3- 222,3-
226, 3- 229
Saginaw Creek Watershed • 3-78, 3-
88.3- 91,3-92,3-95,3- 101,3-
156
salmon ■ 3-48, 3- 57, 3- 124, 3- 153,
3- 155,3- 156,3- 159,3- 161,3-
164.3- 216,3- 217,3- 218,3- 234
scenic quality • 3-146, 3- 197, 3- 202,
3- 203, 3- 204, 3- 207, 3- 208
Scenic Viewshed LUD • 3-9, 3-210
scoping • 3-3, 3- 47, 3- 58, 3- 72, 3-
166, 3- 184
second-growth • 3-35, 3- 44, 3- 128,
3- 131,3- 148,3- 149,3- 152
Security Creek • 3-4, 3- 73, 3- 76, 3-
80.3- 81,3- 84,3- 87,3- 88,3- 89,
3- 90,3- 91,3- 92,3-93,3- 94,3-
95.3- 96,3- 101,3- 154,3- 155,3-
160.3- 161,3- 162,3- 163,3- 164
Security Creek Watershed • 3-80, 3-
81.3- 84,3- 89,3- 95,3- 101,3-
155
sediment • 3-71, 3- 72, 3- 73, 3- 74, 3-
76.3- 77,3- 78,3- 79,3- 80,3- 81,
3- 82,3- 83,3- 84, 3- 87,3- 88,3-
89.3- 90,3- 91,3- 92,3- 93,3-95,
3- 101, 3- 153, 3- 154, 3- 156, 3-
161.3- 162,3- 163,3- 164,3- 165,
3- 176, 3- 231
Sediment Risk Analysis (SRA) • 3-
73.3- 74, 3- 76,3- 77,3- 78,3- 81,
3-82
Sediment Risk Index (SRI) • 3-74, 3-
76.3- 78,3- 80,3- 81,3- 82,3- 87,
3-88,3- 173
Semi-remote Recreation LUD -3-10
sensitive species -71,3- 102, 3- 104,
3- 107
shellfish • 3-48, 3- 53, 3- 57, 3- 71,
3- 153,3- 162,3- 163,3- 164,3-
229
shovel logging • 3-65
sightseeing • 3-21 1, 3- 212, 3- 213
significant restriction • 3-49, 3- 54, 3-
56.3- 57,3- 229
silvicultural prescription • 3-64, 3-
138.3- 144,3- 146,3- 147,3- 148,
3- 149,3- 175,3- 227
42 • Chapter 4
Kuiu Project Area FEIS
silvicultural system ■ 3-30, 3- 64, 3-
144, 3- 149
silviculture ■ 3-35, 3- 59, 3- 65, 3-
231
Sitka spruce • 3-140, 3- 141, 3- 227
soil • 3-7, 3- 64, 3- 71,3- 73, 3- 74, 3-
94.3- 141,3- 144,3- 147,3- 166,
3- 167,3- 168,3- 169,3- 173,3-
174.3- 176,3- 178,3- 179,3- 180,
3- 181,3-230,3- 231
Special Interest Area LUD -3-10
squiiTel, red • 3-109, 3- 1 18, 3- 119
State Historic Preservation Officer
(SHPO)-3-221,3- 228
steelhead trout • 3-155, 3- 156, 3-
159.3- 164
stream buffer • 3-53, 3- 192
stream class • 3-157, 3- 228
stream crossing • 3-53, 3- 71,3- 84,
3- 89, 3-91,3-92,3- 95,3- 101,3-
123.3- 157,3- 160,3- 161,3- 162,
3- 163,3- 193,3-233
subsistence • 3-5, 3- 12, 3- 16, 3- 26,
3- 27, 3- 33,3-48,3-49,3- 50,3-
51.3- 52,3- 53,3- 54,3- 55,3- 56,
3- 57,3- 119,3- 126,3- 186,3-
197.3- 216,3- 217,3- 218,3- 229,
3- 233,3- 234
sustained yield ■ 3-149
T
temporary road • 3-14, 3- 15, 3- 19, 3-
20.3- 21,3-22,3-23,3-24,3-44,
3- 61,3- 62,3- 65,3- 77, 3- 78,3-
80.3- 81,3- 82,3- 83,3- 84,3- 89,
3- 90,3- 91,3- 93,3- 94,3- 95,3-
96, 3- 123,3- 132,3- 157,3- 160,
3- 161, 3- 162, 3- 163, 3- 166, 3-
174.3- 175,3- 176,3- 180,3- 181,
3- 183, 3- 184, 3- 188, 3- 189, 3-
192.3- 193,3- 194,3- 195,3- 219,
3-233
temporary roads • 3-128, 3- 174, 3-
183, 3- 195
thinning ■ 3-30, 3- 33, 3- 35, 3- 44, 3-
84.3- 131,3- 144,3- 147,3- 149,
3- 152
timber economics • 3-219
timber harvest • 3-4, 3- 7, 3- 10, 3-
13.3- 14,3- 15,3- 19,3-20,3-21,
3- 22,3-23,3- 24,3-25,3-26,3-
27, 3- 29, 3- 32, 3- 34, 3- 35, 3- 43,
3-44,3-47,3- 52,3- 54,3- 56,3-
58.3- 59,3- 61,3- 64,3- 65,3- 66,
3- 67,3- 68,3- 69,3- 71,3- 73,3-
74.3- 76,3- 77,3- 78,3- 79,3- 81,
References and Lists
3- 82, 3- 83, 3- 84, 3- 85, 3- 87, 3-
89.3- 90,3-91,3-92,3- 93,3- 94,
3- 95,3- 96,3- 104,3- 107,3- 110,
3- 128,3- 131,3- 132,3- 138,3-
139, 3- 142,3- 144, 3- 146,3- 148,
3- 149,3- 151,3- 152,3- 156, 3-
158, 3- 160,3- 161,3- 163,3- 164,
3- 166,3- 167, 3- 168,3- 173,3-
174.3- 179,3- 180,3- 181,3- 182,
3- 183,3- 185,3- 187,3- 188,3-
189, 3- 190,3- 193,3- 194,3- 195,
3- 199, 3- 201, 3-202, 3-207, 3-
213.3- 214,3-215,3-216,3-219,
3- 222,3- 229,3-231,3- 232,3-
233
timber management • 3-14, 3- 56, 3-
112, 3-231
timber production • 3-7, 3- 59, 3- 141,
3- 143,3- 146,3- 179,3- 200,3-
208
Timber Production LUD • 3-4, 3- 9,
3- 12,3- 35,3- 68,3- 77,3- 78,3-
79.3- 80,3- 136,3- 199,3- 200,3-
201.3- 203,3- 204,3-208,3-210
timber sales ■ 3-60, 3- 65, 3- 70, 3-
143.3- 186
timber supply • 3-70, 3- 228
Tlingit • 3-16, 3-216, 3- 218, 3- 221,
3- 235
Tongass Land and Resource
Management Plan (Forest Plan) • 3-
3.3- 4, 3-7, 3-8, 3-9, 3- 10,3- 11,
3- 13,3- 14,3- 15,3- 16,3-20,3-
24.3- 25,3-26,3- 30,3- 31,3-32,
3- 34,3- 35,3- 36,3-44,3-47,3-
51.3- 53,3- 54, 3- 56,3- 57,3- 58,
3- 61,3- 66,3- 67,3-68,3- 71,3-
72.3- 75,3- 83,3- 103,3- 104,3-
107.3- 108, 3- 109,3- 110,3- 117,
3- 118,3- 119,3- 124,3- 125,3-
126.3- 127,3- 129,3- 132,3- 133,
3- 138,3- 140,3- 143,3- 144,3-
147.3- 152,3- 154,3- 159,3- 165,
3- 166,3- 168,3- 175,3- 179,3-
182.3- 185,3- 196,3- 197,3- 198,
3- 199,3-200,3-201,3-202, 3-
203, 3- 204, 3- 207, 3- 208, 3-210,
3-216,3- 222,3- 227,3-228,3-
229.3- 231,3- 233,3- 234
Tongass National Forest • 3-4, 3- 5, 3-
8, 3- 9, 3- 10,3- 25,3- 30,3- 58,3-
64, 3- 65, 3- 66, 3- 67, 3- 68, 3- 69,
3- 70,3- 71,3- 105,3- 137,3- 138,
3- 139, 3- 144, 3- 166, 3- 182, 3-
186.3- 196, 3-216,3- 227,3-228,
3-234
Kuiu Project Area FEIS
Chapter 4 • 43
4 References and Lists
Tongass Timber Reform Act (TTRA)
• 3-228
tourisqT 3-216,3-217,3-218,3-
219
trails • 3-123, 3- 198,3- 214
transportation • 3-48, 3- 59, 3- 88, 3-
124, 3- 126, 3- 128, 3- 140, 3- 157,
3- 159, 3- 160, 3- 176, 3- 183, 3-
185,3- 186,3- 190,3- 193,3- 194,
3-228
two-aged management • 3-63, 3- 147,
3- 150, 3- 151
U.S. Fish and Wildlife Service
(USFWS) • 3-31, 3- 102, 3- 103, 3-
109, 3- 1 10, 3- 124, 3- 126, 3- 127,
3- 137, 3-228
uneven-aged management ■ 3-63, 3-
67, 3- 147, 3- 152
unroaded • 3-10, 3- 1 1, 3- 13, 3- 17,
3- 22,3- 23,3- 24,3- 25,3- 68
Value Comparison Unit (VCU) • 3-5,
3-207
vegetation ■ 3-16, 3- 27, 3- 60, 3- 76,
3- 84,3- 85,3- 88,3- 89,3- 91,3-
92.3- 95,3- 124,3- 140,3- 141,3-
143, 3- 149,3- 153,3- 178,3- 179,
3- 180,3- 182,3- 187,3- 202,3-
204, 3- 207
viable population ■ 3-126
viewshed • 3-147, 3- 207, 3- 208
visual quality • 3-200, 3- 201
Visual Quality Objective (VQO) • 3-
196, 3- 199, 3- 200, 3- 202, 3- 203,
3- 204, 3- 205, 3- 207, 3- 208
visual resource • 3-199
volume class • 3-60, 3- 133, 3- 143
volume strata • 3-28, 3- 30, 3- 111, 3-
112.3- 117,3- 119,3- 143,3- 144
water quality • 3-7, 3- 53, 3- 83, 3-
89.3- 90,3-91,3- 94,3- 95,3-
154.3- 159, 3- 160,3- 161,3- 162,
3- 163, 3- 164, 3- 234
waterfowl • 3-48, 3- 54, 3- 55, 3- 57,
3- 124
watershed ■ 3-4, 3- 44, 3- 71,3- 72, 3-
73, 3- 74, 3- 75, 3- 76, 3- 77, 3- 78,
3- 79,3- 80,3- 81,3- 82,3- 83,3-
84.3- 85,3- 87,3- 88,3- 90,3- 91,
3- 92,3-93,3-94,3- 95,3-96,3-
101.3- 110,3- 111,3- 112,3- 117,
3- 131, 3- 144, 3- 147, 3- 154, 3-
156.3- 161,3- 162,3- 163,3- 164
Watershed #109-44-10370 -3-156
Watershed #109-45-10090 -3-156
western hemlock - 3-140, 3- 141, 3-
227
wetlands - 3-7, 3- 34, 3- 178, 3- 179,
3- 180,3- 181,3- 182,3-229,3-
231.3- 233
wilderness - 3-5, 3- 9, 3- 10, 3- 13, 3-
14.3- 16,3-24,3- 25,3- 105,3-
107.3- 109,3-219
Wildlife Analysis Area (WAA 5012)
- 3-5,3-26,3-28,3-29, 3- 30,3-
31.3- 32,3- 33,3- 35,3- 36,3-41,
3-42,3-43,3-44,3-47, 3-48,3-
49.3- 51,3- 52,3- 56,3- 57,3-
120.3- 123,3- 124,3- 125,3- 126,
3- 128,3- 131,3- 132,3- 134,3-
135, 3- 136, 3- 137
wildlife habitat • 3-26, 3- 35, 3- 56, 3-
68.3- 128,3- 131,3- 144,3- 145,
3- 146, 3- 147, 3- 148
wind disturbance • 3-148
windthrow • 3-144, 3- 148, 3- 167, 3-
169, 3- 227
winter habitat • 3-30, 3- 56, 3- 129,
3- 130,3- 131
winter range • 3-26, 3- 27, 3- 28, 3-
30.3- 31,3- 32,3- 33,3- 35,3- 36,
3-41,3-42,3-43,3-47, 3- 111,3-
112.3- 117,3- 133
wolf, Alexander Archipelago ■ 3-6, 3-
27.3- 33,3- 34,3- 50,3- 52,3-
118.3- 119,3- 124,3- 125,3- 126,
3- 128,3- 129,3- 133
woodpecker, hairy • 3-118
woodpecker, red-breasted sapsucker •
3-118
Wrangell, city of - 3-48, 3- 49, 3- 61,
3-69,3-216,3-218,3-219
yellow-cedar (Alaska yellow-cedar) •
3-66,3- 68,3- 140,3- 141,3- 148,
3- 149, 3- 227
44 • Chapter 4
Kuiu Project Area FEIS
Appendix A
Reasons for
Scheduling the
Environmental
Analysis of the Kuiu
Timber Sale
Appendix A
Table of Contents
Introduction 1
Why is Timber from the Tongass National Forest Being Offered for Sale? 2
How Does the Forest Service Develop Forecasts about Future Timber Market
Demand? 6
What Steps Must Be Completed to Prepare a Sale for Offer? 9
How Does the Forest Service Maintain an Orderly and Predictable Timber Sale
Program? 10
How Does the Forest Service Decide Where Timber Harvest Projects should
be Located? 14
Conclusion 19
References 20
Reasons for Scheduling the
Environmental Analysis of the
Kuiu Timber Sale Project Area
Introduction
This appendix provides an explanation of the rationale for a specific
timber harvest project and its importance to the multi-year timber
program on the Tongass National Forest. To accomplish this, the
following questions are answered:
• 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?
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 indusiry. 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.
Kuiu Timber Sale FEIS
Appendix A • 1
Appendix A
National Legislation
Alaska-Specific
Legislation
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 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
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):
2 • Appendix A
Kuiu Timber Sale FEIS
Appendix A
Tongass National
Forest Land and
Resource
Management Plan
(Forest Plan, as
amended)
“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 Record of Decision for the Tongass Land Management Plan
Revision (Forest Plan) was signed by the Alaska Regional Forester in
1997. The Forest Plan incorporated new resource information and
scientific studies and reflected an extensive public involvement process.
There was direction to supplement the 1997 Final EIS to evaluate and
consider roadless areas within the Tongass for recommendation as
potential wilderness areas as part of the March 2001 US District Court
decision on litigation on the 1997 Forest Plan. The Record of Decision
for the Supplemental Environmental Impact Statement was signed in
February 2003. The No-action Alternative was selected; no additional
lands were recommended for Wilderness designation and no changes
were made to the Land Use Designations (LUDs) from the 1997 Record
of Decision. The 1997 Forest Plan defines appropriate activities within
each LUD. Approximately 74 percent of the Tongass is allocated to
LUDs where commercial timber harvest is not allowed.
Amendments have been made to the 1997 Forest Plan, primarily to
modify small Old-growth Habitat Reserves to meet Forest Plan criteria.
These amendments have been accomplished through environmental
analysis and are documented in decision documents. Due to those
modifications, LUDs in certain areas have changed from development
LUDs that allow timber harvest to Old-growth Habitat LUD or changed
from the Old-growth Habitat LUD to development LUDs. Since the
plan was signed in 1997, these amendments have affected two percent of
the acres designated as suitable commercial timber by re-designating
them as Old-growth Habitat LUD where timber harvest is not allowed.
The effects to resources in the Final EIS for the 1997 Forest Plan were
analyzed as if the full timber harvest allowed under each alternative
would occur over the next decade and into the future. In that way, the
Forest Plan analysis displayed the maximum environmental effects that
could be reasonably foreseen. Since substantially less timber volume
and acres have been harvested since the 1997 Forest Plan revision than
was analyzed, the effects on resources are expected to be less than
projected in the 1997 Final EIS. The environmental effects analysis in
the Forest Plan projected that up to 267 MMBF and 10,200 acres could
be harvested per year based on the suitable forest lands where timber
Kuiu Timber Sale FEIS
Appendix A • 3
Appendix A
harvest is compatible with the Forest Plan Land Use Designations.
Forest Plan monitoring indicates that average annual harvest has been
considerably less than that amount (Figure A-1).
Figure A-1
Tongass Timber Harvest, 1998-2006
160
140
120
100
80
60
40
20
0
1998 1999 2000 2001 2002 2003 2004 2005 2006
145.8 146.8
■ l?J.O
4LS 50J 460 49J ■.
33.8
—
T ' ' 1 * 1 ' 1 * ' 1 * 1—* ' 1 ^ 1 ■ 1
□ Timber Harvest - mmbf per year
On August 5, 2005, the Ninth Circuit Court of Appeals ruled that a
misinterpretation of the Brooks and Haynes 1997 draft timber demand
projections rendered the 1997 Record of Decision for the Tongass Land
Management Plan Revision arbitrary and capricious. The court of
appeals remanded the matter for further proceedings consistent with the
court's opinion {Natural Resources Defense Council v. U.S. Forest
Service). The process of remedying the shortcomings identified by the
court of appeals is in progress with a Forest Plan Amendment Draft EIS
released in January 2007. However, there are lengthy time periods
involved in clearing timber volume through the NEPA, administrative
appeals and litigation processes. Clearing a timber sale project through
the NEPA process is an important step in the process the Alaska Region
uses to comply with this mandate. Delaying the completion of this and
other site-specific projects until after a decision on the Forest Plan
Amendment is made would undermine the Forest Service’s ability to
keep an even-flow of economical timber supply. This project will be
reviewed for consistency with the decision on the Forest Plan
Amendment.
Allowable Sale Quantity (ASQ)
The ASQ serves as an upper limit on the amount of timber that may be
offered for sale each decade as part of the regularly scheduled timber
sale program. The Record of Decision for the 1997 Forest Plan states:
“The maximum amount of timber that could be harvested
(Allowable Sale Quantity or ASQ) during the first decade of the
Forest Plan implementation is an average of 267 MMBF per year. A
timber volume level less than the ASQ is likely to be offered over
4 • Appendix A
Kuiu Timber Sale FEIS
Appendix A
Roadless Area
Conservation Rule
the next few years, given current market conditions, the transition
that both the timber industry and the Forest Service are experiencing,
and the current amount of appeals and litigation.
The ASQ is the maximum amount of sustainable timber harvest on
suitable forest lands allocated to development by the Forest Plan, in
accordance with its standards and guidelines and management direction.
It consists of two separate Non-Interchangeable Components (NICs)
called NIC I and NIC II. The NIC I component includes lands that can
be harvested with normal logging systems including helicopter logging
with less than V4 mile yarding distance. The NIC II component includes
land that has high logging costs due to isolation or special equipment
requirements. Most of these NIC II lands are presently considered
economically and technically marginal.
There are two purposes of partitioning the ASQ into two components:
(1) to maintain the economic sustainability of the timber resource by
preventing the over-harvest of the best operable ground, and (2) to
identify that portion of the timber supply that may not be harvested
because of marginal economic conditions.
With regard to timber production sustainability, the Record of Decision
for the 1997 Forest Plan further states;
“The timber resource will be managed for production of sawtimber
and other wood products from timberlands available for sustainable
timber harvest, on an even-flow, sustained-yield basis and in an
economically efficient manner. The Tongass National Forest will
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.
The Tongass National Forest will continue to allow timber harvest
while maintaining sustained yield and multiple-use goals. The
forest-wide standards and guidelines for timber include general
direction to “[ejnsure that silvicultural systems other than
clearcutting are considered through an appropriate project level
analysis process.” However, uneven-aged management systems will
be limited to areas where yarding equipment suited to selective
logging can be used.
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 Area Conservation Rule (1/12/2001) has been the subject
of several lawsuits. In the most recent ruling (9/20/06), the court re-
instituted the rule as it appears in the 2004 version of 36 CFR Parts 200
to 299. The rule in effect includes the text at 294.14(d): "this subpart
does not apply to road construction, road reconstruction, or the cutting.
Kuiu Timber Sale FEIS
Appendix A • 5
Appendix A
Annual Market
Demand
sale or removal of timber in inventoried roadless areas on the Tongass
National Forest".
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
Tongass National Forest makes two detenninations on volume to be
offered. The first, “annual market demand” is an estimate on volume to
be offered for the current year, based on a forecast of annual timber
market demand. The second is “planning cycle market demand”
forecasts potential timber volume needs over the life of the Forest Plan.
Annual market demand is analogous to assessing industry performance
in the short-tenn. The general approach is to consider the timber
requirements of the region’s sawmills at different levels of operation and
under different assumptions about market conditions and technical
processing capability.
The annual market demand forecast is a methodology used to set the
short-term goals for the Tongass timber sale program - it is the projected
volume of Tongass timber needed to meet annual market demand. The
estimated annual market demand is the volume the Forest plans to offer
for sale in the current year pending sufficient funding.
The reports Responding to the Market Demand for Tongass Timber
(Morse, 2000) and Tongass National Forest Timber Sale Procedures
(Morse, 2000a) document the formulas and procedures used in
forecasting annual market demand. The Morse methodology originally
used the projected harvest from the final 1997 Brooks and Haynes
report. CuiTcntly calculations of the annual demand use the annual
projected harvest from Brackley 2006 as one of the inputs. In addition,
the methodology is self-correcting based on actual experience and
considers such factors as mill capacity, utilization, and volume under
contract. To the extent that actual harvest is lower than projected
harvest, the inventory of timber under contract builds up and the demand
for new timber decreases, as long as economic volume is available. The
procedures are designed to be flexible given the uncertainty associated
with forecasting market conditions. This is especially difficult in
Southeast Alaska because of the structural transformation underway in
the timber industry. The methodology accounts for the fact that the
6 • Appendix A
Kuiu Timber Sale FEIS
Appendix A
Market Demand for
the Planning Cycle
Forest Service timber sale program cannot quickly respond to market
fluctuations, and allows the industry to accumulate adequate volume
under contract. The methodology includes provisions to monitor
industry behavior and includes ways to adjust timber sale program levels
to reflect harvest activity with some specific criteria for action. These
assumptions provide a basis for estimating the volume of timber likely
to be processed by the industry as a whole in any given year. The
volume of timber likely to be purchased is equal to the volume needed to
make up any inventory shortfall in addition to the volume likely to be
harvested in the coming year.
To keep the annual demand current, the timber sale plan is updated each
fiscal year for each ranger district, whereby the current year is dropped
at the end of the fiscal year and a new year is added. These plans from
the ranger districts are then consolidated into the Tongass Timber Sale
Plan. In the past, the Tongass prepared a 10-year timber sale plan. For
several reasons, the Tongass now uses a 5-year timber sale plan, which
is consistent with Forest Service Manual 2430. These reasons include
the difficulty to project changing market conditions, the outcome of
timber harvest decisions affected by litigation, the time it will take to
remedy the Forest Plan to be consistent with the court’s opinion
{Natural Resources Defense Council v. U.S. Forest Service) and the
completion of the amendment to the Forest Plan currently in progress.
This 5-year plan is based on completed and ongoing environmental
analyses and will contain more-accurate information to purchasers and
provide a plan that is easier to adjust in response to changing market
conditions.
The volume that needs to be offered to meet the “annual market
demand” for FY 07 is projected to be 131 MMBF. This figure was
calculated using the Brackley 2006 “expanded lumber scenario” which
allows for sufficient timber volume for the existing Southeast Alaska
sawmills to operate efficiently. The spreadsheet displaying how this
demand is ealculated 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.
There have been a number of “planning cycle market demand” analyses
prepared for Tongass timber program, including three series prepared by
Brooks and Haynes (1990, 1994, and 1997) for the Forest Service’s
Pacific Northwest Research (PNW) Station that are the 1997 demand
projections were used in the preparing the 1997 Tongass Forest Plan.
Kuiu Timber Sale FEIS
Appendix A • 7
Appendix A
An update of the “planning cycle market demand” assessment by Brooks
and Haynes (1997) was requested from the US Forest Service. In 2006,
the PN'W Research Station published new harvest projections (Brackley
et al. 2006). The Brackley 2006 projections contain four scenarios, as
opposed to the three in Brooks and Haynes ( 1 997). These four
scenarios include: 1) limited lumber production which represents the
current situation where timber supply is limited; 2) expanded lumber
production which represents the current industry in southeast Alaska
operating without the current supply limitations; 3) medium integrated
industry which represents an expansion of the current industry capacity
and better utilization of forest products removed from public timber
sales; and 4) high integrated industry which represents full utilization of
forest products. More information about these scenarios is in the Forest
Plan Amendment Draft EIS (January 2007).
The 2006 projections did not require changes to the basic methodology
from the procedure outlined in Morse (2000a) except to use the
projections from Brackley, 2006 rather than the 1997 Brooks and
Haynes projections (Alexander, 2006).
Table A-1. Projected Tongass National Forest Timber Harvest — in
Million Board Feet (MMBF); (Alexander, 2006')
Year
1- Limited
lumber
scenario
2 - Expanded
lumber
scenario
3 -Medium
integrated
scenario
4 - High
integrated
scenario
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
8 • Appendix A
Kuiu Timber Sale FEIS
Appendix A
Annualized calculation to fulfill derived demand scenarios from Brackley et al.
(2006). This table was created using amiualized values provided by Dr. Allen
Brackley (personal communication, Nov 29 2006) from the model used to develop
derived demand estimates in Brackley et al. (2006a). 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
Both the “annual market demand” and the “planning cyele 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 infomiation 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.
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 for a much longer timeframe,
often doubling the desired time frame.
Kuiu Timber Sale FEIS
Appendix A • 9
Appendix A
Pools of Timber
(Pipeline Volume)
Gate 3 - Preparation of a Timber Sale
During this step, the information and direction included in the decision
docunlent 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 confonn 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.
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
process (Forest Service Handbook 2409.18). From a timber sale
program standpoint, it is also necessary to track and manage multiple
projects through a “pipeline” of time as projects collectively 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
10* Appendix A
Kuiu Timber Sale FEIS
Appendix A
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. Refer to Table A-2, which displays the
current estimated volume in each pool, as well as the goal for volume to
be maintained in each pool, based on historic patterns. Based on historic
patterns, the Tongass has established a goal for the volume to be
maintained in each of the timber pools. 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.
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.
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. Volume in appeals and litigation is tracked as a subset of
this pool as necessary (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.
Kuiu Timber Sale FEIS
Appendix A *11
Appendix A
Pool 2 - Timber Volume Available for Sale (Gates 3, 4 and 5)
Timber volume available for sale ineludes sales for whieh environmental
analysis has been eompleted, and have had any administrative appeals
and litigation resolved. Enough volume in this pool is needed to be
maintained to be able to sehedule future sale offerings of the size and
eonfiguration that best meets market needs in an orderly manner.
As a matter of poliey and sound business practiee, the Forest Service
announces probable future sale offerings through the Periodic Timber
Sale Announcement. Recent delays at Gate 2 have affected sale
preparation and have made scheduling 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.
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 cuiTent 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. Analysis of Tongass timber sales
indicates an average sale length of about 6 years due to modifications in
the contracts due to 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
12 • Appendix A
Kuiu Timber Sale FEIS
Appendix A
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.
Table A-2
Accomplishments in Gate System and Timber Pools (MMBF)
Pipeline Pool Volume
2007 Goal
FY 07 (as of
1/1/07)
Pool 1
Volume Under Analysis
(Gates 1 and 2)
279'
350
Pool 2
Volume Available for Sale
(Gates 3, Gate 4 and Gate 5)
792
304^
Pool 3
Volume Under Contract
(Gate 6)
186“
0
0
The goal for volume under analysis is approximately 4.5 times the projected harvest
for the current year (61.9 MMBF for 2007 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 (6 1 .9 MMBF) in sales that have approved NEPA and
completion of timber sale preparation.
^ Includes volume from sales mutually cancelled under the provision of the 2004
Appropriations Act (Sec. 339). However, most of this volume appraises deficit under
current market conditions and can not be offered for sate under Congressional direction
in the 2006 Appropriations Act (Public Law 109-54, Sec. 416). Does not include
volume under litigation - see Table A-3.
The goal for volume under contract is for purchasers to have 3 times the volume
under contract as projected for harvest for the cuiTent year (61 .9 MMBF).
^ Estimated volume under contract available for harvest (not including timber enjoined
from harvest or sales that have had mutual cancellation requests granted).
Kuiu Timber Sale FEIS
Appendix A • 13
Appendix A
How Appeals and
Litigation Affect the
Timber Sale
Program
Timber Resource
Land Suitability
Timber harvest projeets require site-speeifie environmental analysis that
usually is doeumented in an environmental assessment (EA) or an
environmental impaet 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.
Table A-3
Timber Volume Involved in Appeals and/or Litigation^
Timber volume remanded on appeals 23 MMBF
Timber volume involved with litigation 35.2 MMBF
' As of May 23, 2007 - date of Settlement Agreement with NRDC.
2
Remanded - Decision overturned during internal review. Does not include volume m
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 1997 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 Forest Plan,
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 1997
14* Appendix A
Kuiu Timber Sale FEIS
Appendix A
Forest Plan, the remainder of the land, approximately 96 percent, does
not allow, is not scheduled, or is not physically suitable.
Figure A-2
1997 Forest Plan Timber Resource Suitability Analysis
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 infomiation 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.
District-Level The Tongass National Forest is divided into ten ranger distriets. For
Planning planning and scheduling purposes, the Allowable Sale Quantity (ASQ)
has been allocated to the ranger districts based on the Forest Plan
modeling (FORPLAN) results of suitable and available acreage. The
average annual distribution of the full Forest Plan ASQ by ranger
Kuiu Timber Sale FEIS
Appendix A • 15
Appendix A
districts is displayed in Tabic A-4 (all volumes are identified as sawlog
plus utility).
Table A-4
Annual Distribution of Forest Plan Allowable Sale Quantity
(mmbf) by District
Ranger District
Non-Interchangeable
Component (NIC)*
NIC I
NIC II
Ketchikan/Misty Fiords
32
7
Thorne Bay
42
9
Craig
33
7
Wrangell
28
6
Petersburg
50
9
Sitka
17
4
Hoonah
7
2
Juneau
7
2
Yakutat
4
1
Admiralty National Monument
0
0
NIC Totals
220
47
ASQ Total(mnibf)
267
' NIC I component - lands that can be harvested with normal logging systems
including helicopter logging with less than % mile yarding distance.
NIC II component - includes land that has higher logging costs due to isolation or
special equipment requirements.
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.
The District Rangers to develop a timber sale plan of the potential
timber harvest projects. This plan aims to attain the prescribed 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 in this plan is based, to the extent
possible, on the forecasted annual market demand. Demand may
fluctuate from year to year but recent years have shown little change in
the annual demand projection. Offerings may vary from year to year but
16* Appendix A
Kuiu Timber Sale FEIS
Appendix A
recently they have been in the low market scenario range, as determined
by the projected annual demand.
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.
Considerations the District Ranger takes into account for each project
include:
• The project area contains a sufficient number of suitable timber
production acres allocated to development land use designations.
Available information should indicate that the timber volume being
considered for harvest can be achieved while meeting Forest Plan
goals, objectives, standards and guidelines.
• Other resource use and potential future uses of the area and of
adjacent areas and of non-National Forest lands.
• Areas where the investment necessary for project infrastructure
(roads, bridges, etc.) is achievable with the estimated value of timber
in the project area. Where infrastructure already exists, the project
would allow any maintenance and upgrade of facilities necessary for
removal of timber volume.
• Area 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
Kuiu Timber Sale FEIS
Appendix A • 17
Appendix A
How Does This
Project Fit into the
Tongass Timber
Program?
Why is This Project
Occurring in This
Location?
sales in proximity to timber proeessing faeilities. Timber sale projeets
seheduled for the current year that are not implemented, or the
remaifiing volume of sales 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.
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
1997 Forest Plan and Record of Decision. Based on current year and
anticipated future timber volume demand and the timber supply
provisions of the Tongass Timber Reform Act, the analysis of the Kuiu
Timber Sale is prudent at this time to meet timber sale needs as included
on the approved multiple-year timber sale plan. The anticipated budget
allocations and the availability of resources are sufficient to prepare and
offer this project for sale as scheduled.
This project is currently in Gate 2, Project Analysis. The amount of
volume considered for harvest under the action alternatives ranges from
14.1 MMBF to 41 .4MMBF, which 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 described in the Pools of Timber section of this appendix, the volume
of timber needed to maintain Pool 1 is 4.5 times the amount of the
projected harvest to account for projects at varying stages of analysis for
that year. As displayed in Table A-2, the goal for volume under analysis
is 589 MMBF. Currently, the forest-wide volume under analysis (Pool
1) is about 490 MMBF and includes the volume for this project. This
project contributes to timber sale program planning objectives to meet
the goal of providing an orderly flow of timber from the Tongass on a
sustained yield basis to meet timber supply requirements. It is
reasonable to be conducting the environmental analysis for this project
at this time. The timber volume from this project is currently proposed
for offer in Fiscal Year 2008.
As explained above, timber harvest project areas are selected for
environmental analysis for a variety of reasons. The reasons this project
is being considered in this area include;
• The area is identified in the Forest Plan as Timber Production LUD.
• The Kuiu Timber Sale 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
18* Appendix A
Kuiu Timber Sale FEIS
Appendix A
each planning cycle, pursuant to Section 101 of the Tongass Timber
Reform Act (TTRA).
• Providing substantially less timber volume than required to meet
Forest Plan and TTRA Section 101 timber supply and employment
objectives in order avoid harvest in the project area is not necessary
or reasonable.
• There is an existing road system. Some new NFS and temporary road
would be required to access timber.
• There are two LTFs with the associated sort yards available for log
transfer. The Rowan Bay LTF would require no upgrading and the
Saginaw Bay LTF would require some reconstruction, including the
development of a low angle barge ramp.
Effects on subsistence resources from timber harvest Tongass- wide 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 would be expected to have greater potential
effects on subsistence resources because of the relatively low level of
subsistence harvest in this project area. Harvest within other areas is
foreseeable under the Forest Plan.
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 National Forest Organic Act
provides that national forests may be established “to improve and
protect the forest within the boundaries of, or for the purposes 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
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.”
In addition to nationwide statutes. Section 101 of the Tongass Timber
Refonn 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
Kuiu Timber Sale FEIS
Appendix A • 19
Appendix A
amount of timber offered for sale eaeh year is based on the objeetive of
offering enough volume for sale to meet the projeeted 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-temi 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. This project could supply from
9.6 MMBF to 33.4 MMBF of volume for sale, with harvest potentially
beginning in 2008.
References
Alexander, S. in preparation. Tongass National Forest Timber Sale
Procedures: Using Information about Market Demand to Schedule FY
2006 Timber Offerings (Draft). USDA Forest Service Region 10,
Juneau AK. xx 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.
Brooks, D.J.; Haynes, R.W. 1997. Timber products output and timber
harvests in Alaska: projections for 1997-2010. Gen. Tech. Rep. PNW-
GTR-409. Portland, OR: U.S. Department of Agriculture, Forest
Service, Pacific Northwest Research Station. 17 p.
Morse, K.S. 2000. Responding to the Market Demand for Tongass
Timber: using adaptive management to implement Sec. 101 of the 1990
Tongass Timber Reform Act. Manag. Bull. RlO-MB-413. Juneau, AK:
U.S. Department of Agriculture, Forest Service, Alaska Region. 43 p.
Morse, K.S. 2000a. Tongass National Forest Timber Sale Procedures:
Using Infomiation about Market Demand to Schedule FY 2001 Timber
Offerings. USDA Forest Service Region 10, Juneau AK. 17 p.
USDA Forest Service, Forest Plan Amendment Draft Environmental
Impact Statement, January 2006.
20 • Appendix A
Kuiu Timber Sale FEIS
Appendix B
Activity Cards
Appendix B
Table of Contents
Introduction to Appendix B 1
Unit Card Header Information 1
Harvest Treatments 2
Resource Concerns and Responses 4
Unit Cards 1 1
Road Cards 95
Road Management Objectives 97
Introduction to Appendix B
Activity 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. Both narratives and maps showing site-specific information
are provided.
The introduction to Appendix B is followed by a narrative card and a
map for each proposed harvest unit. These units are in numerical
order. Not every unit is in each alternative. The maps show all
proposed adjacent units whether or not they are in the same
alternatives. Figure B-1 shows all the units as they lie in the project
area.
The last section of this Appendix lists existing and proposed NFS
roads used for the alternatives. It describes the current conditions and
management objectives, and proposed road management objective
changes. The Introduction to the Road Cards explains the terminology
used for the Road Management Objeetive narrative. A map is included
that shows all the roads and their desired future management.
Unit Card Header Information
Each unit card has a header block with information used to generally
describe the stand’s size, location, and volume proposed for harvest.
Each header block contains the following information:
Unit Number: This is the number assigned to the unit block during
the Logging Systems and Transportation Analysis development.
Unit Acres: This is an estimate of total aeres within the unit using
aerial photos and GIS information.
Alternatives: This identifies the altemative(s) in whieh the unit is
proposed.
Aerial Photo: This is the identification number of the most reeent
aerial photograph taken during 1998-99.
Kuiu Timber Sale FEIS
Appendix B • 1
Unit Cards
Land Use Designation (LUD): Land Use Designation is a defined
area of land, identified by the Forest Plan, to which specific
management direction is applied. All proposed units are in the Timber
Production LUD.
Net Timber Volume: This is an estimated volume in thousand board
feet to be harvested. This was derived from field estimates and the
stand exam program. A cruise will be done during implementation to
detennine an accurate volume before the timber is sold.
TM Compartment and Stand: This identifier is used for tracking
purposes from planning through implementation and future treatments.
Volume Strata Acres: This is the approximate number of acres
broken out by volume strata. Three volume strata (high, medium, and
low) are recognized in the Forest Plan and explained in the Timber and
Vegetation section of Chapter 3.
Existing Stand Condition: This is the developmental stage of the
physical and temporal distribution of trees and other plants in a
forested area.
Silvicultural Prescription: This provides infonnation about the
methods, techniques, timing, and monitoring of vegetative treatments.
The detailed silvicultural prescription is in the planning record.
Logging Method/Transportation: This identifies the method of
logging in the unit and the transportation used.
Harvest Treatments
Even-aged
Management,
Clearcut
Two-aged
Management
Silvicultural prescriptions include these unit cards plus the sale layout
and marking guidelines that would be completed for each of the timber
harvest units that are included in the Kuiu Timber Sale Area Record of
Decision. Minor changes can be expected during implementation to
better meet on-site resource management and protection objectives.
Minor adjustments to unit boundaries are also likely during final
layout for the purpose of improving logging system efficiency or for
site conditions.
All merchantable trees will be harvested. The objectives of this system
are to create a fast-growing stand of trees to maximize wood fiber
production, favorable timber sale harvest economics and logging
feasibility. These stands would regenerate into a mostly single-aged
stand.
This system regenerates and maintains a stand with two age classes by
removing trees in clumps or as individual trees. Reserves or clumps
would be distributed somewhat evenly across the harvest unit or stand,
and away from the unit boundary. The resulting stand may be two-
2 • Appendix B
Kuiu Timber Sale FEIS
Unit Cards
Uneven-aged
Management
aged or trend toward the uneven-aged condition as a consequence of
both an extended period of regeneration establishment and retention of
reserve trees that may represent one or more age classes. Two-aged
management regimes can produce stands of greater structural diversity
than even-aged management. These stands would not be reentered for
harvest until the next rotation in approximately 100 years.
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. Uneven-aged management maintains or creates 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
would be in approximately 75 years, when approximately 25 percent
of the stand’s pre-harvest basal area would be removed in patches or in
single trees.
Group Selection
Stands proposed for this prescription would have approximately 50
percent of the area remaining uncut after harvest. Merchantable trees
(trees greater than 9 inches in diameter) would be harvested in small
patches to form a mosaic of irregularly shaped openings within the
stand. Smaller trees may be left in this area if the larger trees can be
safely removed. Each group harvested would consist of a mixture of
tree sizes. Each harvested opening will regenerate, creating a patch of
trees with a uniform age and height. These openings may be thinned.
This will create a stand of three or more distinct size classes in small
groups, resulting in an uneven-aged stand.
Single Tree Selection
Stands proposed for this prescription would have approximately 50
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 using a criterion such as species, diameter
limits or spacing. A range of diameters, or everything above or below
a certain diameter limit, may define the trees selected for harvest.
Different diameters may be used for different species. The resulting
stand may have small openings plus individual trees harvested
throughout the stand. This will maintain or create a stand of three or
more distinct size classes distributed throughout the stand, resulting in
an uneven-aged stand.
Kuiu Timber Sale FEIS
Appendix B • 3
Unit Cards
Resource Concerns and Responses
In the Kuiu Timber Sale Area, most of the economic, wildlife, and
watershed concerns are mitigated with the silvicultural system. Other
resource concerns, such as soils, scenery, and fisheries, are mitigated
by unit design and adherence to Forest Plan standards and guidelines
and Best Management Practices (BMPs).
Riparian Management Areas
Forest Plan Standards and Guidelines and BMP 12.6 direct the design
of Riparian Management Areas (RMAs) associated with each stream
in the Project Area. The Standards and Guidelines prohibit
programmed commercial timber harvest in RMAs associated with all
Class I, Class II, and most Class III streams, except for right-of-way
clearing for road construction.
RMAs vary in width from the edge of the stream channel according to
process group (Table B-1) and stream value class (Table B-2). All
Class I and Class II streams are protected from commercial timber
harvest within a minimum horizontal distance of 1 00 feet from the
bankfull margins. Depending on the channel type, RMA widths can be
up to 140 feet wide on either side of some Class I, Class II, and Class
III streams. RMAs adjacent to Class III streams are protected from
commercial timber harvest, except along palustrine channel types.
RMA widths on Class III streams are extended to the side-slope break
(top of the V-notch).
Unit card maps show the location of all streams, numbered for
reference, and the associated RMAs. RMA widths for each Class I,
Class II, and Class III stream are described in the unit card narratives.
Windthrow concerns within riparian buffers are addressed in the unit
card narratives. Riparian buffers on south facing slopes in units with a
prescription other than uneven-aged management by single tree
selection would be protected by retaining additional trees adjacent to
the buffers. In units with a two-aged, clearcut with reserves or uneven-
aged, group selection prescription, some of the retention would be
along the riparian buffers. In units with uneven-aged, single tree
selection prescriptions, the distribution of trees across the unit would
help protect the buffers. In units with an even-aged prescription, the
windthrow prone buffers would be protected by feathering the edge for
a distance of 50 horizontal feet where trees are less than 16 inches
DBH. Those trees than cannot be felled away from the buffer, would
be retained.
Log yarding practices are based on slope stability, soil disturbance,
channel type, and stream class. Additional measures are taken to
4 • Appendix B
Kuiu Timber Sale FEIS
Unit Cards
protect RMAs from possible disturbance associated with tree felling
and yarding. Harvest activities near Class I, Class II, and Class III
streams require that trees be felled away from the stream and that trees
yarded across or along stream courses be fully suspended to minimize
the exposure of mineral soil. Trees near Class IV streams are felled
away from the stream whenever feasible and logging debris introduced
into Class IV streams is removed. Class IV streams are treated as part
of the hillside, under slope stability standards and guidelines. The
objective is to minimize soil erosion, mass movement, and formation
of new channels.
Best Management Practices
The following Best Management Practices (BMPs) would be applied
in order to protect water quality in the project area as specified in the
Forest Plan (pages C-1 to C-3). The BMPs are cited on the Unit Cards
and Road Cards where appropriate. Not all BMPs apply to every
situation.
BMP 12.6 (Riparian Area Designation and Protection) - To
identify riparian areas and their associated management activities.
BMP 12.6a (Buffer Design and Layout) - To design streamside
buffers to meet objectives defined during the implementation of BMP
12.6.
BMP 12.17 (Revegetation of Disturbed Areas) - To provide ground
cover to minimize soil erosion.
BMP 13.5 (Identification and Avoidance of Unstable Areas) - To
avoid triggering mass movements and resultant erosion and
sedimentation by excluding unstable areas from timber harvest.
BMP 13.9 (Determining Guidelines for Yarding Operations) - To
select appropriate yarding systems and guidelines for protecting soil
and water resources.
BMP 13.16 (Stream Channel Protection - Implementation and
Enforcement) - To provide the site-specific stream protection
prescriptions consistent with objectives identified under BMPs 12.6
and 12.6a. Objectives may include the following:
• Maintain the natural flow regime.
• Provide for unobstructed passage of storm flows.
• Maintain integrity of the riparian buffer to filter sediment and
other pollutants.
• Restore the natural course of any stream that has been diverted
as soon as practicable.
Kuiu Timber Sale FEIS
Appendix B • 5
Unit Cards
• Maintain natural channel integrity to protect aquatic habitat and
other beneficial uses.
• Prevent adverse changes to the natural stream temperature
regime.
BMP 14.1 (Transportation Planning) - To assure soil and water
resources are considered in transportation planning activities.
BMP 14.2 (Location of Transportation Facilities) - To assure water
resources protection measures are considered when loeating roads and
trails.
BMP 14.3 (Design of Transportation Facilities) - To incorporate
site-specific soil and water resource protection measures into the
design of roads and trails.
BMP 14.5 (Road and Trail Erosion Control Plan) - Develop
erosion control plans for road or trail projects to minimize or mitigate
erosion sedimentation and resulting water quality degradation prior to
the initiation of construction and maintenance activities. Ensure
compliance through effective contract administration and timely
implementation of erosion control measures.
BMP 14.6 (Timing Restrictions for Construction Activities) -
Minimize erosion potential by restricting the operating schedule and
conducting operations during lower risk periods.
BMP 14.7 (Measures to Minimize Mass Failures) - Minimize the
chance and extent of road-related mass failures, including landslides
and embankment slumps.
BMP 14.8 (Measures to Minimize Surface Erosion) - Minimize the
erosion from cutslopes, fillslopes, and the road surface, and
consequently reduce the risk of sediment production.
BMP 14.9 (Drainage Control to Minimize Erosion and
Sedimentation) - Minimize the erosive effects of concentrated water
flows from transportation facilities and the resulting degradation of
water quality through proper design and construction of drainage
control systems.
BMP 14.10 (Pioneer Road Construction) - Minimize sediment
produetion assoeiated with pioneer road construction.
BMP 14.11 (Timely Erosion Control Measures for Incomplete
Projects) - Minimize erosion of and sedimentation from disturbed
ground on incomplete projects by completing erosion control work
prior to seasonal or extended shutdowns.
6 • Appendix B
Kuiu Timber Sale FEIS
Unit Cards
BMP 14.12 (Control of Excavation and Sidecast Material) -
Minimize sedimentation from unconsolidated excavated and sidecast
material caused by road construction, reconstruction, or maintenance.
BMP 14.14 (Control of In-channel Operations) - Minimize stream
channel disturbances and related sediment production.
BMP 14.15 (Diversion of Flows Around Construction Sites) -
Identify and implement diversion and de-watering requirements at
construction sites to protect water quality and downstream uses.
BMP 14.17 (Bridge and Culvert Design and Installation) -
Minimize adverse impacts on water quality, stream courses, and
fisheries resources from the installation of bridges, culverts, or other
stream crossings.
BMP 14.20 (Road Maintenance) - Maintain all roads in a manner
which provides for soil and water resources protection by minimizing
rutting, road prism failures, sidecasting, and blockage of drainage
facilities.
BMP 14.22 (Access and Travel Management) - Control access and
manage road use to reduce the risk of erosion and sedimentation from
road surface disturbance especially during the higher risk periods
associated with high runoff and spring thaw conditions.
Process Groups and Channel Types
The Tongass National Forest defines stream channel types according
to the Channel Type User Guide (USDA Forest Service 1992), the
foundation upon which aquatic habitat management prescriptions are
developed. Channel types are defined within the context of fluvial
process groups that describe the interrelationship between watershed
runoff, landform relief, geology, and glacial or tidal influences on
fluvial erosion and deposition processes. Individual channel type
classifications are defined by physical attributes such as channel
gradient, channel width, channel pattern, stream bank incision and
containment. Table B-1 shows the Forest Plan codes used on the unit
card narratives. See the Forest Plan, Figure D-1 (page D-4) for a visual
representation of the typical distribution of channel process groups.
Each unit card summarizes the protection for a particular unit. Only
the channel types found in proposed timber harvest units are listed.
Kuiu Timber Sale FEIS
Appendix B • 7
Table B-1. Channel Types in or adjacent to proposed harvest
units '
Process Group
Channel
Type Code
Channel Type Description
High Gradient
Contained
HC2
Shallowly to Moderately
Ineised Footslope Channel
HC3
Deeply Incised Upper Valley
Channel
HC5
Shallowly Incised Very High
Gradient Channel
HC6
Deeply Incised Mountain
Slope Channel
Moderate Gradient
Contained
MC2
Moderate Width and Incision
Contained Channel
Moderate Gradient
Mixed Control
MMl
Narrow Mixed Control
Channel
MM2
Moderate Width Mixed
Control Channel
Table B-2. Stream Value Classes
Stream
Value
Class
Criteria
Class I
Streams and lakes with anadromous or adfluvial fish or fish habitat; or high
quality resident fish waters, or habitat above fish migration barriers known to
be reasonable enhancement opportunities for anadromous fish.
Class II
Streams and lakes with resident fish or fish habitat and generally steep (6-25
percent or higher) gradient (can also include streams with a 0-6 percent
gradient) 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. For
streams less than 30 percent gradient, special care is needed to determine if
resident fish are present.
Class IV
Other intennittent, ephemeral, and small perennial channels with insufficient
flow or sediment transport capabilities to have immediate influence on
downstream water quality or fish habitat capability. Class IV streams do not
have the characteristics of Class I, II, or III streams and have a bankfull width
of at least 0.3 meter (1 foot).
8 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Timber Sale
Figure B-1
Unit Pool
Legend
Unit Pool
Non-National Forest
Lakes/Saltwater
Project Area Boundary
Existing Open Roads
Stream Value Class I & II
Miles
0 0.25 0.5
1.5
Unit Cards
Kuiu Timber Sale FEIS
Appendix B • 1 1
Kuiu Timber Sale Unit Card
Unit Number: 101
Unit Acres: 96
Alternatives: 4, 5 i
1999 Aerial 198 106,
Photo: 198_107
Land Use Timber Production
Designation:
Net Timber
Volume:
TM-
Compartment 2-121
and Stand:
Volume
Strata Acres;
Low
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / Extend NFS Road (46021)
Resource Concerns & Responses
Fish Habitat / Watershed
Streams 1 and 4 are Class III, channel type HC5. '
Streams 2, 3, and 5-7 are Class IV, channel type HC5. ;
Streams 1 and 4: No programmed commercial timber harvest within the RMA, which is I
defined as the V-notch. Implement BMPs 12.6, 12.6a., 13.9, and 13.16.
Streams 2, 3, and 5-7: Split yard away from class IV streams whenever possible. Buck, i
limb, and top felled trees clear of streamcourses. Remove any slash deposited in
streamcourse as a result of timber harvest activities. Implement BMPs 12.6, 13.9, and
13.16.
Extreme hazard soils (MMI-4) along western boundary (14 acres) of the unit and at the !
bottom southeast section of unit (2 acres).
Field survey by soil scientist determined 14 western acres as stable. Unit was designed j
to eliminate 2 acres at bottom southeast section. Use partial suspension in western
section.
Wildlife/Biological Diversity
Concern: Large amount of high Volstrata present in unit. Red squirrel and black bear use reported
in unit. 35 acres of medium (HSI 0.40 to 0.50) deer habitat value occurs in this unit. 78
acres of high value marten (HSI >0.89) habitat occurs within unit.
Response: Harvest would not isolate habitat by removing corridors linking low elevation habitat to '
high elevations.
Vegetatlon/TImber
Concern: Even-aged opening size is close to 100 acres. I
Response: During layout ensure harvest unit does not exceed 100 acres.
No resource concerns for: Scenery, Karst, Wetlands, Heritage |
Concern:
Response:
Soils
Concern:
Response:
12 • Appendix B
Kuiu Timber Sale FEIS
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 101 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
Scale is 1 inch = 660 feet
1320
Kuiu Timber Sale Unit Card
Unit Number: I03c
Unit Acres: 20
Alternatives: 2
1999 Aerial 198 106,
Photo: 198_107
Land Use Timber
Designation: Production
Net Timber ccc
„ , 555 MBF
Volume:
TM-
Compartment 2-133
and Stand:
W 1 High 17
Volume j.
. Medium 3
Strata Acres: , „
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One existing NFS Road (46021)
Resource Concerns & Responses
Fish Habitat / Watershed
Concern:
Stream 1 is Class III, Channel Type HC5.
Stream 2 is Class III, Channel Type HC2.
Response:
Streams 1 and 2: No programmed commercial timber harvest within the RMA, which is
defined as the V-notch. Implement BMPs 12.6, 12.6a., 13.9, and 13.16.
Wildlife/Biological Diversity
Concern:
Small unit size but large amount of high Volstrata within the unit. Less than one acre of
high (HSI > 0.60), 15 acres of medium (HSI 0.40 to 0.50) deer habitat value occurs within
this unit. 17 acres of high value marten (HSI >0.89) habitat occurs within this unit.
Response:
Clearcut prescription would remove all high Volstrata when unit is harvested. Harvest
would not isolate habitat and no corridors that link low and high elevations would be
harvested.
No resource concerns for: Scenery, Soils, Karst, Wetlands, Heritage, Vegetation
it
14 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 103c Alternative 2
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 103c Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 1 03d
Unit Acres: 5
Alternatives: 2
1999 Aerial 1 98 1 06,
Photo: I98_l07
Land Use Timber
Designation: Production
Net Timber isgMBF !
Volume:
TM-
Compartment 2-123
and Stand:
Volume , .
- Medium
Strata Acres:
Low
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, cleareut
Logging Method/ Transportation: Cable /One existing NFS Road (46021)
Resource Concerns & Responses
Fish Habitat / Watershed
Coneem: Stream 1 is Class III, Channel Type HC5.
Response: Stream 1: No programmed commercial timber harvest within the RMA, which is defined
as the V-notch. Implement BMPs 12.6, 12.6a., 13.9, and 13.16.
Wildlife/Biological Diversity
Coneem: Small unit, large amount of high Volstrata within unit. One acre of high (HSI > 0.60), 4
acres of medium (HSI 0.40 to 0.50) deer habitat value occurs within this unit. 5 acres of
high value marten (HSI >0.89) habitat value occurs within this unit.
Response: Cleareut prescription would remove all high Volstrata when unit is harvested. Harvest
would not isolate habitat and no corridors would be removed that link low and high
elevations.
No resource concerns for: Scenery, Soils, Karst, Wetlands, Heritage, Vegetation
:
-
16 • Appendix B Kuiu Timber Sale FEIS 5
Kuiu Unit 103d Alternative 2
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 103d Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 109
Unit Acres: 100
Alternatives: 3, 4, 5
1999 Aerial 198 74,
Photo: 198 75
Land Use Timber Production
Designation:
Net Timber 2,063 MBF Alt 3 !
Volume: 2,681 MBF Alt 4 & 5
TM-Compartment _
and Stand:
Volufne Strata ^.. .
. Medium 14
Acres: , _
Low 7
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alt 3 Two-aged management, 50% area retention, clearcut with reserves, 52 acres and even-aged management,!
clearcut, 48 acres.
Alt 4 and 5 Even-aged management, clearcut, 100 acres.
Logging Method/ Transportation: Cable / One temporary road, one new NFS Road (46034) and on reconditioned NFS Road (6417)
Resource Concerns & Responses
Fish Habitat / Watershed
Concern:
Response:
Concern:
Response:
Stream 1 is Class I, Channel Type MM2.
Stream 2 is Class II, Channel Type HC3. :
Stream 3 is Class III, Channel Type HC3.
Streams 4 and 5 are Class IV, Channel Type HC5.
Stream 6 is Class III, Channel Type HC5.
Stream I : No programmed commercial timber harvest in the RMA, which is defined as the greatest of the
flood plain, riparian vegetation or soils, riparian associated wetland fens, or 120 feet.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as within 100 feet
of the stream or to the top of the V-notch, whichever is greater.
Streams 3 and 6: No programmed commercial timber harvest within the RMA, which is defined as the V-
notch.
Streams 4 and 5: Split yard away from Class IV streams whenever possible. Buck, limb, and top felled trees
clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber harvest activities.
All Streams: Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow potential
Streams 1, 2, and 3: In Alt 3 some retention would be left along the stream buffer to protect against
windthrow. In Alts 4 and 5, the riparian buffer will be protected by feathering the edge for a distance of 50
horizontal feet where trees less than 16 inches DBH and those trees that cannot be felled away from the
buffer will be retained.
Stream 6: For Alts 3, 4 and 5, the riparian buffer will be protected by feathering the edge for a distance of
50 horizontal feet where trees less than 16 inches DBH and those trees that cannot be felled away from the
buffer will be retained.
Wildlife/Biological Diversity
Concern:
Response:
Large amount of high and medium Volstrata present in unit. 39 acres of high value deer habitat (HSI
>0.60), 53 acres of medium value deer habitat (HSI 0.40 to 0.50) and 79 acres of high value marten habitat
(HSI >0.89) occur within this unit. Unit is potentially a travel corridor for animals from high elevation to
low elevation.
Alternatives 4 and 5 prescribe clearcut han^est. This prescription would reduce habitat value and create
large area of second growth. It would remove travel corridor between high elevation and low elevation and
would isolate some higher elevation habitat. Alternative 3 prescribes uneven-aged management, which
would mitigate removal of travel corridor for all but 48 acres within this unit.
Vegetation/Timber
Concern: Even-aged opening size is close to 100 acres.
Response: During layout ensure harvest unit does not exceed 100 acres.
No resource concerns for: Scenery, Soils, Karst, Wetlands, Heritage
18 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 109 Alternative 3,4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 109 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
1^
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 109b
Unit Acres: 17
Alternatives: 2
1999 Aerial 1 98 74,
Photo: 198 75
Land Use Timber
Designation: Production
Net Timber 147 MBF
Volume:
TM-
Compartment 2-125
and Stand:
\i 1 High 6
Volume .
r.. - A Medium 7
Strata Acres:
Low 4
Existing Stand Condition: Old-growth
Silvicultural Prescription: Two-Aged management clearcut with reserves-50% area retention above road,
Uneven-aged management - Single Tree Selection -50% BA retention below the road.
Logging Method/ Transportation: Cable / One new NFS Road (46034) and one reconditioned NFS Road
(6417)
Resource Concerns & Responses
Fish Habitat / Watershed
Concern: Stream 1 is Class I, Channel Type MM2.
Stream 2 is Class II, Channel Type HC3.
Stream 3 is Class III, Channel Type HC3
Streams 4 and 5 are Class IV, Channel Type HC5.
Response: Stream 1 : No programmed commercial timber harvest in the RMA, which is defined as the
greatest of the flood plain, riparian vegetation or soils, riparian associated wetland fens, or 120
feet. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 4 and 5: Split yard away from Class IV streams whenever possible. Buck, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: High Volstrata present in unit. 5 acres high value (HSI >0.60), 7 acres of medium value (HSI 0.4
to 0.5) deer habitat occurs within this unit. 5 acres high value marten (HSI >0.89) habitat occurs
within this unit. Area is a potential travel corridor from high elevation habitat to low elevation
habitat.
Response: 50% basal area retention and small size of the unit would mitigate impacts to potential animal use.
This treatment would reduce travel corridor between high elevation and low elevation but would
not isolate higher elevation habitat because of prescription.
No resource concerns for: Scenery, Soils, Karst, Wetlands, Heritage, Vegetation
20 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 109b Alternative 2
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 109b Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 1 1 1
Unit Acres: 24
Alternatives: 2, 4, 5
1999 Aerial 198 74,
Photo: 298 127
Land Use Timber Production
Designation:
Net Timber 161MBFAlt2
Volume: 321MBFAlt4&5
TM-
Compartment 2-126
and Stand:
w 1 High 8
Volume w .
«... Medium 1 6
Strata Acres:
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alt 2 Two Aged Management - 50% area retention, clearcut with reserves
Alt 4 and Alt 5 Even-aged management, clearcut, 24 acres
Logging Method/ Transportation: Cable / One temporary road and two reconditioned NFS Roads (6417 and
6443)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class I, Channel Type MC2/MM1.
Response: Stream 1, MC2 section: No programmed commercial timber harvest within the RMA, which is
defined as within 100 feet of the channel, or to the top of the side-slope break, whichever is
greater. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 1 MMl section: No programmed commercial timber harvest in the RMA, which is defined
as the greatest of the flood plain, riparian vegetation or soils, riparian associated wetland fens, or
120 feet. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Only high and medium Volstrata present. This area was identified as a wildlife corridor by the
IDT. 8 acres of medium value (HSI 0.40 to 0.50) deer habitat and 8 acres of high value marten
(HSI >0.89) habitat are within this unit.
Response: Two-aged management and small size of the unit in Alt 2 would mitigate potential impacts to
animal habitat. Alts 4 & 5 would reduce habitat value and create a large area of second growth.
Alternative 2 would maintain travel corridor between high elevation and low elevation.
Alternatives 4 and 5 would remove this corridor link between high and low elevations. t
No resource concerns for: Scenery, Soils, Karst, Wetlands, Heritage, Vegetation
i
22 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 111 Alternative 2,4,5
V/
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 111 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 112
Unit Acres: 22
Alternatives: 3, 4, 5 !
1999 Aerial 198 77,
Photo: 298 1 24
Land Use Timber Production
Designation:
Net Timber 352 MBF Alt 3
Volume: 705 MBF Alt 4 & 5 i;
TM-
Compartment 3-126
and Stand:
High 22
Volume Medium 0 |j
Strata Acres: Low 0 |
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alt 3 Two-aged management - 50% area retention, cleareut with reserves
Alt 4 and Alt 5 Even-aged management, elearcut.
Logging Method/ Transportation: Cable / One existing NFS Road (6418)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Stream 1 is Class III, Channel Type HC3.
Streams 2 and 3 are Class IV, Channel Type HC5.
Response;
Stream I : No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. j
Streams 2 and 3: Split yard away from Class IV streams whenever possible. Buck, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of i
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern;
Deer, bear and cavity nesting use, only high Volstrata present in unit. 14 acres of medium value |
(HSI 0.40 to 0.50) deer habitat and 22 acres of high value marten (HSI >0.89) habitat are within
this unit. i
Response:
Two-aged management in Alt 3 and small size of unit would mitigate impacts. Alts 4 and 5 would '
reduce habitat value and create large area of second growth. Alt 3 would maintain a travel ;
corridor between high elevation and low elevation. Alts 4 and 5 would remove the corridor. ;
No resource concerns for: Scenery, Soils, Wetlands, Karst, Heritage, Vegetation 1
24 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 112 Alternative 3,4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 112 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
Scale is 1 inch = 660 feet
1320
Kuiu Timber Sale Unit Card
Unit Number: 204
Unit Acres: 69
Alternative: 3
598 130,
Photo.
Land Use Timber Production
Designation:
Net Timber
. , , 627 MBF
Volume:
TM-
Compartment 3-127
and Stand:
./ , High 35
Volume ..
«... Medium 34
Strata Acres: , .
Low 2
Existing Stand Condition: Old-growth |
Silvicultural Prescription: Alt 3 Two-aged management - 50% area retention, clearcut with reserves
Logging Method/ Transportation: Cable / One temporary road and two new NFS Roads (46032 and 46033)
Resource Concerns & Responses
Fish Habitat/Watershed I
Concern: Stream 1 is Class III, Channel Type HC6.
Stream 2 is Class IV, Channel Type HC5.
Stream 3 is Class IV, Channel Type HC5.
Response: Stream 1 : No programmed commercial timber harvest within the RMA, which is defined as the !
V-notch. Implement BMPs 12.6, 12.6, 13.9, and 13.16. |
Streams 2 and 3: Split yard away from Class IV streams whenever possible. Buck, limb, and top i
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Large amount of high and medium Volstrata reported in this unit. 14 acres of high value (HSI
>0.60), 24 acres of medium value (HSI 0.40 to 0.50) deer habitat and 35 acres of high value
marten (HSI >0.89) habitat are located within this unit.
Response: Two-aged management prescriptions in Alternative 3 would mitigate the harvest of high and
medium Volstrata and deer and marten habitat values within the unit. Harvest would not isolate
high elevation habitat. No travel corridors would be removed.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage, Vegetation
26 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 204 Alternative 3
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 204 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
Scale is 1 inch = 660 feet
1320
z:
Kuiu Timber Sale Unit Card
Unit Number: 204
Unit Acres: 59
Alternative: 5
1999 Aerial 598 130,
Photo: 598 131
Sgnatlon: ''''■"'’er Production
Net Timber i a unr-
Volume: 1,027 MBF
TM-Compartment ^
and Stand:
High 28
Volume Strata a* i or,
Acres: Medium 30
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alt 5 Even-aged Management, eleareut
Logging Method/ Transportation: Cable / One temporary road and two new NFS Roads (46032 and 46033)
Resource Concerns & Responses
Fish Habitat/Watershed
Coneem: Stream 1 is Class III, Channel Type HC6
Stream 2 is Class IV, Channel Type HC5
Stream 3 is Class IV, Channel Type HC5
Response; Stream I : No programmed eommercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12. 6a, 13.9, and 13.16.
Streams 2 and 3: Split yard away from Class IV streams whenever possible. Buck, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Large amount of high and medium Volstrata reported in this unit. 14 acres of high value deer
habitat (HSI >0.60), 24 acres of medium value deer habitat (HSI 0.40 to 0.50) and 35 acres of
high value marten habitat (HSI >0.89) are located within this unit.
Response: Clearcut harvest in Alt 5 would remove all old-growth habitat and reduce deer and marten habitat
values. Harvest would not isolate high elevation habitat. No travel corridors would be removed.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage, Vegetation
28 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 204 Alternative 5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 204 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number:
205
Unit Acres:
39
Alternatives:
3
1999 Aerial
Photo:
598 1 30,
598 131
Land Use
Desfgnation:
Timber Production
Net Timber
Volume:
425 MBF
TM-Compartment
and Stand:
3-128
Volume Strata
Acres:
High 9
Medium 18
Low 12
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One temporary road
Resource Concerns & Responses
Fish Habitat/Watershed
Coneem: Stream 1 is Class III, Channel Type HC6
Response; Stream 1 : No programmed eommereial timber harvest within the RMA, whieh is defined as the
V-noteh. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: High, medium and low Volstrata located within unit. 1 acre of high value deer habitat (HSI
>0.60), 4 acres of medium value deer habitat (HSI 0.40 to 0.50) and 9 acres of high value marten
habitat (HSI >0.89) are located within the unit.
Response: Clearcut harvest would remove all old-growth habitat and reduce marten and deer habitat values.
Harvest would not isolate high elevation habitat. No travel corridors would be removed.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage, Vegetation
30 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 205 Alternative 3
///
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 205 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissloned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Fjd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number:
207
Unit Acres:
62
Alternatives:
2,4,5
1999 Aerial
Photo:
598 1 00,
598 lOl
Land Use
Designation:
Timber Production
Net Timber
Volume:
1,004 MBF Alts 2,4
1,927 MBF Alt 5
TM-Compartment
and Stand:
3-I29
Volume Strata
Acres:
High 59
Medium 3
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alt 2 and 4 Two-aged management - 50% area retention, clearcut with reserves 52
acres, even-aged management clearcut 1 0 acres
Alt 5 Even-aged management, clearcut
Logging Method/ Transportation: Cable and Shovel logging / One existing NFS Road (46096)
Resource Concerns & Responses
Fish Habitat/Watershed
Streams 1, 2, 4, 5, and 6 are Class IV, Channel Type HC5.
Stream 3 is Class III, Channel Type HC6.
Streams 1, 2, 4, 5, and 6: Split yard away from Class IV streams whenever possible. Buck, limb,
and top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a
result of timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 3; No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes stand susceptible to windthrow.
Stream 3: In Alts 2 and 4 some retention would be left along the stream buffer to protect against
windthrow. In Alt 5 the riparian buffer will be protected by feathering the edge for a distance of
50 horizontal feet where trees less than 16 inches DBH and those trees that cannot be felled away
from the buffer will be retained.
Soils/Wetlands
Concern; Initial concerns were for extreme hazard soils (MMI-4) in proposed unit and for protection of high
value sedge fen at bottom of unit.
Response: boundary was designed to avoid extreme hazard soils (MMI-4) from harvest which should
also provide protection for high value sedge fen. No further concerns.
Wildlife/Biological Diversity
Concern: A targe amount of high Volstrata is located in this unit (50 acres). 1 acre of high value deer
habitat (HSI >0.60), 12 acres of medium value deer habitat (HSI 0.40 to 0.50) and 58 acres of
high value marten habitat (HSI >0.89) are within the unit.
Response: Alts 2 and 4 were designed to retain a wildlife travel corridor. 50% area retention prescriptions
would mitigate the harvest of high Volstrata and marten habitat within the unit. Harvest would not
isolate habitat and no corridors would be removed between low and high elevations.
Alt 5 would remove all old-growth habitat within the unit through clearcut harvest. This would
isolate and remove travel corridors between high and low elevations.
No resource concerns for: Karst, Wetlands, Scenery, Heritage, Vegetation
Concern:
Response:
Concern:
Response:
32 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 207 Alternative 2,4,5
///
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 207 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 207
Unit Acres: 52
Alternatives: 3
1999 AerisI <oo i no
Photo:
598 101
Snatton: Timber Production
vlme:'" ^25 MBF
TM-Compartment ,, ,
and Stand:
High 50
Volume Strata i-
Acres: ^
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Two-aged management - 50% area retention, cleareut with reserves, 49 aeres and ;
even-aged management, elearcut, 3 acres
Logging Method/ Transportation: Cable and Shovel logging / One existing NFS Road (46096)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Streams 1, 2, 4, 5, and 6 are Class IV, Channel Type HC5.
Stream 3 is Class III, Channel Type HC6.
Response:
Soils
Streams 1, 2, 4, 5, and 6: Split yard away from Class IV streams whenever possible. Buck, limb,
and top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a
result of timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. ,
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. |
Concern:
Initial concerns were for extreme hazard soils (MMI-4) in proposed unit and for protection of high!
value sedge fen at bottom of unit.
Response:
Unit boundary was designed to exclude extreme hazard soils (MMI-4) from harvest which should ;
also provide protection for high value sedge fen. No further concerns.
Wildlife/Biological Diversity
Concern:
This prescription was designed to retain a wildlife travel corridor. A large amount of high
Volstrata is located in this unit. 1 acre of high value deer habitat (HSI >0.60), 12 acres of medium
value deer habitat (HSI 0.40 to 0.50) and 58 acres of high value marten habitat (HSI >0.89) are
within the unit.
Response:
50% area retention prescriptions would mitigate the harvest of high Volstrata and marten habitat
within the unit. Harvest is not expected to isolate habitat and no corridors would be removed.
No resource concerns for: Karst, Wetlands, Scenery, Heritage, Vegetation
34 • Appendix B
Kuiu Timber Sale FEIS
J
Kuiu Unit 207 Alternative 3
[
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 207 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
0
660
Scale is 1 inch = 660 feet
1320
Z]
Kuiu Timber Sale Unit Card
Unit Number:
208
Unit Acres:
97
Alternatives:
3
1999 Aerial
Photo:
598 99,
598 1 00
Land Use
Designation:
Timber Production
Net Timber
Volume:
2,953 MBF
TM-Compartment
and Stand:
3-130
Volume Strata
Acres:
High 96
Medium 1
Low 0
M!
iT'
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One new NFS Road (46032)
Resource Concerns & Responses
Fish Habitat/Watershed
Coneern:
Stream 1 is Class IV, Channel Type HC5.
Stream 2 is Class III, Channel Type HC5.
Stream 3 is Class III, Channel Type HC5.
Stream 4 is Class III, Channel Type HC6.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage
Response: Stream I : Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Streams 3 and 4; No programmed commercial timber harvest within the RMA, which is defined
as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern; Wolf den found in unit in 2003 monitored 2003 — 2005. No activity noted 2004 or 2005. Large
amount of high Volstrata reported in this unit. 5 acres of high value deer habitat (HSI >0.60), 78
acres of medium value deer habitat (HSI 0.40 to 0.50) and 96 acres of high value marten habitat ;
(HSI >0.89) are within the unit.
Response: Buffer was placed around den, eastern edge of unit boundary moved to exclude den and buffer. _
Clearcut harvest would remove all old-growth habitat and reduce deer and marten habitat values.
Harvest would not isolate high elevation habitat. No travel corridors would be removed. ;
Vegetation/Timber
Concern: Even-aged opening size is close to 100 acres.
Response: During layout ensure harvest unit does not exceed 100 acres.
fit;
I <
36 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 208 Alternative 3
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 208 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
Scale is 1 inch = 660 feet
1320
Kuiu Timber Sale Unit Card
Unit Number: 208
Unit Acres: 98
Alternatives: 4 f
1999 Aerial 598 99,
Photo: 598 1 00
SgnSon: Timber Production
Net Timber oor a
Volume; 3,385 MBF ; ;
)
TM-Compartment
and Stand:
High 95
Volume Strata .• -i
Acres; Medium 3
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut, 98 acres
Logging Method/ Transportation: Cable / One new NFS Road (46032)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class IV, Channel Type HC5.
Stream 2 is Class III, Channel Type HC5.
Stream 3 is Class III, Channel Type HC5.
Response: Stream 1 : Split yard away from Class IV streams whenever possible. Buck, limb, and top felled 1
trees clear of stream courses. Remove any slash deposited in stream course as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. j
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as j
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Wolf den found in unit in 2003 monitored 2003 - 2005. No activity noted 2004 or 2005. Large
amount of high Volstrata reported in this unit. 5 acres of high value deer habitat (HSI >0.60), 78
acres of medium value deer habitat (HSI 0.40 to 0.50) and 96 acres of high value marten habitat
(HSI >0.89) habitat are within the unit.
Response: Buffer was placed around den, eastern edge of unit boundary moved to exclude den and buffer. ■
Clearcut harvest would remove all old-growth habitat and reduce deer and marten habitat values.
Harvest would not isolate high elevation habitat. No travel corridors would be removed.
Vegetation/Timber
Concern: Even-aged opening size is close to 100 acres.
Response: During layout ensure harvest unit does not exceed 100 acres.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage
/ 1
r
r
),
<
1
1
1
■ li
I
38 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 208 Alternative 4
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 208 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
F|d
660
Scale is 1 inch = 660 feet
1320
□
Kuiu Timber Sale Unit Card
Unit Number: 208a
Unit Acres: 43
Alternatives: 2, 5
1999 Aerial 598 99,
Photo: 598 100
Land Use -r- i r. i
Designation: Timber Production
Net Timber
Volume: 864 MBF
TM-Compartment , ,
and Stand:
High 25
Volume Strata a* j- in
Acres: Medium 18
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One new NFS Road (46032)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Stream 1 is Class IV, Channel Type HC5.
Stream 2 is Class II, Channel Type HC5.
Stream 3 is Class III, Channel Type HC5.
Response:
Stream 1 : Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. >
Wildlife/Biological Diversity |
Concern:
Wolf den found in 2003 and monitored 2003-2005. No activity noted 2004-2005. Large amount
of high and medium Volstrata reported in this unit. 9 acres of high value deer habitat (HSI >0.60),
15 acres of medium value deer habitat (HSI 0.40 to 0.50) and 24 acres of high value marten .
habitat (HSI >0.89) are within the unit.
Response:
Wolf den buffer prescribed for site. Unit split on both sides of den and buffer area. Clearcut
prescription will remove all old-growth habitat and reduce the deer and marten habitat values
when unit is harvested. Harvest would not isolate high elevation habitat. No travel corridors
would be removed.
No resource concerns for: Karst, Wetlands, Soils, Scenery, Heritage, Vegetation
40 • Appendix B
,
Kuiu Timber Sale FEIS
Kuiu Unit 208a Alternative 2,5
//
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 208a Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 208b
Unit Acres: 51
Alternative: 2
1999 Aerial 598_100,
Photo: 598 101
SsJgnaUon: Timber Production
Net Timber ,
Volume: '’“1 MBF
TM-Compartment t iti
and Stand:
High 49
Volume Strata i- r.,
Acres: Medium 2
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, eleareut
Logging Method/ Transportation: Cable / One new NFS Road (46032)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Response:
Stream 1 is Class III, Channel Type HC5. j
Stream 2 is Class III, Channel Type HC5. j
Stream 1 : Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Wolf den found 2003 and monitored 2003-2005. No activity noted 2004-2005. Large amount of
high Volstrata reported in this unit. 21 acres of high value deer habitat (HSI >0.60), 20 acres of
medium value deer habitat (HSI 0.40 to 0.50) and 50 acres of high value marten habitat (HSI
>0.89) are within the unit.
Response: Wolf den buffer prescribed for site. Unit split on both sides of den and buffer area. Clearcut
prescription will remove all old-growth habitat and reduce the deer and marten habitat values
when unit is harvested. Harvest would not isolate high elevation habitat. No travel corridors
would be removed.
No resource concerns for: Karst, Wetlands, Soils, Scenery, Heritage, Vegetation
42 • Appendix B
Kuiu Timber Sale FEIS
/ /
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 208b Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
I
Kuiu Timber Sale Unit Card
Unit Number: 208b
Unit Acres: 40
Alternative: 5
1999 Aerial 598 100,
Photo: 598 101
SgnaUon: Timber Production
Net Timber , ^
Volume: MBF
TM-Compartment , . ^ .
and Stand:
High 40
Volume Strata a
Acres: Medium 0
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One new NFS Road (46032)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class III, Channel Type HC5.
Stream 2 is Class III, Channel Type HC5.
Response: Stream 1 : Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Wolf den found 2003 and monitored 2003-2005. No activity noted 2004-2005. Large amount of
high Volstrata reported in this unit. 21 acres of high value deer habitat (HSI >0.60), 20 acres of
medium value deer habitat (HSI 0.40 to 0.50) and 40 acres of high value marten habitat (HSI
>0.89) are within the unit. '
Response: Wolf den buffer prescribed for site. Unit split on both sides of den and buffer area. Clearcut
prescription would remove all old-growth habitat and reduce the deer and marten habitat values.
Harvest would not isolate high elevation habitat. No travel corridors would be removed.
No resource concerns for: Karst, Wetlands, Soils, Scenery, Heritage, Vegetation
44 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 208b Alternative 5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 208b Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 209
Unit Acres: 64
Alternatives: 2, 3, 4, 5
1999 Aerial 598 1 00,
Photo: 598_l0l
Land Use i r. j .
Designation: Timber Production
1,223 MBF Alts 2,
Net Timber .
Volume:
2,074 MBF Alt 5
TM-Compartment ,
and Stand:
High 64
Volume Strata a/i j n
Acres: °
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alts 2, 3, and 4 Uneven-aged management, 50% area retention, Group Selection, 19
acres. Uneven-aged Management, 50% BA retention. Single Tree Selection, 45 acres
Alt 5 Even-aged management, clearcut
Logging Method/ Transportation: Cable / One existing NFS Road (46096) | j
Resource Concerns & Responses | i
Fish Habitat/Watershed * ii
Stream 1 is Class III, Channel Type HC5. | '■
Stream 2 is Class IV, Channel Type HC5. I ■
Stream 1 : No programmed commercial timber harvest within the RMA, which is defined as the | f
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. ij
Stream 2: Split yard away from Class IV streams whenever possible. Buck, limb, and top felled • ^
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber i ‘ j
harvest activities.
Location makes this stand susceptible to windthrow. 1
Streams 1 and 2: In Alt 5 the riparian buffer will be protected by feathering the edge for a distance |
of 50 horizontal feet where trees less than 16 inches DBH and those trees that cannot be felled | lj
away from the buffer will be retained. f
li
Evidence of past landslides uphill of Class 3 stream. Very steep slopes at V-notch, original ji f
design included 2 acres of extreme hazard soils (MMI-4). |
Extreme hazard soils (MMI-4) were removed from unit. No further soil concerns. J fi
Wildlife/Biological Diversity
Concern: Black bear, red-breasted sapsucker activity and game trails were noted in the unit. Entire unit is
comprised of high Volstrata. 1 1 acres of high value deer habitat (EISI >0.60), 19 acres of medium
value deer habitat (HSI 0.40 to 0.50) and 64 acres of high value marten habitat (HSI >0.89) are ;
located with the unit.
Response: 50% BA retention would mitigate the harvest of old-growth and deer and marten habitat values ^
within the unit in Alternatives 2, 3, and 4. Clearcut harvest would remove all old-growth and
reduce deer and marten habitat values in Alternative 5. Harvest would not isolate habitat or
corridors in Alternatives 2, 3 and 4. Alternative 5 would isolate high elevation habitat and remove
the travel corridors.
I
No resource concerns for: Karst, Wetlands, Scenery, Heritage, Vegetation
Concern:
Response:
Concern:
Response:
Soils
Concern:
Response:
46 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 209 Alternative 2, 3,4, 5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 209 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
Scale is 1 inch = 660 feet
1320
Kuiu Timber Sale Unit Card
Unit Number: 210
Unit Acres: 48
Alternatives: 3, 4, 5
1999 Aerial 598 97,
Photo: 98^ 99
Sanation: Timber Production
Net Timber ,
Volume: 1,437 MBF ^
TM-Compartment
and Stand:
High 44 \
Volume Strata a/t j- d i
Acres: Medium 4 k
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One temporary road
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class III Channel Type HC2.
Streams 2, 3, 4, and 5 are Class IV, Channel Type HC2.
Response: Stream I : No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 2, 3, 4, and 5: Split yard away from Class IV streams whenever possible. Buck, limb, and
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Soils
Concern:
Response:
Steep cliff area just southwest of unit
Boundary located to avoid steep cliff areas.
Wildlife/Biological Diversity
Concern: Large amount of high Volstrata reported in this unit. 5 acres of medium value deer habitat (HSI
0.40 to 0.50) and 42 acres of high value marten habitat (HSI >0.89) locate within unit.
Response: Harvest would not isolate habitat and no corridors would be removed.
No resource concerns for: Scenery, Heritage, Vegetation, Karst, Wetlands
48 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 210 Alternative 3,4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 210 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Pd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 211
Unit Acres: 36
Alternatives: 4, 5
1999 Aerial 598 97,
Photo: 98^ 99
Sgratlon: timber Production
Net Timber -7-nAAr.r' B
Volume: ’23 MBF |
TM-Compartment ^ .
and Stand:
High 20 ^
Volume Strata a/, j 11
Acres: '^'=dium 11 rt
Low 5 l<]j
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One temporary road and one existing NFS Road (46096)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class IV, Channel Type HC5.
Stream 2 is Class IV, Channel Type HC2.
Response: Streams 1 and 2: Split yard away from Class IV streams whenever possible. Buck, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: Large amount of high Volstrata reported in this unit. 2 acres of high value deer habitat (HSI
>0.60), 6 acres of medium value deer habitat (HSI 0.40 to 0.50) and 20 acres of high value marten
habitat (HSI >0.89) are located within unit.
Response: Harvest would not isolate habitat and no corridors would be removed.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage, Vegetation, Wildlife
\
50 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 211 Alternative 4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 211 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Pd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 212
Unit Acres: 9
Alternatives: 4, 5
1999 Aerial 598 97,
Photo: 98, 99
Land Use Timber
Designation: Production
Net Timber
Volume: ^24 MBF
TM-Compartment ,
and Stand:
High 7
Volume Strata j- r.
Acres: Medium 2
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Shovel / One temporary road
Resource Concerns & Responses
Fish Habitat/Watershed
Coneera: Streams 1 and 2 are Class IV, Channel Type HC5.
Response: Streams 1 and 2: Split yard away from Class IV streams whenever possible. Buek, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern: 6 acres of medium value deer habitat (HSI 0.40 to 0.50) and 7 acres of high value marten habitat
(HSI >0.89) are within the unit.
Response: Harvest would not isolate habitat and no corridors would be removed.
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage, Vegetation
52 • Appendix B
I
Kuiu Timber Sale FEIS i
1
I
Kuiu Unit 212 Alternative 4,5
/ / /
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 212 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 302
Unit Acres: 66
Alternatives: 4
1'
’I
V
1999 Aerial 298 123,
Photo: 298 124
Land Use l r> j
Designation: Timber Production
Net Timber ,
Volume: 1,309 MBF
TM-Compartment , ,
and Stand:
High 66
Volume Strata i- ^
Acres: Medium 0
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Uneven-aged management, 50% BA retention. Single Tree Selection
Logging Method/ Transportation: Helicopter / Use landing on existing NFS Road (6413)
Resource Concerns & Responses
Fish Habitat/Watershed !
Concern:
Streams 1, 4, and 7 are Class III, Channel Type HC5.
Streams 2, 3, 5, and 6 are Class IV, Channel Type HC5.
Response:
Streams 1, 4, and 7: No programmed commercial timber harvest within the RMA, which is ;
defined as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. '
Streams 2, 3, 5, and 6: Split yard away from Class IV streams whenever possible. Buck, limb, and
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of |
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Soils
Concern:
Steep soils exist in patches in unit.
Response:
Helicopter harvest with full suspension.
Wildlife/Biological Diversity '
Concern:
Large amount of high Volstrata in unit. Less than one acre of high value deer habitat (HSI >0.60), '
30 acres of medium value deer habitat (HSI 0.40 to 0.50) and 66 acres of high value marten
habitat (HSI >0.89) are within the unit.
Response:
50% BA retention would help maintain old-growth characteristics and values and retain high
value marten habitat. Harvest would not isolate habitat and no corridors would be removed. |
No resource concerns for: Scenery, Heritage, Vegetation, Wetlands, Karst
54 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 302 Alternative 4
/ / /
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 302 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Pd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 303
Unit Acres: 58
Alternatives: 4
1999 Aerial 598 1 30,
Photo: 598 131
Land Use -r- i r. j
Designation: Timber Production
Net Timber , .c-tivAnT-
Volume: 1,157 MBF
TM-Compartment ^
and Stand:
High 58
Volume Strata » .t . n
Acres: Medium 0
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Uneven-aged management, 50% BA retention. Single Tree Selection
Logging Method/ Transportation: Helicopter / Use landings on existing NFS Road (6413)
Resource Concerns & Responses
Watershed/Fisheries
Concern: Streams 1, 2, 3, and 4 are Class III, Channel Type HC6.
Response: Streams 1, 2, 3, and 4: No programmed commercial timber harvest within the RMA, which is
defined as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Soils
Concern: Unit initially had 10 acres of extreme hazard soils (MMI-4).
Response: Extreme hazard soils (MMI-4) were deleted from unit boundary. No further soil concerns.
Wildlife/Biological Diversity
Concern: Large amount of high Volstrata in unit. 22 acres of important deer habitat (HSI >0.60) and 58
acres of high value marten habitat (HSI >0.89) within the unit.
Response: 50% BA retention would mitigate harvest by retaining old-growth characteristics and values and
retain marten and deer habitat. Harvest would not isolate habitat and no corridors would be
removed.
No resource concerns for: Scenery, Heritage, Vegetation, Karst, Wetlands
56 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 303 Alternative 4
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 303 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 305 a/b
Unit Acres: 24
Alternatives: 4
1999 Aerial 598 1 31,
Photo: 598 132
SgnaHon: Timber Production
Net Timber
Volume: 484 MBF
TM-Compartment
and Stand:
High 24
Volume Strata j- a
Acres:
Low 0
Existing Stand Condition: Old-growth
Silvicuitural Prescription: Uneven-aged management, 50% BA retention, Single Tree Selection
Logging Method/ Transportation: Helicopter / Use landing on existing NFS Road (6413)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class III, Channel Type HC5.
Stream 2 is Class IV, Channel Type HC5.
Stream 3 is Class III, Channel Type HC6.
Response: Streams 1 and 3: No programmed commercial timber harvest within the RMA, which is defined
as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16
Stream 2: Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Soils
Concern: Unit initially had 12.5 acres extreme hazard soils (MMI-4) that had evidence of windthrow.
Response: Unit boundary was designed to avoid all extreme hazard soils (MMI-4). No further soil concerns.
Wildlife/Biological Diversity
Concern: Large amount of high Volstrata in unit. 5 acres of high value (HSI >0.60) deer habitat and 24
acres of high value marten (HSI >0.89) habitat are within unit.
Response: 50% BA retention would mitigate harvest by retaining old-growth characteristics and values and
retain marten and deer habitat. Harvest would not isolate habitat and no corridors would be
removed.
No resource concerns for: Scenery, Heritage, Vegetation, Wetlands, Karst
58 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 305a/305b
Alternative 4
zzz:i
E
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Recreational River Corridor
Proposed Unit 305a Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
I
\
I
0
660
Scale is 1 inch = 660 feet
1320
Kuiu Timber Sale Unit Card
Unit Number: 307
Unit Acres: 17
Alternatives: 3, 4, 5
1999 Aerial 598 132,
Photo: 598 133
Land Use Timber
Designation: Production
vlme"" 288 MBF
TM-Compartment , ,
and Stand:
High 8
Volume Strata a* j- r.
Acres: Medium 9
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One temporary road
Resource Concerns & Responses
Watershed/Fisheries
Coneem: Stream 1 is Class III, Channel Type HC6.
Stream 2 is Class I MM2.
Response: Stream 1 : No programmed eommereial timber harvest within the RMA, whieh is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16
Stream 2: No programmed eommereial timber harvest in the RMA, which is defined as the
greatest of the floodplain, riparian vegetation or soils, riparian associated wetland fens, or 120
feet. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Concern: Location makes this stand susceptible to windthrow.
Response: Streams 1 and 2: For Alts 3, 4 and 5 the riparian buffer will be protected by feathering the edge
for a distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that
cannot be felled away from the buffer will be retained.
Wildlife/Biological Diversity
Concern: Large amount of high and medium Volstrata in unit. 8 acres of high value deer habitat (HSI
>0.60) and 8 acres of high value marten habitat (HSI >0.89) are within the unit.
Response: Harvest would not isolate habitat and no corridors would be removed.
No resource concerns for: Soils, Wetlands, Karst, Scenery, Heritage, Vegetation
60 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 307 Alternative 3,4,5
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 307 Boundary
Adjacent Proposed Units
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 308
Unit Acres: 39
Alternatives: 3,4,5 ; "
1999 Aerial 298 1 26,
Photo: 298 127
Sgnaton: timber Production
Net Timber om
Volume: 297 MBF ■
TM-Compartment
and Stand:
High 6
Volume Strata a* i- ■!
Acres: Medium 33 ■
Low 0 |j'
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable and Shovel / One temporary road
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Streams 1, 2, and 4 are Class III, Channel Type HC6.
Stream 3 is Class IV Channel Type HC5.
Stream 5 is Class II Channel Type HC6.
Stream 6 is Class I Channel Type MM2.
Response: Streams 1, 2, and 4: No programmed commercial timber harvest within the RMA, which is
defined as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 3: Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 5: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs]
12.6, 12.6a, 13.9, and 13.16.
Stream 6: No programmed commercial timber harvest in the RMA, which is defined as the
greatest of the flood plain, riparian vegetation or soils, riparian associated wetland fens, or 120
feet. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Concern: Location makes this stand susceptible to windthrow.
Response: Streams 1, 2, 4, 5 and 6: In Alts 3, 4 and 5 the riparian buffer will be protected by feathering the J
edge for a distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that]
cannot be felled away from the buffer will be retained.
Wildlife/Biological Diversity
Concern: Large amount of medium Volstrata in unit. 5 acres of high value deer habitat (HSI >0.60) and 5
acres of high value marten habitat (HSI >0.89) are within the unit.
Response: Harvest would not isolate habitat and no corridors would be removed.
No resource concerns for: Soils, Wetlands, Karst, Scenery, Heritage, Vegetation
62 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 308 Alternative 3,4,5
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 308 Boundary
Adjacent Proposed Units
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 401
Unit Acres: 20
Alternatives: 4, 5 j
1999 Aerial 1 98 72,
Photo: 1 98 73
Land Use -r- i r> j
Designation: Timber Production
Net Timber 0
Volume: *>53 MBF |l
TM-Compartment ^
and Stand:
High 20
Volume Strata [I
Acres: 0
Low 0 1
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, cleareut
Logging Method/ Transportation: Cable / Two reconditioned NFS Roads (6417 and 6422)
Resource Concerns & Responses
Watershed/Fisheries
Concern: Stream
Response:
is Class I, Channel Type MMl.
Stream 2 is Class II, Channel Type HC3.
Stream 3 is Class III, Channel Type HC6.
Stream 1 : No programmed commercial timber harvest in the RMA, which is defined as the
greatest of the flood plain, riparian vegetation or soils, riparian associated wetland fens, or 120
feet. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern:
IDT recommended dropping this unit from alternatives 2 and 3 because it was a wildlife corridor
between two existing clearcuts. Large amount of high Volstrata would be harvested in this unit. |
17 acres of high value deer habitat (HSI >0.60), 3 acres of medium value deer habitat (HSI 4.0 to^
5.0) and 20 acres of high value marten habitat (HSI >0.89) are within the unit. ^
Concern not addressed. Cleareut harvest would remove wildlife corridor.
Response:
No resource concerns for: Soils, Scenery, Heritage, Vegetation, Karst, Wetlands
li
W 1
11
64 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 401 Alternative 4,5
/ / /
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 401 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 402
Unit Acres: 24
Alternatives: 4, 5 j |
1999 Aerial 298 1 29,
Photo: 298 130
Sgnatlon: Timber Production
Net Timber ^rrtAATAr- t!
Volume: “9 MBF | |
TM-Compartment .
and Stand:
High 19 it
Volume Strata j- k
Acres: 3
Low 2 J 1
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One new NFS Road (46030)
Resource Concerns & Responses
¥i-
Fish Habitat/Watershed
Coneem:
f|!
(fi
Response:
Concern:
Response:
Streams 1, 2, and 4 are Class IV, Channel Type HC5.
Stream 3 is Class IV, Channel Type HC2.
Stream 5 is Class II, Channel Type HC2. ,,
Stream 6 is Class III, Channel Type HC2. 1 1
Streams 1, 2, 3, and 4: Split yard away from Class IV streams whenever possible. Buck, limb, and I;
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of |
timber harvest activities. Implement BMPs 12.6, 12.6a. 13.9, and 13.16. u'
Stream 5: No programmed commercial timber harvest within the RMA, which is defined as p|
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Stream 6: No programmed commercial timber harvest within the RMA, which is defined as the —
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. _
Access road would cross a Class II stream. H
Install a log stringer bridge. Designate location of stream crossing and minimize stream channel ||'j
disturbance from road construction/storage (BMPs 14.14, 14.17).
4.
Wetlands
Concern:
Response:
Forested wetland exists in the unit.
Suitable for cable harvest with partial suspension, too wet for shovel.
Wildlife/Biological Diversity
Concern: Unit is potential wildlife travel corridor. Large amount of high Volstrata would be harvested in
this unit. 1 acre of high value deer habitat (HSI >0.60) and 19 acres of high value marten habitat
(HSI >0.89) are within the unit.
Response: Concern not addressed. Clearcut harvest would reduce wildlife travel corridor.
No resource concerns for: Scenery, Heritage, Vegetation, Soils, Karst
66 • Appendix B
Kuiu Timber Sale FEIS
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 402 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 403
Unit Acres: 29
Alternatives: 3, 4, 5
1999 Aerial 298 1 29,
Photo: 130,131
Sgnatlon: Timber Production
vlme""' 857 MBF
TM-Compartment . ,
and Stand:
High 26 1
Volume Strata j t J
Acres: Medium 3
Low 0 1
■r
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One new NFS Road (46030)
Resource Concerns & Responses
Fish Habitat/Watershed
Coneem: Streams 1 and 5 are Class IV, Channel Type HC5.
Stream 2 is Class III, Channel Type HC2.
Stream 4 is Class IV, Channel Type HC2.
Stream 3 is Class II, Channel Type HC2. i
Response: Streams 1, 4, and 5: Split yard away from elass IV streams whenever possible. Buck, limb, and
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the stream or to the top of the V-notch, whichever is greater. Implement BMPs
12.6, 12.6a, 13.9, and 13.16.
Access road would cross a Class II stream.
Install a log stringer bridge. Designate location of stream crossing and minimize stream channel
disturbance from road construction/storage (BMPs 14.14, 14.17).
Concern;
Response:
Wetlands
Concern: Forested wetland exists in the unit
Response: Suitable for cable harvest with partial suspension, too wet for shovel.
Concern: Road crosses wetlands.
Response: Follow BMPs when constructing road in wetland (examples include, minimizing road width and
deep placement of culverts).
Wildlife/Biological Diversity
Concern: Large amount of high Volstrata would be harvested in this unit. 6 acres of high value deer habitat
(HSI >0.60) and 26 acres of high value marten habitat (HSI >0.89) are within the unit.
Response; Harvest would not isolate habitat and corridors would not be removed.
No resource concerns for: Scenery, Heritage, Vegetation, Soils, Karst
68 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 403 Alternative 3,4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 403 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 404
Unit Acres: 28
Alternatives: 2, 3, 4, 5
1999 Aerial 598 136,
Photo: 598 137
Land Use Timber
Designation: Production
Net Timber 472 MBF Alt 2 & 3
Volume: 770 MBF Alt 4 & 5
TM-Compartment .
and Stand:
High 23
Volume Strata a/i j- ^
Acres: 4
Low 1
N“
rits
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alts 2 and 3 Uneven-aged management, 50% BA retention, Single Tree Selection.
Alts 4 and 5 Even-aged management.
Logging Method/ Transportation: Cable / One new NFS Road (46030)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern;
Response:
Concern:
Response:
Stream 1 is Class IV, Channel Type HC5.
Stream 2 is Class III, Channel Type HC2.
Stream 3 is Class I, Channel Type MC2.
Stream 4 is Class IV, Channel Type HC5.
Stream 1 and 4: Split yard away from Class IV streams whenever possible. Buck, limb, and
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a
result of timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: No programmed commercial timber harvest within the RMA, which is defined as
the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 3: No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the channel, or to the top of the side-slope break, whichever is greater.
Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow.
Streams 2 and 3: In Alts 4 and 5 the riparian buffer will be protected by feathering the edge
for a distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that
cannot be felled away from the buffer will be retained.
Wetlands
Concern:
Response:
Forested wetland exists in the unit.
Suitable for cable harvest with partial suspension, too wet for shovel.
Wildlife/Biological Diversity
Concern; Unit includes portion of a corridor between two existing managed stands. High and medium
Volstrata are within the unit. 21 acres of high value deer habitat (HSI >0.60), 4 acres of
medium value deer habitat (HSI 4.0-5. 0) and 23 acres of high value marten habitat (HSI
>0.89) are within the unit.
Response: Partial harvest with 50% BA retention would mitigate impacts to old-growth, help retain
marten and deer habitat, and maintain corridor in Alternatives 2 and 3. Clearcut harvest
systems would remove corridors in Alternatives 4 and 5.
No resource concerns for: Scenery, Heritage, Vegetation, Soils, Karst
70 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 404 Alternative 2, 3,4, 5
/ /
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 404 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 405
Unit Acres: 25
Alternatives: 2, 3, 4, 5
1999 Aerial 598 1 36,
Photo: 598 137
Land Use -r- i r. j ,
Designation: Timber Production
Net Timber 410MBFAlt2&3
Volume: 820 MBF Alt 4 & 5 :
TM-Compartment ^
and Stand:
High 25
Volume Strata
Acres:
Low
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alts 2 and 3 Two-aged management, 50% area retention, elearcut with reserves
Alts 4 and 5 Even-aged management
Logging Method/ Transportation: Cable / One new NFS Road (46030) and one temporary road
IK
\
\
Resource Concerns & Responses
Concern:
Response:
Fish Habitat/Watershed
Stream 1 is Class III, Channel Type HC2.
Stream 2 is Class IV, Channel Type HC5.
Stream 1: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 2: Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes stand susceptible to windthrow.
Stream 1 : In Alts 2 and 3 some retention would be left along the stream buffer to protect against
windthrow. In Alts 4 and 5, the riparian buffer will be protected by feathering the edge for a
distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that cannot be
felled away from the buffer will be retained.
Concern:
Response:
Wetlands
Concern:
Response:
Forested wetland exists in the unit.
Suitable for cable harvest with partial suspension, too wet for shovel.
Wildlife/Biological Diversity
Concern:
Response:
This unit linked with unit 404 is a wildlife corridor between two previously harvested units. High
Volstrata would be harvested in this unit. Less than one acre of high value deer habitat (HSI .
>0.60), 25 acres of medium value deer habitat (HSI 4. 0-5.0) and 25 acres of high value marten ^
habitat (HSI >0.89) would be harvested within this unit.
Partial harvest with 50% area retention would mitigate impacts to old-growth habitat, retain
marten and deer habitat, and retain the corridor. Clearcut harvest would remove the corridor.
No resource concerns for: Soils, Karst, Scenery, Heritage, Vegetation
72 • Appendix B
Kuiu Timber Sale FEIS
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 405 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
F|d
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 409
Unit Acres: 46
Alternatives: 3, 4, 5 1
1999 Aerial 298 130,
Photo: 131,132
Land Use Timber
Designation: Production
Net Timber 663 MBF Alt 3
Volume: 1,325 MBF Alts 4 &
TM-Compartment 6-40 &
and Stand: 7-121
High 40 ']
Volume Strata i- ^
Acres: <> J
Low 0 jH[
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alt 3 Two-aged management - 50% area retention, clearcut with reserves
Alt 4 and 5 Even-aged management, clearcut
Logging Method/ Transportation: Shovel / One temporary road and one new NFS Road (46030)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class III, Channel Type HC5.
Stream 2 is Class IV, Channel Type HC5.
Stream 3 is Class III, Channel Type HC6.
Response: Streams 1 and 3: No programmed commercial timber harvest within the RMA, which is defined
as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16. In Alt 3 some retention would be
left along the stream buffer to protect against windthrow.
Stream 2: Split yard away from Class IV streams whenever possible. Buck, limb, and top felled
trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of timber
harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Concern: Location makes this stand susceptible to windthrow.
Response: In Alts 4 and 5, the riparian buffer will be protected by feathering the edge for a distance of 50
horizontal feet where trees less than 16 inches DBH and those trees that cannot be felled away
from the buffer will be retained.
Concern: Access road would cross a Class II stream.
Response: Install a log stringer bridge. Designate location of stream crossing and minimize stream channel
disturbance from road construction/storage (BMPs 14.14, 14.17).
Wildlife/Biological Diversity
Concern: Wildlife corridor between two previously harvested units. High and medium Volstrata occur
within this unit. 27 acres of medium value deer habitat (HSI 4. 0-5.0) and 40 acres of high value
marten habitat (HSI >0.89) occur within this unit.
Response: Travel corridor would be mitigated by 50% area retention in Alternative 3. Clearcut harvest in
Alternatives 4 and 5 would remove travel corridor.
No resource concerns for: Soils, Wetlands, Karst, Scenery, Heritage, Vegetation
74 • Appendix B
Kuiu Timber Sale FEIS
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 409 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Pd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 410
Unit Acres: 45
Alternatives: 3, 4, 5 |
1999 Aerial 298 130,
Photo: 131,132
Desfgnltlon: Timber Production
Net Timber
Volume: 996 MBF 1
TM-Compartment 6-41 &
and Stand: 7-122
High 29
Volume Strata a* i- ,r
Acres: Medium 15
Low 1
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / One temporary road and one new NFS Road (46030)
Resource Concerns & Responses
Fish Habitat/Watershed
Coneem:
Response:
Coneem:
Response:
Stream 1 is Class III, Channel Type HC6.
No programmed eommercial timber harvest within the RMA, whieh is defined as the V-noteh.
Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Loeation makes this stand suseeptible to windthrow.
Stream 1 : In Alts 3, 4 and 5, the riparian buffer will be proteeted by feathering the edge for a
distanee of 50 horizontal feet where trees less than 16 inches DBH and those trees that cannot be
felled away from the buffer will be retained.
Access road would cross a Class II stream.
Install a log stringer bridge. Designate location of stream crossing and minimize stream channel
disturbance from road constmction/storage (BMPs 14.14, 14.17).
Wildlife/Biological Diversity
Concern: High amount of animal use was reported. Field crews noted red squirrel, black bear, deer, red-
breasted sapsucker, and many neo-tropical migrant birds. Large amount of high and medium
Volstrata in unit. 2 acres of high value deer habitat (HSI >0.60), 21 acres of medium value deer
habitat (HSI 4. 0-5.0) along with 29 acres of high value marten habitat (HSI >0.89) occur within
the unit.
Concern:
Response:
Response:
Clearcut harvest would not isolate habitat or eliminate corridor.
No resource concerns for: Soils, Wetlands, Scenery, Heritage, Vegetation, Karst
i >
i
76 • Appendix B
Kuiu Timber Sale FEIS
[
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 410 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
1
^ !
Kuiu Timber Sale Unit Card
Unit Number:
412
Unit Acres:
99
Alternatives:
4, 5 1
1999 Aerial
Photo:
298 1 32,
133, 134
Land Use
Designation:
Timber Production
Net Timber
Volume:
3,048 MBF
TM-Compartment
and Stand:
7-123
Volume Strata
Acres:
High 93
Medium 6
Low
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, elearcut
Logging Method/ Transportation: Cable / One temporary road and one new NFS Road (46035)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Response:
Stream 1 is Class IV, Channel Type HC2.
Stream reach 2 is Class II, Channel Type HC2.
Stream 3 is Rowan Creek, and is Class II, Channel Type MC2.
Stream reach 4 is Class II, Channel Type HC2.
Stream reach 5 is Class IV, Channel Type HC2.
Stream 6 is Class III, Channel Type HC5.
Stream 7 is Class III, Channel Type HC6.
Streams 1 and 5: Split yard away from Class IV streams whenever possible. Buck, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 2, 3, and 4: No programmed commercial timber harvest within the RMA, which is
defined as within 100 feet of the stream or to the top of the V-notch, whichever is greater.
Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 6 and 7: No programmed commercial timber harvest within the RMA, which is defined
as the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow.
Streams 2, 3, 4, 6 and 7: In Alts 4 and 5, the riparian buffer will be protected by feathering the
edge for a distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that
cannot be felled away from the buffer will be retained.
Wildlife/Biological Diversity
Concern: Black bear, red squirrel, deer, red-breasted sapsucker use and game trails were reported by field
personnel. Brown Creepers were present and vocalizations were heard within the unit. Large
amount of high Volstrata in unit. 50 acres of high value deer habitat (HSI >0.60), 26 acres of
medium value deer habitat (HSI 4. 0-5.0) along with 93 acres of high value marten habitat (HSI
>0.89) occur within the unit.
Response: Clearcut harvest would not isolate habitat and area is not an isolated corridor.
Vegetation/Timber
Concern: Even-aged opening size is close to 100 acres.
Response: During layout ensure harvest unit does not exceed 100 acres.
Concern:
Response:
No resource concerns for: Soils, Karst, Wetlands, Scenery, Heritage
78 • Appendix B Kuiu Timber Sale FEIS
k
Kuiu Unit 412 Alternative 4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 412 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Fd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 414
Unit Acres: 72
Alternatives: 4 \
1999 Aerial 598 136,
Photo: 598 137
Snitlon: Timber Production
Net Timber ,
Volume: 1,174 MBF
TM-Compartment .
and Stand:
High 72
Volume Strata
Acres: '^‘=‘‘rum
Low
Existing Stand Condition: Old-growth
Silvicultural Prescription: Two-aged management, 50% area retention, clearcut with reserves, 49 acres and
uneven-aged management, 50% area retention, group selection, 23 acres
Logging Method/ Transportation: Cable / Two temporary roads and one new NFS Road (46031)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Response;
Concern:
Response:
Streams 1 and 4 are Class II Channel Type HC3, and Class II Channel Type HC5.
Streams 2 and 3 are Class III Channel Type HC3, and Class III Channel Type HC5.
Streams 5, 6, and 7 are Class IV, Channel Type HC5.
Streams 1 and 4: No programmed commercial timber harvest within the RMA, which is defined
as within 100 feet of the stream or to the top of the V-notch, whichever is greater.
Streams 2 and 3: No programmed commercial timber harvest within the RMA, which is defined
as the V-notch.
Streams 5, 6, and 7: Split yard away from Class IV streams whenever possible. Buck, limb, and
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities.
All Streams : Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow. :
Some retention will be left along the stream buffer to provide additional windthrow protection.
Wildlife/Biological Diversity
Concern:
Response:
Unit is a wildlife travel corridor between high and low elevations. Large amount of high Volstrata
in unit. 51 acres of high value deer habitat (HSI >0.60), 10 acres of medium value deer habitat
(HSI 4. 0-5.0) along with 69 acres of high value marten habitat (HSI >0.89) occur within the unit.
50% area retention would mitigate harvest and help retain corridor and some old-growth
characteristics as well as marten and deer habitat. Clearcut harvest would not isolate habitat and
area is not an isolated corridor.
Recreation/Scenery
Lower portion of unit (3 1 acres) located within Forest Plan Recreational River Land Use
Designation.
Measures taken to minimize the potential effeets on scenery from timber harvest for this
project were limited to the design of Units 414 and 415 within the Kadake Creek
Recreational River corridor using a harvest method of 50 percent basal area retention.
Concern:
Response:
No resource concerns for: Heritage, Vegetation, Karst, Wetlands, Soils
80 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 414 Alternative 4
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Recreational River Corridor
Proposed Unit 414 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Fd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 415
Unit Acres: 27
Alternatives: 2, 4
1999 Aerial 598 95,
Photo: 598 94
Land Use i r. i
Designation: timber Production
Net Timber rtnc AArti-
Volume: ^05 MBF
TM-Compartment ^
and Stand:
High 24
Volume Strata .• n
Acres: 0
Low 3
Existing Stand Condition: Old-growth | N
Silvicultural Prescription: Two-aged management, 50% area retention, clearcut with reserves
Logging Method/ Transportation: Cable and Shovel / One temporary road, one existing NFS Road (6415), and |
one reconditioned NFS Road (46091 ) [ ,
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Response:
Concern:
Response:
Stream 1 is Class I, Channel Type MC2 for the lower section and Class II, Channel Type MC2 for
the upper section.
Stream 1 : No programmed commercial timber harvest within the RMA, which is defined as
within 100 feet of the channel, or to the top of the side-slope break, whichever is greater.
Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow.
Some retention will be left along the stream buffer to provide additional windthrow protection.
Wildlife/Biological Diversity
Concern:
Unit is wildlife travel corridor between high and low elevations. Large amount of high Volstrata
in unit. 25 acres of high value deer habitat (HSI >0.60) and 25 acres marten value habitat (HSI
>0.89) values occur within the unit.
Response: Retention of 50% area would mitigate harvest by retaining some old-growth characteristics,
maintaining travel corridor and retaining marten and deer habitat.
Recreation/Scenery
Concern: Lower portion of unit (18 acres) located within Forest Plan Recreational River land use
designation.
Response: Measures taken to minimize the potential effects on scenery from timber harvest for this project
were limited to the design of Units 414 and 415 within the Kadake Creek Recreational River
corridor using a harvest method of 50 percent area retention.
No resource concerns for: Soils, Karst, Wetlands, Heritage, Vegetation
82 • Appendix B
Kuiu Timber Sale FEIS
I ^
1
Kuiu Unit 415 Alternative 2,4
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Recreational River Corridor
Proposed Unit 415 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
0
Fd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 416
Unit Acres: 44
Alternatives: 2, 3, 4, 5
1999 Aerial 598 95,
Photo: 598 94
Land Use i r> j x-
Designation: Timber Production
vlme:'""' 1,409 MBF
TM-Compartment ^ . .
and Stand:
High 43
Volume Strata x* .• ,
Acres: Medium 1
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, eleareut
Logging Method/ Transportation: Cable / One temporary road and one reeonditioned NFS Road (46091)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern:
Stream 1 is Class II, Channel Type MC2. ■
Stream 2 is Class IV, Channel Type HC5. :
Stream 3 is Class IV, Channel Type HC5. , v
Response:
Stream 1 : No programmed commercial timber harvest within the RMA, which is defined as
within 1 00 feet of the channel, or to the top of the side-slope break, whichever is greater. ( ;
Implement BMPs 12.6, 12.6a, 13.9, and 13.16. | f
Streams 2 and 3: Split yard away from Class IV streams whenever possible. Buck, limb, and top :
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern:
Unit has high Volstrata. 13 acres of high value deer habitat (HSI >0.60), 23 acres of medium !
value deer habitat (HSI 4.0 to 5.0) along with 25 acres of high value marten habitat (HSI >0.89) i '
occur within the unit.
Response:
Clearcut harvest would not isolate habitat and area is not an isolated corridor. 1
No resource concerns for: Soils, Scenery, Heritage, Vegetation, Karst, Wetlands
84 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 416 Alternative 2, 3, 4,5
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 416 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 417
Unit Acres: 24
Alternatives: 2, 3, 5 |
1999 Aerial 198 70,
Photo: 198 71
SjnSon: Timber Production
Net Timber 387 MBF Alt 3 |
Volume: 774 mBF Alt 2 & 5 |
TM-Compartment „ ,
and Stand:
High 24 11
Volume Strata j- J
Acres: Medium 0
Low 0 9
Existing Stand Condition: Old-growth
Silvicultural Prescription: Alts 2 and 5 Even-aged management, clearcut
Alt 3 Two-aged management, 50% area retention, clearcut with reserves
Logging Method/ Transportation: Cable / One reconditioned NFS Road (46094)
Resource Concerns & Responses
Fish Habitat/Watershed
Concern: Stream 1 is Class III, Channel Type HC3
Streams 2, 3, and 4 are Class IV, Channel Type HC5.
Response: Stream 1 : No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 2, 3, and 4: Split yard away from Class IV streams whenever possible. Buck, limb, and
top felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Wildlife/Biological Diversity
Concern:
Response:
High amount of animal use was reported. High Volstrata exists within the unit. Area is wildlife
travel corridor between high and low elevations. 3 acres of high value deer habitat (HSI >0.60),
15 acres of medium value deer habitat (HSI 4.0 to 5.0) along with 24 acres of high value marten
habitat (HSI >0.89) occur within the unit.
50% area retention in Alternative 3 would mitigate the harvest of old-growth habitat by retaining
corridor function and retaining some old-growth characteristics. Even-aged prescriptions in
Alternatives 2 and 5 would remove the travel corridor.
No resource concerns for: Soils, Wetlands, Karst, Scenery, Heritage, Vegetation
! /
! I
86 • Appendix B
Kuiu Timber Sale FEIS
/
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 417 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 418
Unit Acres: 45
Alternatives: 2. 4, 5 >
’ ’ i|
1999 Aerial 198_70,
Photo: 198 71
Des^natlon: timber Production
Net Timber 344 MBF Alt 2 |
Volume: 687 MBF Alts 4, 5
TM-Compartment
and Stand: ~ ^
High 1 7
Volume Strata i a
Acres; Medium 14
Low 14
Existing Stand Condition; Old-growth
Silvicultural Prescription: Alt 2 Two-aged management, 50% area retention, clearcut with reserves
Alts 4 and 5 Even-aged management, clearcut
Logging Method/ Transportation: Shovel / One temporary road and one existing NFS Road (6402)
Resource Concerns & Responses
A
Fish Habitat/Watershed
Concern:
Response:
Stream 1 is Class II, Channel Type MC2.
Stream 2 is Class IV, Channel Type HC5.
Stream 3 is Class IV, Channel Type HC5.
Stream 4 is Class III, Channel Type HC5.
Stream 1 : No programmed commercial timber harvest within the RMA, which is defined as
within 1 00 feet of the channel, or to the top of the side-slope break, whichever is greater.
Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 2 and 3: Split yard away from Class IV streams whenever possible. Buck, limb, and top
felled trees clear of streamcourses. Remove any slash deposited in streamcourse as a result of
timber harvest activities. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Stream 4: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow.
Streams 1 and 4: Alt 2 Some retention will be left along the stream buffer to provide additional
windthrow protection. In Alts 4 and 5, the riparian buffer will be protected by feathering the edge
for a distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that
cannot be felled away from the buffer will be retained.
Wildlife/Biological Diversity
Concern:
Response:
Concern:
Response:
High amount of animal use was reported. High, medium and low Volstrata exists within the unit.
Wildlife corridor exists between high and low elevations. 17 acres of high value deer habitat (HSI
>0.60), 1 1 acres of medium value deer habitat (HSI 4.0 to 5.0) along with 17 acres of high value
marten habitat (HSI >0.89) occur within the unit.
50% area retention in Alternative 2 would mitigate the harvest by retaining function of the travel
corridor. Additionally, it would reduce the impacts to high volume old-growth by retaining some
of the characteristics. Deer and marten habitat values would be retained.
Clearcut harvest in Alternatives 4 and 5 would remove the travel corridor.
No resource concerns for: Scenery, Heritage, Soils, Vegetation, Karst, Wetlands
88 • Appendix B
Kuiu Timber Sale FEIS
\-
\-
/' /
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 418 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Fd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 503
Unit Acres: 95
Alternatives: 4, 5
1999 Aerial 198 102,
Photo: 103, 104
SgnSon: Timber Production
Net Timber
Volume: 2,637 MBF
TM-Compartment ^
and Stand: ’ °
High 65
Volume Strata i-
Acres: ^0
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, elearcut
Logging Method/ Transportation: Cable / One temporary road, reeondition and extend NFS Road (6427)
Resource Concerns & Responses
Fish Habitat/Watershed
Coneern:
Response:
Concern:
Response:
Wildlife/Biological Diversity
Concern: High animal use. High use of the game trails as a wildlife travel corridor exists between high and
low elevations. Large amount of high and medium Volstrata would be harvested in this unit. 5
acres of high value deer habitat (HSI >0.60), 67 acres of medium value deer habitat (HSI 4.0 to
5.0) along with 63 acres of high value marten habitat (HSI >0.89) within unit.
Response: Concerns not addressed. Harvest would eliminate travel corridors between low and high
elevations in this unit.
Vegetation/Timber
Concern: Even-aged opening size is close to 100 acres.
Response: During layout ensure harvest unit does not exceed 100 acres.
No resource concerns for: Soils, Wetlands, Karst, Scenery, Heritage fV
Stream reach 1 is Class III, Channel Type HC6.
Stream reach 2 is Class II, Channel Type HC6.
Stream 3 is Dean Creek and is Class II, Channel Type HC3.
Stream 4 is Dean Creek and is Class III, Channel Type HC3.
Stream 5 is Class III, Channel Type HC5.
Streams 1, 4, and 5: No programmed commercial timber harvest within the RMA, which is
defined as the top of the V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Streams 2 and 3: No timber harvest within 100 feet of stream, or within the v-notch (side slope
breaks). Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow.
Streams 1, 2, 3, 4 and 5 in Alts 4 and 5, the riparian buffer will be protected by feathering the
edge for a distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that
cannot be felled away from the buffer will be retained.
\
I
ir
'y
)'
(
90 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Unit 503 Alternative 4,5
I I I
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Recreational River Corridor
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 503 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissioned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
Pd
660
1320
Scale is 1 inch = 660 feet
Kuiu Timber Sale Unit Card
Unit Number: 504
Unit Acres: 25
Alternatives: 4, 5
1999 Aerial 1 98 102,
Photo: 198 103
Sgnatlon: timber Production
Net Timber aotaai-.t’
Volume:
TM-Compartment ~
and Stand:
High 14
Volume Strata ii
Acres: Medium 1 1
Low 0
Existing Stand Condition: Old-growth
Silvicultural Prescription: Even-aged management, clearcut
Logging Method/ Transportation: Cable / Recondition one NFS Road (6427)
s
Resource Concerns & Responses
Fish Habitat/Watershed
Stream 1 is Class III, Channel Type HC6.
Stream 2 is Class III, Channel Type HC5.
Stream 3 is Class III, Channel Type HC2.
All Streams: No programmed commercial timber harvest within the RMA, which is defined as the
V-notch. Implement BMPs 12.6, 12.6a, 13.9, and 13.16.
Location makes this stand susceptible to windthrow.
Streams 1 and 2: In Alts 4 and 5, the riparian buffer will be protected by feathering the edge for a
distance of 50 horizontal feet where trees less than 16 inches DBH and those trees that cannot be
felled away from the buffer will be retained.
Wildlife/Biological Diversity
Concern; High animal use. High use of the game trails as a wildlife travel corridor between high and low
elevation exists within this unit. Large amount of high and medium Volstrata would be harvested
in this unit. 1 1 acres of medium value deer habitat (HSI 4.0 to 5.0) and 13 acres of high value
marten habitat (HSI >0.89) occur within the unit.
Response: Clearcut harvest would remove travel corridors between low and high elevations with the harvest
of this unit.
No resource concerns for: Soils, Wetlands, Karst, Scenery, Heritage, Vegetation
Concern:
Response:
Concern:
Response:
92 • Appendix B
Kuiu Timber Sale FEIS
2100-
Kuiu Unit 504 Alternative 4,5
[
Existing Managed Stands
Riparian Management Area
Forest Plan Old-Growth Reserve
Extreme Hazard Soils
High Hazard Soils
Proposed Unit 504 Boundary
Adjacent Proposed Units
Stream Value Class I
Stream Value Class II
Stream Value Class III
Stream Value Class IV
Open NFS Roads
Closed NFS Roads
Decomissloned Roads
Proposed NFS Roads
Reconditioned Roads
Proposed Temporary Roads
100-ft. Contour Interval
N
660
1320
Scale is 1 inch = 660 feet
o
94 • Appendix B
' *•» I
This page intentionally left blank
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Kuiu Ti^_
Road Cards
Kuiu Timber Sale FEIS
Appendix B • 95
Intended
Purpose
/Future Use
General
Design Criteria
and Elements
Maintenance
Criteria
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 associated with timber harvest activities for this project.
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. See Figure B-
2 for a map of the Kuiu Timber Sale 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.
This information is critical for determining whether a Corps of
Engineer’s permit will be required for segments of road crossing
wetlands. Roads built solely for silvicultural purposes do not require
these permits.
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
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 and revegetate as needed
to control runoff.
The active maintenance strategy is applied to roads 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 intemiediate maintenance strategy is to storm proof, or stabilize
the road, by providing roadway features such as drivable water bars
Kuiu Timber Sale FEIS
Appendix B • 97
Road Cards
Operation
Criteria
Site-specific
Design Criteria
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 stretehes 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
intemiittent use roads during their closure cycle. Road storage is
defined in FSH 5409.17 as “the process/action of elosing a road to
vehiele 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
are 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 to define road
management considerations, leading to a maintenance strategy to be
applied to each road in the Kuiu Timber Sale Area. Figure B-2 shows
the desired future condition of each road in the project area as a result
of the process. The work needed to meet the objeetives can be
accomplished on the roads along the haul route in these timber sales.
Work needed on other roads to meet the desired objective will be
scheduled as funding allows.
The operations criteria include a presentation of each of the five traffic
management strategies identified in FSM 773 1 (encourage, accept,
discourage, prohibit, and eliminate) to be applied to different traffic
classes on each road. The traffic management narrative describes what
aetions 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 structures, gating, etc.
The site-specific design criteria include road location objectives,
wetland information, erosion control, proposed rock borrow sources,
and all streams within the project area with proposed construetion or
rehabilitation of stream crossing structures. Site-specific design criteria
for the proposed reconstruction of designated roads for this project
include timing restrictions for construction activities (Table B-3).
98 • Appendix B
Kuiu Timber Sale FEIS
Road Cards
Table B-3. Stream classes, species of concern, and construction
timing windows for stream crossings on designated roads proposed
for reconstruction
ROAD#
MILE POST
STREAM
CLASS
SPECIES OF
CONCERN
CONSTRUCTION
TIMING WINDOW
6417
0.119
II
CT
July 18 -- Aug 15
6417
0.789
II
DV
No restriction
6417
0.793
II
DV
No restriction
6417
0.925
1
SS, DV
June 1 -- Sept 1
6417
1.209
1
SS, CT, DV
July 18 -- Aug 15
6417
1.456
1
SH, PS, DV
July 18 -- Aug 1
6427
NONE
NONE
NONE
No restriction
46091
NONE
NONE
NONE
No restriction
46094
NONE
NONE
NONE
No restriction
6422
NONE
NONE
NONE
No restriction
6443
0.125
1
SS
June 1 -- Sept 1
CT = cutthroat, DV = Dolly Varden, SS = silver salmon, SH = steelhead,
PS = pink salmon
Kuiu Timber Sale FEIS
Appendix B • 99
Road Cards
This page intentionally left blank
100 • Appendix B
Kuiu Timber Sale FEIS
Kuiu Timber Sale
Figure B-2
Proposed Road Maintenance Levels
Legend
IBI Productive Old-Growth
I I Managed Stands
I I Non-National Forest
Lakes/Saltwater
..... Project Area Boundary
Suitable for Passenger Vehicles
===== High Clearence Vehicles
Basic Custodial Care (Closed)
500ft Contour Interval
Stream Value Class I & II
A
0 0.5 1
3 4
Miles
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
ML OG RM SM TM
Route No
Route Name
Begin Terminus
End Terminus
6402 I
Kuiu Mainline
Saginaw Bay LTF
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
’98 598-127-128, 298-123, 198-78,
0.00
31.92
Existing
PAD1,C1,PB C6
105 to 1 12, 198-64 to 70, 298-138,
598-145 to 147, 83, 698-4, 69,798-
196, 133, 13,498-140, 139, 29, 30
Functional
Class
Local
Service
Life
LI
Surface
General Design Criteria and Elements
Design
Width Speed Critical Vehicle
Shot rock
16'
30
Lowboy
Design Vehicle
Lowboy
Intended Purpose/Future Use
serves as main arterial road from Saginaw Bay to Threemile Arm, will remain open to all traffic to junction with 6434.
Maintenance Criteria
Bmp
Emp
Operational Maintenance Level
(Current Condition)
Objective Maintenance Level
(Desired Future Condition)
0.00
28.75
3
3
28.75
31.92
3
1
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 on open segment
Discourage:
N/A
Prohibit:
Motorized vehicles on closed segment
Eliminate:
Motorized vehicles on closed segment
Travel Management Narrative
Road will remain open to all traffic except for last 3 miles. Road closure may include any combination of tanktraps at the
ibeginning 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. Additional stream structures and road
cross drain structures may be removed if necessary to address resource concerns.
Approved
District Ranger Date
'I'Kuiu Timber Sale FEIS
Appendix B • B-103
Road Management Objective
Project
System
l.and Use Designation
Kuiu
1 Kuiu
OG TM
Route No
Route Name
Begin Terminus
End Terminus
6404
1 Rowan Bay
Rowan Bay Sortyard
6402 MP 14 1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
4.43
Existing
PA Cl NW
’98 198-66, 118 to 122
General Design Criteria and Elements
Functional
Service
Design
Class
Life
Surface
Width
Speed
Critical Vehicle
Design Vehicle
Local
LI
Shot rock
16'
1 30
1 Lowboy
Lowboy
Intended Purpose/Future Use
Road will be maintained to facilitate travel passenger car at 30 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Maintenance Criteria
Bmp Emp Operational Maintenance Level Objective Maintenance Level
(Current Condition) (Desired Future Condition)
0.00 4.43 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
B-104 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
TM
Route No
Route Name
Begin Terminus
End Terminus
6413
1 South Fork Saginaw
6402 MP 2
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
1 0.00
2.84
Existing
PA D1 SE
’98 598-128 to 132
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
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
2.84
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 1 0 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act:
No
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1 ). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved_
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-105
Road Management Objective
System Land Use Designation
I Kuiu
Kuiu
OG RR TM
Route No
Route Name
Begin Terminus
End Terminus
6415
Kuiu Connection
6402 MP 13
6402 MP 2
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
’98 598-128, 103, 698-24, 50, 798-
0.00
18.51
Existing
PA Cl NW, PADl SE, SW
178 to 183,698-57,16,598-94,
137, 298-132 to 135
General Design Criteria and Elements
Functional
Class
Local
Service
Life
LI
Design
Surface
Shot rock
Width
Critical Vehicle
1
16’
Ho
Lowboy
Design Vehicle
Lowboy
Intended Purpose/Future Use
Serves as part of loop road on north Kuiu between Rowan and Saginaw Bays.
Maintenance Criteria
Bmp
Emp
Operational Maintenance Level
(Current Condition)
Objective Maintenance Level
(Desired Future Condition)
0.00
18.51
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.
Highway Safety Act:
Yes
Operation Criteria
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
Keep road open to all traffic.
Approved
District Ranger Date
B-106 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Project
Functional
Class
System
Land Use Designation
Kuiu
1 Kuiu
1 tm I
Route No
Route Name
Begin Terminus
End Terminus
6417
Security Bay Connection
6402 MP 7
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
3.67
Existing
PADl SW
’98 198-107, 108, 74, 298-127 to
129
Service
Life
General Design Criteria and Elements
Design
Surface
Width
Critical Vehicle
Design Vehicle
Local
LI
Shot rock |
1 1^'
1 1°
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
3.67
1
0.00
2.50
2
0.00
3.67
1
Maintenance Narrative
When road is reopened, it will be maintained to facilitate travel by pickup truck at 10 inph. All culverts, ditches and drainage
structures will be serviced, and road brushed.
Highway Safety Act: No
Traffic Encourage:
Management
Strategies Accept:
Discourage:
Prohibit:
Eliminate:
Operation Criteria
Jurisdiction: National Forest ownership
Hikers, bicycles
High clearance vehicles when open
N/A
Motorized vehicles on closed section
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-107
Road Management Objective
Project
System
Land Use Designation
I Kuiu
1
Kuiu 1
TM 1
Route No
Route Name
Begin Terminus
End Terminus
6418
1 Upper Saginaw Bay
6402 MP3 1
J
Begin MP
Length
Status
Map Quarter Quad Photo year, roll, photos
0.00
1.70
Existing
1
PA D1 SW
’98 298-123,124,198-77 |
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
14'
1 0 Log truck
1 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)
Alaska Forest Practices Act Class
0.00
1.70
2
Active
0.00
1.70
1
Closed
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act:
No
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1 ). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-108 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
TM
Route No
Route Name
Begin Terminus
End Terminus
6422
Saginaw Bay |
6417 MP 2 1
1
Begin MP
Length
Status
Map Quarter Quad Photo year, roll, photos
0.00
0.24
I Existing
PADl SW
’98 198-73
General Design Criteria and Elements
Functional
Class
Service
Life
Surface Width
Design
Speed Critical Vehicle
Design Vehicle
Local
u II
Shot rock 14'
1 0 1 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
0.24
1
0.00
0.24
2
0.00
0.24
1
Maintenance Narrative
When road is reopened, it will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage
structures will be serviced, and road brushed.
Highway Safety Act:
No
Operation Criteria
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-109
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
I TM
Route No
Route Name
Begin Terminus
End Terminus
6425
Dean Creek
I 6402 MP 5
I
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
6.47
Existing
PADl SW, NW
’98 198-105, 104, 198-219 to 222,
198-100
General Design Criteria and Elements
Functional
Class
Service
Life Surface
Width
Design
Speed Critical Vehicle Design Vehicle
Local
LI Shot rock
1 1
I 20 Lowboy
Lowboy
Intended Purpose/Future Use
Access for silvicultural activities. Close road at junction with road 46251 until needed in the future.
Maintenance Criteria
Bmp
Emp
Operational Maintenance Level
(Current Condition)
Objective Maintenance Level
(Desired Future Condition)
0.00
4.76
2
2
4.76
6.47
1
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 20 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Highway Safety Act: Yes
Operation Criteria
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
The first part of the road will remain open to all traffic and the last 1.71 miles of road will remain closed.
Approved
District Ranger Date
B-110 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Project
System
Land Use Designation
Kuiu
I
Kuiu
TM
Route No
Route Name
Begin Terminus
End Terminus
6427
Security Bay
I
6425 MP 2 I
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
3.44
I Existing
PADl SW I I
’98 198-103, 104, 81
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
Ly
Shot rock
□fn
I
I 1 0 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
1.15
2
0.00
3.44
2
0.00
3.44
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act; No
Jurisdiction: National Forest ownership
Traffic Encourage:
Management
Strategies Accept:
Hikers, bicycles
High clearance vehicles on open section
Discourage: N/A
Prohibit: Motorized vehicles on closed section
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-11 1
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
TM
Route No
Route Name
Begin Terminus
End Terminus
6448
Saginaw
Camp
1 Saginaw Bay LTF
1 Pentilla’s Camp
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
0.81
Existing
PADISW 1
’98 598-126,298-119 |
Functional
Class
Service
Life
Surface
General Design Criteria and Elements
Design
Width Speed Critical Vehicle Design Vehicle
Local
LI
Shot rock
16'
1 0 Lowboy
Lowboy 1
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
0.81
2
2
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act:
No
Jurisdiction: National Forest ownership
T raffle
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
All motorized vehicles when open
Discourage:
N/A
Prohibit:
N/A
Eliminate:
N/A
Travel Management Narrative
Road will remain open to all traffic.
Approved
District Ranger Date
B-1 12 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Project System Land Use Designation
Kuiu
1
Kuiu
TM
Route No
Route Name
Begin Terminus
End Terminus
46021
Security Ridge
6402 MP 4.59
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
1 0.00
1.38
Existing
PADISW 1
’98 198-78, 106
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
1 14' 1
1 1 0 Log truck
Log truck
Intended Purpose/Future Use
Local road used for silvicultural activities, will be opened periodically, closed during times of inactivity. Serves as telephone
receiving area.
Maintenance Criteria
Bmp
Emp
Operational Maintenance Level
(Current Condition)
Objective Maintenance Level
(Desired Future Condition)
0.00
1.38
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
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
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenanee level 1 ). Road
closure may include any combination of tanktraps at the beginning of the road, pulling some or all drainage stmctures such as
culverts, and/or gating. This road will be further evaluated for the most effective and efficient closure method prior to
implementation. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-113
Road Management Objective
Project
System
Land Use Designation
Kuiu
1
Kuiu 1
RR TM
Route No
Route Name
Begin Terminus
End Terminus
46091
1 Wilder
1
6415 MP 5
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
1 1.58
Existing
1
PADl SE
’98 598-94, 95 |
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
1 '‘t 1
1 10 Log truck
1 1 Log truck 1
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
1.58
1
0.00
1.10
2
0.00
1.58
1
Maintenance Narrative
When road is reopened, it will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage
structures will be serviced, and road brushed.
Highway Safety Act: No
Operation Criteria
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-1 14 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Land Use Designation
TM
Route No Route Name Begin Terminus End Terminus
46094
I Burke Wind
1 6402 MP 13
1 1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00 I
1.58 1
Existing
PA Cl NW, PADl SW
1 ’98 198-69,70,71
Project
Kuiu
System
Kuiu
General Design Criteria and Elements
Functional
Class
Service
Life Surface
Design
Width Speed
Critical Vehicle
Design Vehicle
Local
LI Shot rock
14' 1 10
Log truck
1 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
1.58
1
0.00
0.80
2
0.00
1.58
1
Maintenance Narrative
When road is reopened, it will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage
structures will be serviced, and road brushed.
Operation Criteria
Highway Safety Act:
No
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain first 0.80 miles as maintenance level 2 during project activities. Close road after timber harvest (maintenance level
1 ). 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. Additional stream structures and road cross drain structures may be removed if necessary to
address resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-115
Road Management Objective
Project
System
Land Use Designation
Kuiu
I
Kuiu 1
r™ 1
Route No
Route Name
Begin Terminus
End Terminus
46096
I Shorty
6413 MP2
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
3.80
Existing
PA D1 SW, SE
’98 598-132, 198 to 102
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle Design Vehicle
Local
LI
Shot rock
I 1
1 1 0 1 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
3.80
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act:
No
Jurisdiction:
National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehicles when open
Discourage:
N/A
Prohibit:
Motorized vehicles on closed section
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1 ). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-116 • Appendix B
Kuiu Timber Sale FEIS
Road Management Objective
Project
Land Use Designation
Kuiu
I
Kuiu
OG TM
Route No
Route Name
Begin Terminus
End Terminus
I 46430 I
6415 MP 3.50
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
2.56
I Planned
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local I
LI
Shot rock
I I I
1 1 0 Log truck
Log truck 1
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
2.56
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act: No
Jurisdiction: National Forest ownership
Traffic Encourage:
Management
Strategies Accept:
Hikers, bicycles
High clearance vehicles
Discourage: N/A
Prohibit: N/A
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved^
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-117
Site Specific Design Criteria
Road 46030
ROAD LOCATION: The road steadily gains elevation between the beginning point at the
existing Road 6415. The 6,100 feet follows the existing roadbed of a decommissioned
temporary road. At about 6,100 feet the road leaves the existing decommissioned roadbed
and heads west across a muskeg forest mix saddle area toward the next hillside that contains
the timber units. At about 6,900 feet a stream crossing is needed using a 50 foot log stringer
bridge. At about 7,400 feet until the end of the road, the road is slowly gaining elevation on
timbered hillsided to access the timber units.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). Most of this road
segment would be constructed as timber access road.
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: 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:
MP 1.35 AHMU 11 Channel Type MMl BF Width 17 ft Incision 13 ft Substrate bedrock,
cobble Gradient 3% Structure 50’ Log Stringer Bridge Narrative: Mostly bedrock. No timing
required.
B-118 • Appendix B
Kuiu Timber Sale FEIS
Legend
Road 46030
Units
Contours 1 00 ft.
Stream Class I
Stream Class II
Stream Class III
Suitable for Passenger Vehicles {ML3)
High Clearence Vehicles (ML2)
‘ • Basic Custodial Care (Closed) (ML1)
■“ ^ New NFS Designated Construction (ML2)
= = = Reconditioned
New Temporary Construction
0 660 1,320 2,640
Feet
1 inch equals 1 ,320 feet
Road Management Objective
Project
System
Land Use Designation
Kuiu
' 1
Kuiu
OG TM
Route No
Route Name
Begin Terminus
End I'erminus
4603 1 1
1
6415 MP 3.92 ||
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
0.67
Planned
1
1
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
14'
1 0 Log truck
1 Log truck 1
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 Objective Maintenance Level
(Current Condition) (Desired Future Condition)
0.00 0.67 2 1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
servieed, and road brushed.
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
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road eross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-120 • Appendix B
Kuiu Timber Sale FEIS
Site Specific Design Criteria
Road 46031
ROAD LOCATION: The road steadily gains elevation between the beginning point at the
existing Road 6415. The first 2,000 feet follows the existing roadbed of a decommissioned
temporary road. At the end of the existing decommissioned roadbed the new road heads to
the northeast across timbered land on a sideslope gaining elevation till it accesses unit 414.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). Most of this road
segment would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
Kuiu Timber Sale FEIS
Appendix B • B-121
Legend RO0Cl 46031
Units
Contours 100 ft.
Stream Class 1
Stream Class II
Stream Class III
- — Basic Custodial Care (Closed ) (ML 1 )
” ’ New NFS Designated Construction (ML2)
-= Reconditioned
New Temporary Construction
0 660 1,320 2,640
Feet
1 inch equals 1,320 feet
'■ - Suitable for Passenger Vehicles (ML3)
High Clearence Vehicles (ML2)
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
OG TM
Route No
Route Name
Begin Terminus
End Terminus
46032
46096 MP 1.10
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00 I
1.39
Planned
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
I Local
LI 1
Shot rock
14'
1 0 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
1.39
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Highway Safety Act: No
Traffic Encourage:
Management
Strategies Accept:
Operation Criteria
Jurisdiction: National Forest ownership
Hikers, bicycles
High clearance vehicles
Discourage: N/A
Prohibit: N/A
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1 ). Road
closure may include any combination of tanktraps at the beginning of the road, pulling some or all drainage stnactures such as
culverts, and/or gating. This road will be further evaluated for the most effective and efficient closure method prior to
implementation. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved^
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-123
Site Specific Design Criteria
Road 46032
ROAD LOCATION: The road steadily gains elevation between the beginning point at the
existing Road 46096. The first 1,500 feet steadly gains elevation through a 15 year old
clearcut. The road then enters timber sideslope and continues to gain elevation at an average
of 10% to 15%. The majority of the road is located on sideslope averaging about 40 to 50%.
WETLANDS; The road location crosses no mapped wetlands (BMP 12.5). This road segment
would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
B-124 • Appendix B
Kuiu Timber Sale FEIS
Legend Road 46032
Units
Contours 100 ft.
stream Class I
Stream Class II
Stream Class III
“ ” Suitable for Passenger Vehicles (MLS)
==- High Clearence Vehicles (ML2)
• “ ‘ Basic Custodial Care (Closed) (ML1 )
— - New NFS Designated Construction (ML2)
=== Reconditioned
New Temporary Construction
0 660 1,320 2,640
Feet
1 inch equals 1,320 feet
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
OG TM
Route No
Route Name
Begin Terminus
End Terminus
46033
46032 MP 1.10
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00
0.17
Planned
1
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
14'
1 0 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 Euture Condition)
0.00
0.17
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Highway Safety Act: No
Traffic Encourage:
Management
Strategies Accept:
Operation Criteria
Jurisdiction: National Forest ownership
Hikers, bicycles
High clearance vehicles
Discourage: N/A
Prohibit: N/A
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1 ). 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. Additional stream stmctures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-126 • Appendix B
Kuiu Timber Sale FEIS
Site Specific Design Criteria
Road 46033
ROAD LOCATION: The road steadily gains elevation between the beginning point at the
planned Road 46032. The majority of the road is located on sideslope averaging about 40 to
50%.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). This road segment
would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
Kuiu Timber Sale FEIS
Appendix B • B-127
Legend
Units
Contours 1 00 ft.
Stream Class I
Stream Class II
Stream Class III
— - Suitable for Passenger Vehicles (ML3)
; High Clearance Vehicles (ML2)
Basic Custodial Care (Closed) (ML1)
New NFS Designated Construction {ML2)
“ Reconditioned
— New Temporary Construction
Alternative 2 & 4 Road 46033
0 660 1,320 2,640
Feet
1 inch equals 1,320 feet
Legend
Units
Contours 100 ft.
Stream Class I
Stream Class II
Stream Class 111
Basic Custodial Care (Closed) (MLI )
— - New NFS Designated Construction (ML2)
=== Reconditioned
New Temporary Construction
Alternative 3 & 5 Road 46033
0 660 L320 2,640
Feet
1 inch equals 1 ,320 feet
— - Suitable for Passenger Vehicles (ML3)
=== High Clearence Vehicles (ML2)
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu 1 1
OG TM
Route No
Route Name
Begin Terminus
End Terminus
46034
1
6417 MP 1.35
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
0.00 I
1.25
Planned
1
1
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
14’
1 0 Log truck
Log truck 1
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 to facilitate travel by pickup truck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act: No Jurisdiction: National Forest ownership
Traffic Encourage:
Management
Strategies Accept:
Hikers, bicycles
High clearance vehicles
Discourage: N/A
Prohibit: N/A
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-130 • Appendix B
Kuiu Timber Sale FEIS
Site Specific Design Criteria
Road 46034
ROAD LOCATION; The road steadily gains elevation between the beginning point at the
existing Road 6417. The first 2,400 feet follows the existing roadbed of a decommissioned
temporary road. At the end of the existing decommissioned roadbed the new road heads to
the northeast and steadly gains elevation through a 15 year old clearcut. The road then enters
timber sideslope and continues to gain elevation at an average of 10% to 15%. The majority of
the road is located on sideslope averaging about 30 to 40%.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). Most of this road
segment would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
Kuiu Timber Sale FEIS
Appendix B • B-131
Legend
I Alternative 4
Contours 100 ft.
Stream Class I
Stream Class II
■ Basic Custodial Care (Closed) (ML1)
•” ' New NFS Designated Construction (ML)
=== Reconditioned
New Temporary Construction
Road 46034
0 660 1,320 2,640
fi I I
1 inch equals 1,320 feet
stream Class III
Suitable for Passenger Vehicles (ML3)
High Clearence Vehicles (ML2)
Road Management Objective
Project
System
Land Use Designation
Kuiu
Kuiu
OG TM
Route No
Route Name
Begin Terminus
End Terminus
46035
6415 MP 1.19
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
I 0.00
1.25
1 Planned
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle
Design Vehicle
Local
LI
Shot rock
14'
1 0 Log truck
Log truck
Intended Purpose/Future Use
Local road used for silvicultural activities, will be opened periodieally, closed during times of inactivity.
Maintenance Criteria
Bmp
Emp
Operational Maintenance Level
(Current Condition)
Objective Maintenance Level
(Desired Future Condition)
0.00
0.31
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup tmck at 10 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Highway Safety Act: No
Traffic Encourage:
Management
Strategies Accept:
Operation Criteria
Jurisdiction: National Forest ownership
Hikers, bicycles
High clearance vehicles
Discourage: N/A
Prohibit: N/A
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-133
Site Specific Design Criteria
Road 46035
ROAD LOCATION: The road steadily gains elevation between the beginning point at the
existing Road 6415. The first 600 feet is through a 15 year old clearcut. At the end of the
clearcut the new road heads to the northwest along timbered sideslope and steadly gains
elevation at an average of 10% to 15%. The majority of the road is located on sideslope
averaging about 30 to 40%.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). This road segment
would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
B-134 • Appendix B
Kuiu Timber Sale FEIS
Legend
Road 46035
Units
Contours 1 00 ft.
Stream Class I
Stream Class II
Stream Class III
■ - ■ Basic Custodial Care (Closed) (ML1)
New NFS Designated Construction (ML2)
= ^ Reconditioned
New Temporary Construction
0 660 1,320 2,640
rill
1 inch equals 1 ,320 feet
- Suitable for Passenger Vehicles (ML3)
= High Clearance Vehicles (ML2)
Road Management Objective
Project
System
Land Use Designation
I Kuiu
1
Kuiu
OGTM 1
Route No
Route Name
Begin Terminus
End Terminus
46021 1
1
46021 MP 1.38
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
1.38
0.60
Planned
1 1
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle Design Vehicle
Local
LI
Shot rock
1 1 1
1 1 0 1 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)
1.38
1.98
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 1 0 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act: No
Jurisdiction: National Forest ownership
Traffic Encourage:
Management
Strategies Accept:
Hikers, bicycles
High clearance vehicles
Discourage: N/A
Prohibit: N/A
Eliminate: Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1 ). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
B-136 • Appendix B
Kuiu Timber Sale FEIS
Site Specific Design Criteria
Road 46021
ROAD LOCATION: The road steadily gains elevation between the beginning point at the end
of existing Road 46021 . The first 400 feet is through a 1 5 year old clearcut. At the end of the
clearcut the new road heads to the south along timbered sideslope steadly gains elevation at
an average of 10% to 15%. The majority of the road is located on sideslope averaging about
30 to 40%.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). This road segment
would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
Kuiu Timber Sale FEIS
Appendix B • B-137
Legend
Road 46021
Units
Contours 100 ft.
Stream Class I
Stream Class II
Stream Class III
- ■ • • ‘ Basic Custodial Care (Closed) (MLI)
=— =” New NFS Designated Construction (ML2)
Reconditioned
New Temporary Construction
0 660 1,320 2,640
— — Feet
1 inch equals 1,320 feet
- • Suitable for Passenger Vehicles (ML3)
High Clearence Vehicles (ML2)
Road Management Objective
Project System Land Use Designation
Kuiu
Kuiu
OG TM
Route No
Route Name
Begin Terminus
End Terminus
6427
6427 MP 3.44
1
Begin MP
Length
Status
Map Quarter Quad
Photo year, roll, photos
3.44
1 0.22
Planned
1
General Design Criteria and Elements
Functional
Class
Service
Life
Surface
Width
Design
Speed Critical Vehicle Design Vehicle
Local
LI
Shot rock
14'
10 Log tmck
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
(Planned Initial Condition)
Objective Maintenance Level
(Desired Future Condition)
3.44
3.66
2
1
Maintenance Narrative
Road will be maintained to facilitate travel by pickup truck at 15 mph. All culverts, ditches and drainage structures will be
serviced, and road brushed.
Operation Criteria
Highway Safety Act:
No
Jurisdiction: National Forest ownership
Traffic
Encourage:
Hikers, bicycles
Management
Strategies
Accept:
High clearance vehieles
Discourage:
N/A
Prohibit:
N/A
Eliminate:
Motorized vehicles on closed section
Travel Management Narrative
Maintain as maintenance level 2 during project activities. Close road after timber harvest (maintenance level 1). 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. Additional stream structures and road cross drain structures may be removed if necessary to address
resource concerns.
Approved
District Ranger Date
Kuiu Timber Sale FEIS
Appendix B • B-139
Site Specific Design Criteria
Road 6427
ROAD LOCATION: The road steadily gains elevation between the beginning point at the end
of existing Road 6427. The first 700 feet is through a 1 5 year old clearcut. At the end of the
clearcut the new road heads to the southwest along timbered sideslope and steadly gains
elevation at an average of 10% to 15%. The majority of the road is located on sideslope
averaging about 30 to 40%.
WETLANDS: The road location crosses no mapped wetlands (BMP 12.5). This road segment
would be constructed as timber access road.
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: 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 no stream crossings that require site-specific design
consideration for volume of flow, fish habitat, or other design complexity.
B-140 • Appendix B
Kuiu Timber Sale FEIS
Legend
Road 6427
Units
Contours 1 00 ft.
Stream Class I
Stream Class II
Stream Class III
Suitable for Passenger Vehicles (ML3)
Basic Custodial Care (Closed) (ML1)
'"■* ■ New NFS Designated Construction (ML2)
==■ Reconditioned
New Temporary Construction
0 660
1,320
2,640
mu Feet
1 inch equals 1 ,320 feet
High Clearance Vehicles (ML2)
Appendix C
Agency Responses
to Public Comments on the
Kuiu Timber Sale Area Draft
Environmental
Impact Statement
Introduction to Appendix C
After the Kuiu Timber Sale Area Draft Environmental Impact Statement (DEIS) was
made available to the public, a Notice of Availability was published in the Federal
Register on February 2, 2006. Publication of the Notice started a 45-day public comment
period, which ended on March 20, 2006. Public notices announcing availability of the
DEIS were also published in the Juneau Empire, the Newspaper of Record, and the
Petersburg Pilot, the local Petersburg newspaper.
The Forest Service received approximately 76,200 emails, the majority of which were
form letters generated from the Natural Resources Defense Council and the Wilderness
Society websites. Approximately 100 other letters and emails were received, the majority
expressing disapproval with the project, but they contained no substantive remarks.
Approximately 100 other letters and emails were received, the majority expressing
disapproval with the project, but they contained no substantive remarks. These comments
were noted as well as the preference for Alternative 1, the No Action alternative. The
original comments are in the project planning record.
Additionally, there were 1 1 email comment letters that addressed general issues such as
timber economics, opposition of new roads, the cost of roadbuilding, the exportation of
timber, and the subsidizing of timber companies. None of these letters were specific to
the Kuiu Timber Sale. These comments were considered and many were responded to
within responses to other comments more specific to the Kuiu project. These comments
are in the project planning record.
The Forest Service received 18 substantive comment letters in response to the Kuiu
Timber Sale Area DEIS from agencies, organizations, and individuals (Table D-1). Five
comment letters were received from state and federal agencies, five from organizations
and eight from individuals. The Interdisciplinary Team responded to the comments.
Summary of Comments
The comments received covered several topics and ranged from general issues to quite
detailed concerns about the analysis.
A majority of the letters included comments regarding water quality and fish habitat.
There was concern that logging would increase sedimentation to watershed areas and
create adverse effects to salmon and other types of fish species.
Many concerns were also voiced about the Forest Plan. The comments were that TEMP
had been invalidated in NRDC v. U.S. Forest Service and that the Forest Service should
not be pursuing timber projects until a new Forest Plan for the Tongass is completed.
Timber economics in general, and in relation to the Forest Plan, was also brought up in
several comments.
Some eomments expressed concern about deer. These included: the use of the deer
model, important deer winter range, and affects on subsistence for the residents of Kake.
There were some concerns raised about soil stability and the risk of landslides. It was
suggested that unit boundaries be redrawn to exclude areas with extreme hazard MMI - 4
soils.
Kuiu Timber Sale FEIS
Appendix C • 1
Introduction
One organization expressed a preference for Alternative 4, two agencies preferred
Alternative 2, and the remaining comment letters advocated Alternative 1 , the No- Action
Alternative.
SHPO concurred with the Kuiu Timber Sale Draft EIS, as did the State of Alaska. The
EPA rated the Draft EIS as EC-1 (environmental concerns, adequate information
provided).
Table C- 1. Letters received from Agencies, Organizations, and Individuals
No.
Commenter
Public Numbers
Public
Comment
Agency
Response
1
Alaska Coastal Management Program
C3-6
Cl
2
Environmental Protection Agency
C8-11
C12
3
National Marine Fisheries Service
C13-16
C17-19
4
Department of the Army
C20
C21
5
Organized Village of Kake
C22-24
C25-27
6
Consolidated comments from:
Greenpeace, Sitka Conservation
Society, Juneau Group of the Sierra
Club, The Wilderness Society, and the
Natural Resources Defense Council
C28-70
C71-98
7
Southeast Alaska Conservation Council
C99-106
C107-111
8
The Committee on Conservation of
Forests and Wildlife
C112-114
C115-118
9
Chico Area Fly Fishers
C119-122
C123-125
10
Sealaska Corporation
C126-127
C128
11
Dave Beebe
C129-133
C134-140
12
Edna Jackson
C141-143
C144-145
13
Katie Fearer
C146
C147-148
14
Glen Ith
C149-151
C152-153
15
John Kober
C154
C155-156
16
Mike Jackson
C157-159
C160-162
17
Steve Mashuda
C163-165
C166-168
18
Chris Zimmer, Juneau, Alaska
C169-170
C171-172
19
NRDC form letter
C173
C174
20
WS form letter
C175
C176
2 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #1 - ACMP
DEPARTMENT OF NATURAL RESOURCES
OFFICE OF PROJECT MANAGEMENT/PERMITTING
ALASKA COASTAL MANAGEMENT PROGRAM
j FRANK H. MURKOWSKI, GOVERNOR
a SOUTHCENTRAL REGIONAL OFFICE
550 W 7“ AVENUE SUITE 1660
ANCHORAGE, ALASKA 99501
PH: (907) 269-7470 FAX: (907) 269-3891
A
CENTRAL OFFICE
302 GOLD STREET. SUITE 202
P.O. BOX 111030
JUNEAU, ALASKA 99811-1030
PH: (907) 465-3562 FAX: (907) 465-3075
a
PIPELINE COORDINATORS OFFICE
411 WEST 4™ AVENUE, SUITE 2C
ANCHOFIAGE, ALASKA 99501
PH: (907) 257-1351 FAX (907) 272-3629
Ms. Patricia Grantham
US Forest Service - Peter^ul
PO Box 1328
Petersburg, Alaska 99929
\
anger District
April 26, 2006
Dear Ms. Grantham:
Subject: Kuiu Timber Sale Area Draft EIS
State LD. No. AK 0602-04J
Final Consistency Response - Concurrence
The Office of Project Management and Permitting (OPMP) has completed coordinating the
State’s review of the '‘‘‘Kuiu Timber Sale Area Draft Environmental Impact Statement"
distributed by the USDA Forest Service for consistency with the Alaska Coastal Management
Program (ACMP). The proposed project area is located on Kuiu Island near Kake, Alaska.
ACMP-1
Based upon review by the Alaska Departments of Environmental Conservation and Natural
Resources, OPMP has developed the enclosed final consistency response, in which the State
concurs with the determination that was submitted by the U.S. Forest Service, that the project is
consistent with the ACMP and affected coastal district’s enforceable policies, to the maximum
extent practicable. This will be the final ACMP decision for this project as proposed.
By copy of this letter, I am informing the U.S. Army Corps of Engineers and State review
participants of OPMP’s finding. If you have any questions, please contact me at 907-465-4664
or email joe_donohue@dnr.state.ak.us.
Enclosure
Sincerely,
.
Joe Donohue
ACMP Project Specialist
“Develop, Enhance, and Conserve Natural Resources for Present and Future Alaskans. ”
Kuiu Timber Sale FEIS
Appendix C • 3
Comment Letter #1 - ACMP
cc: Kevin Hanley - ADEC, Juneau *
Mark Fink - ADFG,’ Anchorage *
Doug Sanvik - ADNR/ DMLW, Juneau *
Jim Anderson - ADNR/DMLW, Juneau *
Mike Curran - ADNR/DOF, Ketchikan *
Roy Josephson - ADNR/DOF, Haines*
Jim Cariello - ADNR/OHMP, Petersburg *
Jennifer Becker - ADNR/OPMP, Juneau *
Margie Goatley - ADNR/SHPO, Anchorage *
Andy Hughes - ADOT/PF, Juneau *
Paul Reese - Coastal District, Kake *
Victor Ross - USACE, Regulatory, Ehnendorf AFB/ Anchorage *
Cindy Hartmann - NMFS, Juneau *
Tom Waldo - Earth Justice, Juneau *
Buck Lindekugel - SEACC, Juneau *
Larry Edwards - Greenpeace, Sitka *
Michele Metz - Sealaska Corporation, Juneau *
* = emailed
Final Consistency Response - Concurrence
Page 2 of 5
4 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #1 - ACMP
• Access management measures including storage of classified roads,
• Any necessary project-specific mitigation measures and monitoring requirements,
• A determination whether there may be a significant restriction on subsistence uses, and
• Whether any changes in the small old-growth habitat reserves in Value Comparison Units
(VCUs) 398, 399, or 402 should be made, and approved as a non-signif icant amendment to
the Forest Plan."
Scope of Project to be Reviewed:
The scope of these concurrent NEPA scoping and preliminary ACMP consistency comment
reviews included all information, possible alternatives and their descriptions, and procedural
decisions that are discussed within the “Kuiu Timber Sale Area Draft Environmental Impact
StatemeuC'^-. ^ — .
Consistency Statement:
Based on an evaluation of your project by the Alaska Department of Natural Resources’ -
Division of Mining, Land and Water (DMLW), and Office of Habitat Management and
Permitting (OHMP), and the Alaska Department of Environmental Conservation (ADEC), the
State of Alaska concurs with the consistency determination submitted by the U.S. Forest
Service - Petersburg Ranger District.
Advisories;
Department of Natural Resources:
Office of Habitat Management and Permitting (OHMP) - On March 23, 2006 OPMP had
issued a proposed ACMP consistency response to the U.S. Forest Service as an objection to the
consistency determination submitted by the Federal agency for the proposed “Kuiu Timber Sale
Area” project. The State’s objection was based upon a lack of sufficient detailed project
information that prevented the Department of Natural Resources’ Office of Habitat
Management and Permitting (OHMP) from completing project consistency comments for the
ACMP consistency review.
ACMP - 2
On April 26, 2006 OPMP received an electronic message that the USFS had provided the
Petersburg OHMP office with the information required to complete an assessment of the
consistency of the proposed “Kuiu Timber Sale Area” project with the ACMP standards and
policies. Based upon this additional information, OHMP recommends the proposed project be
found consistent with the ACMP to the extent practicable with the following advisory: "While
Alternative 4 (preferred) makes minimal allowances for wildlife, we strongly recommend the
selection of alternative 2 [for the Record of Decision], which better addresses concerns for
important deer habitat."
Department of Environmental Conservation (ADEC) - On March 14, 2006 OPMP received the
following preliminary ACMP consistency comments:
Final Consistency Response - Concurrence
Page 4 of 5
Kuiu Timber Sale FEIS
Appendix C • 5
Comment Letter #1 - ACMP
ACMP-3
“Pursuant to 11 AAC 110.015 of the Alaska Coastal Management Program and 11 AAC 95 (the
Forest Practices Regulations), the department concurs with the Forest Service's consistency
determination for this project. Our concurrence applies only to the water quality and
fisheries aspects of this sale. We are able to agree with this determination based, in large
part, on the level of information that was provided concerning the proposed road maintenance
and closure methods. In addition, the full implementation of the TLMP process group
standards and guidelines (RIP2.III.E) along all Class I, II, and III streams within the project
area provides reasonable assurance that yarding will be carried out consistent with the
standards of 11 AAC 95.360(a). As indicated above, we strongly recommend that the Forest
Service select Alternative 2 for the Record of Decision for this project, as it best ensures
the maintenance of water quality and fish habitat, and it has the least potential for further
det rimeola 1. cumuloti ve
This consistency response may include reference to specific laws and regulations, but this in
no way precludes an applicant’s responsibility to comply with all other applicable State and
federal laws and regulations.
This consistency response is only for the project as described. If, after issuance of a final
consistency response, the applicant proposes any changes to the approved project, including
its intended use, prior to or during its siting, construction, or operation, the applicant must
contact this office immediately to determine if further review and approval of the
modifications to the project is necessary. Changes may require amendments to the State
authorizations listed in this response, or may require additional authorizations.
If the proposed activities reveal cultural or paleontological resources, the applicant is to stop
any work that would disturb such resources and immediately contact the State Historic
Preservation Office (907-269-8720) and the U.S. Army Corps of Engineers (907-753-2712) so
that consultation per section 106 of the National Historic Preservation Act may proceed.
Final Consistency Response Prepared By:
Joe Donohue - ACMP Project Specialist
Department of Natural Resources
Alaska Coastal Management Program
302 Gold Street, Ste. 202
PO Box 111030
Juneau, Alaska 99811-1030
(907) 465-4664
Joe Donohue
Final Consistency Response - Concurrence
Page 5 of 5
6 • Appendix C
Kuiu Timber Sale FEIS
Response to ACMP
ACMP - 1
The Forest Service notes the concurrence that the project is consistent with the ACMP
and affected coastal district’s enforceable policies, to the maximum extent practicable.
ACMP -2
The State’s preference for Alternative 2 has been noted.
ACMP -3
The Forest Service will comply with all applicable State and federal regulations. The
Forest Service will contact the Office of Project Management/Permitting if there is need
for further review and approval. If cultural resources are discovered during project
implementation, any work that may disturb those resources will stop and the Forest
Service will proceed with Section 106 consultation.
Kuiu Timber Sale FEIS
Appendix C • 7
Comment Letter #2 - EPA
EPA- 1
Patricia Grantham, Project Manager
Attn: Kuiu Timber Sale
USDA Forest Service
P.O. Box 1328
Petersburg, AK 99833
Dear Ms. Grantham:
The U.S. Environmental Protection Agency (EPA) has reviewed the draft Environmental
Impact Statement (EIS) for the Kuiu Timber Sale Area (CEQ No. 20060032), Tongass
National Forest, in accordance with our responsibilities under the National Environmental Policy
Act (NEPA) and Section 309 of the Clean Air Act. Section 309, independent of NEPA,
specifically directs EPA to review and comment in writing on the environmental impacts
associated with all major federal actions. Under our policies and procedures, we evaluate the
document's adequacy in meeting NEPA requirements.
The draft EIS proposes a no action and three action alternatives that include timber
harvest, road construction and road closure activities. Alternative 2 proposes timber harvest on
491 acres of forestland, construction of 2.9 miles of temporary road, reconstruction of 4.5 miles
of road, and closure of 8.2 miles of open road after completion of the project. Alternative 3
would include timber harvest on 794 acres of forestland, construction of 7.5 miles of temporary
road, reconstruction of 3.2 miles of road, and closure of 8.4 miles of open road after completion
of the project. Alternative 4 (Proposed Alternative) would consist of timber harvest on 1,425
acres of forestland, construction of 19 miles of temporary road, reconstruction of 6.1 miles of
road, and closure of 1 1 miles of open road after completion of the project. Alternative 5 would
include timber harvest on 1,231 acres of forestland using only clearcut harvesting methods,
construction of 17.1 miles of temporary road, reconstruction of 6.9 miles of road, and closure of
1 1 miles of open road after completion of the project.
EPA has rated the draft EIS as Environmental Concerns - Adequate Information (EC-1),
consistent with EPA’s rating system (enclosed). EPA’s primary concern is the potential for
adverse water quality impacts. EPA supports the selection of Alternative 2 as the
environmentally preferred alternative that would meet the purpose and need of the project.
Alternative 2 would reduce impacts to wildlife, hydrology and fisheries as well as minimize
adverse impacts to wetlands.
^3^ Printed on Recycled Paper
8 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #2 - EPA
2
We appreciate the opportunity to comment on the draft EIS for the Kuiu Timber Sale. If
you would like to discuss issues related to our review, please contact Denise Clark at (206) 553-
8414 or myself at (206) 553-1601.
Christine B. Reichgott, Manager
NEPA Review Unit
Enclosure
Kuiu Timber Sale FEIS
Appendix C • 9
Comment Letter #2 - EPA
EPA COMMENTS ON THE DRAFT EIS FOR THE KUIU TIMBER SALE AREA
TONGASS NATIONAL FOREST, ALASKA
EPA’s comments address those matters that relate directly or indirectly to the authorities
of EPA, consistent with our review responsibilities under Section 309 of the Clean Air Act. Our
review places particular emphasis on ensuring impacts to water quality, air quality and wetlands
are minimized or mitigated. We also consider purpose and need and supporting information as
they relate to the identification of reasonable and feasible alternatives and their associated
environmental impacts.
Water Quality
EPA -2
The draft EIS indicates that harvest would take place in an area of Kuiu Island that has
experienced impacts from past harvest levels. Past cumulative harvest (since 1975) in
watersheds that would be affected by the project range from 8% to 31% of the project area
(Table 3-42). EPA appreciates the commitment to close roads to reduce sediment loading to
streams and contribute to long term improvement in watershed health. The cumulative impacts
discussion indicates there will be an overall long-term improvement in the health of each
Watershed. We recommend that the final EIS discuss the short term impacts in more detail,
especially the time frame for which short term impacts are expected to peak and then begin to
diminish. Would short term sediment loading be expected to be lower than thresholds established
by the Tongass Forest Plan? We recommend that harvest be avoided or minimized in watersheds
that have a past cumulative harvest at or near 20% or greater to avoid potential water quality and
^quatic habitat impacts until those watersheds have fully recovered.
Sediment Loading to Streams
The introduction of fine sediment to streams is an important water quality concern. The
draft EIS indicates that there is a high potential for changes in stream chaimel conditions if
sediment loads increase. The major source of sediment transport to streams within the project
area would be through road construction and reconstruction and the placement and removal of
culverts. Another potential source would be the removal of trees from steep slopes. The short
term increase in sediment load to streams would be assumed to offset by the closure of roads,
which may have a long-term beneficial effect.
EPA - 3
EPA -4
The potential short term impacts due to mass movement of soils would be significantly
greater under Alternatives 4 and 5. In addition, the acres of detrimental soil disturbance from
harvest and road construction is significantly less for Alternatives 2 and 3 versus Alternatives 4
and 5. Also Alternative 2 would need the least stream crossings (5 versus 19 for Alternatives 3,
^ and 5). Lastly Alternative 2 would have the lowest potential rate of landslides for the
proposed acres of harvest based on Mass Movement Index (Table 3-76). We recommend that
the final EIS discuss the timeframe of when mass movement would be likely to occur, i.e., when
the mass movement hazard be the greatest risk. The draft EIS and public scoping comments
indicate that the watersheds on Kuiu Island support of variety of species of fish important for the
economy as well as for subsistence use. EPA supports the selection of a timber harvest volume
(^hat meets the purpose and need with minimum impacts to the environment. Since the draft EIS
states that there will likely be future timber harvest within the project area, we recommend
selection of Alternative 2, since it would have the least environmental impacts and allow the
streams to recover more fully prior to future harvests.
10 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #2 - EPA
U.S. Environmental Protection Agency Rating System for
Draft Environmental Impact Statements
Definitions and Follow-Up Action*
Environmental Impact of the Action
LO - Lack of Objections
The U.S. Environmental Protection Agency (EPA) review has not identified any potential environmental impacts
requiring substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation
measures that could be accomphshed with no more than minor changes to the proposal.
EC - Environmental Concerns
EPA review has identified environmental impacts that should be avoided in order to fully protect the environment.
Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce
these impacts.
EO - Environmental Objections
EPA review has identified significant environmental impacts that should be avoided in order to provide adequate
protection for the environment. Corrective measures may require substantial changes to the preferred alternative or
consideration of some other project alternative (including the no-action alternative or a new alternative). EPA intends to work
with the lead agency to reduce these impacts.
EU - Environmentally Unsatisfactory
EPA review has identified adverse enviromnental impacts that are of sufficient magnitude that they are unsatisfactory
from the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce
these impacts. If the potential imsatisfactory impacts are not corrected at the final EIS stage, this proposal will he
recommended for referral to the Council on Environmental Quality (CEQ).
Adequacy of the Impact Statement
Category 1 - Adequate
EPA beheves the draft EIS adequately sets forth the enviromnental impact(s) of the preferred alternative and those of the
alternatives reasonably available to the project or action. No further analysis of data collection is necessary, but the reviewer
may suggest the addition of clarifying language or information.
Category 2 - Insufficient Information
The draft EIS does not contain sufficient information for EPA to fully assess emironmental impacts that should be
avoided in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that
are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action.
The identified additional information, data, analyses or discussion should be included in the final EIS.
Category 3 - Inadequate
EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or
the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed
in the draft EIS, which should be analyzed in order to reduce the potentially significant enviromnental impacts. EPA beheves
that the identified additional information, data, analyses, or discussions are of such a magnitude that they should have full
public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the National
Environmental Policy Act and or Section 309 review, and thus should be formally revised and made available for public
comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal could
be a candidate for referral to the CEQ.
* From EPA Manual 1640 Policy and Procedures for the Review of Federal Actions Impacting the Environment. February,
1987.
Kuiu Timber Sale FEIS
Appendix C • 11
Response to ERA
EPA-1
The EPA’s rating of EC- 1 (Environmental Coneerns-Adequate Information) and support for
the selection of Alternative 2 is not^d.
EPA-2
The recommendation to discuss short-term impacts to watersheds in more detail has been
addressed by expanding Issue 4 in Chapter 3 of the FEIS. Short-term sediment loading is
expected to be consistent with the Forest Plan, and is not expected to exceed water quality
standards set by the State of Alaska. The recommendation to avoid or minimize harvest in
watersheds that have past cumulative harvest levels near 20 percent or greater is noted. The
DEIS (p. 3-124) notes that because of the age of the majority of the existing clearcuts the 30-
year cumulative harvest levels within all the watersheds would be less than 12 percent by the
year 2011, including the harvest from any of the proposed alternatives.
EPA-3
The DEIS (p. 3-195) states that within four to seven years after harvest, root strength tends to
decrease and soil cohesion begins to lesson, however, the upper time limit is not well
defined. This discussion has been expanded in the FEIS to respond to the recommendation
that the FEIS discuss the timeframe when mass movement would likely occur.
EPA - 4
The recommendation for the selection of Alternative 2 is noted.
12 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #3 - NMFS
Patricia Grantham
District Ranger
Petersburg Ranger District
P.O. Box 1328
Petersburg, AK 99833
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
National Marine Fisheries Service
P.O. Box 21668
Juneau, Alaska 99802-1668
Dear Ms. Grantham:
The National Marine Fisheries Service (NMFS) reviewed the Kuiu Timber Sale Area Draft
Environmental Impact Statement (DEIS). The Kuiu Timber Sale Area is located on north Kuiu
Island approximately 12 miles southwest of Kake and 35 miles northwest of Petersburg. The
project area is within Value Comparison Units 399, 400, 402, and 421 and encompasses
approximately 46,102 acres of National Forest System land. Four issues were identified through
project scoping: roadless areas; wildlife habitat and subsistence; timber harvest economics; and
cumulative watershed effects. Concerns were raised about the cumulative impact of introducing
additional timber harvest and roads to watersheds that contain extensive harvested areas and high
road densities. The DEIS stated “The cumulative effects of harvest and road building within
Kuiu Timber Sale Area may affect the condition of stream channels draining these watersheds.”
The action alternatives would harvest approximately 14.6 to 42.6 million board feet of timber;
build 2.9 to 19 miles of temporary road; and reopen between 3.2 and 6.9 miles of existing closed
classified roads. The preferred alternative. Alternative 4, would harvest approximately 42.6
million board feet of timber from approximately 1,425 acres, build 19 miles of new temporary
roads and reconstruct 6.1 miles of closed classified road. As mitigation between 8.2 and 1 1
miles of currently open classified roads will be closed following harvest. In addition, structures
on Road 6413 and excess fill in a stream crossing on Road 6417 will be removed (page 2.21).
Section 305(b) of the Magnuson-Stevens Fishery Conservation and Management Act
(MSFCMA) requires Federal agencies to consult with NMFS on all actions that may adversely
affect EFH. NMFS is required to make conservation recommendations, which may include
measures to avoid, minimize, mitigate or otherwise offset adverse effects. We offer the
following comments specific to the MSFCMA for your consideration.
For the purposes of this project, EFH includes all segments of streams where sahnon reside
during any life stage or period of the year, and the marine waters and substrates of Rowan and
Saginaw Bays. The streams in the project area provide important habitat for pink, chum, and
coho salmon as well as steelhead and cutthroat trout and Dolly Varden char. The marine waters
and substrates of Rowan and Saginaw Bays provide important habitat for a number of ground
fish species including Pacific cod, arrowtooth flounder. Pacific Ocean perch, walleye pollock,
dusky rockfish, shortraker and rougheye rockfish, yelloweye rockfish, sablefish, flathead
rex sole, sculpin and skate.
sole
■'’WOF
Kuiu Timber Sale FEIS
ALASKA REGION - www.fakr.noaa.gOv
Appendix C • 13
Comment Letter #3 - NMFS
NMFS
1
NMFS
2
NMFS
3
NMFS
4
NMFS concurs with the Forest Service determination that the Kuiu Timber Sale may adversely
"affect Essential Fish HabitatT^arvest is proposed in two watersheds that currently have over 20
percent of the watershed harvested within the past 30 years and one watershed with 19.8 percent
of the watershed with recent harvest. This 20 percent harvest is considered a threshold of
concern in third order watersheds which triggers a more intensive watershed analysis prior to
additional disturbances. Since harvest began 8 to 59 percent of the project area watersheds have
been harvested. Only watershed 109-44-10370 has less than a 19% harvest since harvest began.
Of the seven watersheds in the project area three have a very high sediment risk index (SRI), two
have a high SRI, and 2 have a moderate SRI. The unit cards identify fish habitat/watershed
concerns in all units.
The DEIS identified 6 grey culverts and 44 red culverts in the project area. A red crossing is one
that cannot pass juvenile fish at some or all flows, a green fish crossing is one that can pass
juvenile fish at all flows up to the Q2-2day flow (a two day delay Ifom the mean annual flood),
and a gray fish crossing needs additional analysis to determine if it is red or green. Of the 44 red
culverts, 11 are on Class I streams (page 3-180). Those culverts that have had upstream habitat
analysis block or partially block approximately 2.4 miles of Class I habitat and 5.2 miles of Class
^ stream habitat. The 44 culverts that do not meet current standards for fish passage should be
described in further detail as well as the corresponding habitat that is impacted and not available
or only partially available. The potential for correcting some or all of these culverts should be
investigated. What opportunities are being foregone by not replacing or improving fish passage
in these culverts in conjunction with this proposed timber sale and road maintenance and
construction activities? What are the cumulative impacts on fish passage from previous road
construction and proposed construction?
V
Forest roads are only exempted from Clean Water Act jurisdiction if they are maintained to
ensure waters are not impaired ((404) (f) (1) (E)). The DEIS identified that road maintenance
needs are increasing as the road system and drainage structures age. Data provided in the DEIS
and in the road condition survey indicates that the existing roads impair biological characteristics
of the waters. Perhaps existing best management practices are not sufficient to ensure these
Toads will not impair waters. NMFS is concerned with construction of additional miles of road
when the existing roads are potentially impairing the chemical and biological characteristics of
waters. The project should incorporate measures to remediate for impaired waters from prior
road construction. The mitigation proposed seems minimal relative to the number of red culverts
^ the project area.
The unit cards identify several units with high hazard soils mass movement index, MMI-3 or
extreme hazard soils MMI-4. These units are: 101, 207, 209, 303, 305, and 417. The portion of
the unit with MMI-3 and MMI-4 soils has been removed in some instances but not all. In some
instances logging is being allowed and full suspension is not required, while in other cases full
suspension is required. Logging on soils with a high mass movement index increases the chance
of a landslide which increases the potential for sediment delivery to streams. [Minimizing the
risk of sediment inputs to streams from landslides and roads provides a strate^ for avoiding
undesirable channel changes (page 3-1 14)71
7
14 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #3 - NMFS
NMFS
5a
NMFS
5b
NMFS
5c
NMFS
5d
NMFS
6
NMFS
7
NMFS
8
NMFS
9
NMFS
10
NMFS 11
NMFS 12
NMFS
13
NMFS
14
The narrative on page 3-181 and 3-186 gives the existing continuous bark coverage in Rowan
'^ay as 0.5 acres and in Saginaw Bay as 1.08 acresCThe Alaska Department of Environmental
Conservation (ADEC) data base has different amounts of bark debris from the 2002 dive report
(personal communication with Chris Foley on March 20, 2006). For the Rowan Bay LTF ADEC
lists 0.81 acres of continuous bark debris and 0.64 acres of discontinuous bark debris. For the
Saginaw Bay LTF ADEC lists 0.74 acres of continuous bark debris, 0.1 acres of discontinuous
Usark debris, and 0.86 acres of zero to trace bark coverageZJfhe cumulative impact of additional
bark debris is not discussed relative to existing wood debris. The DEIS simply states “Sporadic
use of either LTF is not expected to cause additional bark accumulation.” However the amount
^f existing accumulation is close to the threshold (100% bark covering more than 1 acre and
deeper than 10 cm at any single point) and which triggers a remediation plan. How much bark is
^xpected to be added from this proposed sale? I The EA does not discuss the October 1995 LTF
Siting, Construction, Operation, Monitoring and Reporting Guidelines or whether the LTFs meet
those guidelines. Both LTFs were constructed prior to these guidelines and were not required to
comply with the siting guidelines. Would they comply with these guidelines ^presently
configured? If not, then barging the logs should be given more consideration.*-The DEIS does
^ot provide a detailed analysis of the costs of a barge LTF facility verses an in-water LTF or the
potential benefits to the biological resources of using a barge facili^
>-
^he EA could use additional clarity and information in the following areas:
• It would be most helpful to the reader to have the order of the watersheds the same in all
the tables to facilitate comparisons.
• As mentioned above the amount of bark debris accumulation is different than that
reported by ADEC.
• The narrative at the top of page 3-114 states “Except for roads and landings, timber
harvest occurring more than 20 years ago was not accounted for because harvested
slopes are expected to recover rooting strength in the soil and stabilize after a 20 year
period.” Elsewhere in the document you use a 30 year timeframe (see C-14).
• P 3-1 1 7 says 27% of the Saginaw Creek Watershed has been harvested, however Page
C-27 says 29% has been harvested.
• It would be useful to have the all the watershed condition information summarized in a
table including the percent of the watershed harvested since harvest began; the acres in
riparian harvest and percent of the watershed with riparian harvest; number and size of
landslides; and the sediment risk index (SRI).
• Include the inherent SRI in Table 3-49.
• Identify the number of red and gray culverts in each watershed and by road number.
• Include data on the existing stream conditions for Rowan Creek watershed and 109-44-
1-370 watershed.
>-
NMFS offers the following EFH Conservation Recommendations pursuant to Section
305(b)(4)(A) of the MSFCMA.
1 . Evaluate the potential for correcting the 44 red culverts that do not meet the current
standards for fish passage. Include this information in the analysis, and evaluate
foregone opportunities if fish passage is not corrected as a part of this project.
3
Kuiu Timber Sale FEIS
Appendix C • 15
Comment Letter #3 - NMFS
r
NMFS
15
2. Change the unit boundaries for Units 101, 207, 303, 305 to eliminate the extreme hazard
soils (MMI-4) from the Unit. For units where this may not be feasible require full
suspension and single tree’ selection.
3. Change the unit boundary (NE comer of the unit) for Unit 41 7 to eliminate the high
^ hazard soils (MMI-3) from the Unit.
NMFS
16
4. Implement the management recommendations identified in the watershed analysis which
includes: strict avoidance of potentially unstable slopes when planning road locations and
timber harvest units, diligent maintenance of open roads, and placing roads in storage
when not needed for specific planned activities.
NMFS
17
5. Consider including some of the management opportunities identified in Table 1-3 (page
1-13) as mitigation for this project.
NMFS
18
6. Evaluate the potential to use a barge in conjunction with both LTFs instead of putting the
logs directly in the water.
If you have questions regarding our comments contact Cindy Hartmann at (907) 586-7585.
Sincerely,
Robert D. Mecum
Acting Administrator, Alaska Region
cc: Kris Rutledge, USDA FS, Petersburg Ranger District
comments-alaska-tongass-petersburg@fs.fed.us
*Chris Meade, EPA Juneau
*Tom Schumacher, ADF&G, Juneau
*Richard Enriquez, USFWS, Juneau
*Bill Hanson, USFWS, Juneau
*Kevin Hanley, ADEC, Juneau
*Jim Cariello, ADNR-OHMP, Petersburg
*Joe Donohue, ADNR-OPMP, Juneau
*Don Martin, USFS, Juneau
*Ron Dunlap, USFS, Juneau
*Dick Aho, USFS, Petersburg
*Cindy Hartmann, NMFS, Juneau
* email
A
16 • Appendix C
Kuiu Timber Sale FEIS
Response to NMFS
NMFS-1
That NMFS concurs with the Forest Service determination is noted.
NMFS -2
Culverts which reduce or restrict fish passage are being looked at and prioritized on a
forest-wide level. The potential for correcting the red culverts in the planning area was
examined and the opportunity to improve fish passage where road work is proposed for
the timber sale project was incorporated. Two red fish passages problems will be
corrected with the implementation of any of the action alternatives, creating a reduction
in the cumulative impacts to fish passage.
NMFS -3
Best Management Practices (BMPs) are sufficient to protect water quality. The existing
roads were constructed before BMPs were in place. All proposed roads and
approximately 8 to 1 1 miles of currently open NFS roads would be closed after timber
harvest is complete. An interagency group is currently working on a model that would
help make management recommendations for the red culverts. 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.
NMFS -4
A soil stability analysis was completed by a Soils Scientist for all MMI-4 soils within
planned road locations and timber harvest units. All unstable slopes were avoided.
However, due to numerous concerns, those units with MMI-3 and MMI-4 soils were
reanalyzed. Units 207, 303, and 305 (see unit cards in FEIS Appendix B) will be
modified to exclude the MMI-4 soils. For Unit 101, the MMI-4 soils in the southeast
comer of the unit will be removed and the area along the western edge of the unit will
remain. There are no streams in this area and the risk of sedimentation delivery to a
stream is very small. The majority of the slope within unit 417 was between 45-65% and
very little slope gradient over 70%. Where 70% slope gradients did exist, the area was
well benched, well drained, and had no evidence of slumping or sliding. Although the
GIS database has identified soils at the northeast comer as being MMI-3, this area is
considered low risk for mass movement potential.
NMFS - 5a
The numbers in the DEIS were the numbers in the dive report. When the dive report was
sent to ADEC it was reanalyzed and decided that the amount of bark accumulation was
over estimated. The number reported by ADEC will be used in the FEIS.
NMFS - 5b
There are many variables that make estimation of additional bark accumulation
impossible. If the logs are barged, then no significant amount of bark accumulation is
expected as a result of this timber sale. If the logs are placed in the water, the amount of
bark accumulation depends on: how much bark is on the trees when placed in the water,
the wave action of the water, how long the logs are in the water, the time of year that the
trees are harvested, and how the logs are placed in the water. The bark accumulation will
Kuiu Timber Sale FEIS
Appendix C • 17
Response to NMFS
be monitored and if the accumulation exceeds EPA standards then appropriate action will
be taken.
NMFS - 5c
Neither LTF meets all of the 1985 siting and construction guidelines. This, however, is
not a requirement because they were constructed before 1985. The common practice in
the timber industry is to barge logs; however, both the Saginaw and Rowan Bay LTFs are
permitted under the EPA General Permit AK-G70-0027 to raft logs. It is important to
retain the flexibility to raft logs if needed.
NMFS - 5d
The cost of a barge LTF is not significantly different from an in-water LTF. Both the
Saginaw and Rowan Bay LTFs can accommodate barges at this time; however, Saginaw
LTF could use additional work to make barging easier and more convenient. The benefit
to biological resources of a barge LTF is that very little bark accumulation will occur.
NMFS -6
The order of the watersheds in the tables was made consistent within the section to
facilitate easier comparisons.
NMFS -7
Please see NMFS - 5a for response to this comment.
NMFS -8
The 20-year time frame referred to in the DEIS (p.3-1 14) describes the expected recovery
time, with respect to landslide risk, for harvested slopes. This number comes directly
from a paper that assessed slope recovery time (Brardinoni et al., 2002), and that paper is
cited in the DEIS (p. 3-1 14). The 30-year time frame referred to elsewhere in the
document comes from the Forest Plan, which states that a more complex watershed
analysis should be conducted in watersheds having more than 20 percent of the watershed
acres with trees in second-growth younger than 30 years. This direction is described in
the DEIS (p.3-1 12).
NMFS -9
There is an error on page 3-1 17 of the DEIS. The correct cumulative harvest level for
Saginaw Creek is 29 percent, as stated in Appendix C on page C-27. This error has been
corrected in the FEIS.
NMFS -10
The information requested has been added to the Hydrology Resource report that is
available in the planning record. It was not included in the FEIS to minimize document
size.
NMFS - 11
The inherent SRI was included in the FEIS table.
18 • Appendix C
Kuiu Timber Sale FEIS
Response to NMFS
NMFS-12
The red and gray culvert locations are available by road number from the Road Condition
Surveys located in the planning record. This information does not include watershed
names.
NMFS -13
Detailed stream channel condition assessments were only conducted for watersheds with
greater than 20% cumulative harvest. Because Rowan Creek and 109-44-10370 do not
exceed this threshold, the information requested is not available.
NMFS - 14
See NMFS - 2 for response
NMFS -15
See NMFS - 4.
NMFS - 16
Units 207, 303, and 305 will be modified to exclude the MMI-4 soils. For unit 101, the
MMI-4 soils in the southeast comer of the unit will be removed and the area along the
western edge of the unit will remain. All roads opened for this project will be placed in
storage after timber harvest is complete and additional miles of road will be placed in
storage. Unstable slopes were avoided in road locations and timber harvest units.
NMFS -17
As part of this project, approximately 8 to 1 1 miles of open road will be placed in
storage. Some of these activities are in the beginning stages of analysis and may be
completed before the FEIS can be implemented and others are outside the puipose and
need of this project.
NMFS -18
The common practice in the timber industry is to barge logs, however, the Rowan Bay
and Saginaw Bay LTFs are permitted under the EPA General Permit AK-G70-1000 to
raft logs. It is important to retain the flexibility to raft logs if needed.
Kuiu Timber Sale FEIS
Appendix C • 19
Comment Letter #4- Dept, of the Army
Regulatory Branch
POA-2006-279
DEPARTMENT OF THE ARMY
U.S. ARMY ENGINEER DISTRICT, ALASKA
P.O. BOX 6898
ELMENDORF AFB, ALASKA 99506-0898
FEB 1 0 2006
Ms. Patricia Grantham
Petersburg District Ranger
U.S. Forest Service
648 Mission Street
Ketchikan, Alaska 99901
Dear Ms. Grantham:
Thank you for the opportunity to comment on the Kuiu Timber Sale Area,
Draft Environmental Impact Statement (DEIS) . It has been assigned number
POA-2006-279, Frederick Sound, which should be referred to in all future
correspondence with this office.
DA - 1
DA -2
You may contact me at (907) 753-2712, toll free from within Alaska at
(800) 478-2712, by email at nicole .m. hayes0poaO2 . usace . army .mil , or by mail at
the letterhead address, ATTN: CEPOA-CO-R-E, if you have questions. For
additional information about our Regulatory Program, visit our web site at
www.poa.usace.army.mil/reg.
Four of the five proposed alternatives in the DEIS, requires temporary
road construction to include temporary placement of culverts and bridges
(with the exception of Alternative 1, the No-Action Alternative) . In
. — addition, the four work alternatives include utilizing the Rowan Bay and/or
the Saginaw Bay Log Transfer Facilities (LTFs) . We concur with the
determination that all temporary roads proposed for this project are exempt
from Clean Water Act permitting, provided they are constructed according to
best management practices that include the baseline provisions that are listed
— in 33 CFR 323.4(a) (6) (i-xv) . If the roads are maintained open for public use.
Department of the Army (DA) authorization would be required if there is a
discharge of fill material into the waters of the U.S. Please keep in mind
that all silviculture roads proposed for conversion to multi-use roads would
need to be evaluated for permitting requirements. We also concur with the
determination that reconstruction of Saginaw Bay LTF and/or modifications to
.^Rowan Bay LTF may require DA authorization.
Sincerely,
Nicole Hayes
Regulatory Specialist
RECEIVED
FEB 1 5 2006
FOrTEST SERVICE
20 • Appendix C
Kuiu Timber Sale FEIS
Response to Dept, of the Army
DA-1
The Forest Service acknowledges the concurrence that all temporary roads proposed for
this project are exempt from Clean Water Act permitting, provided they are constructed
according to BMPs (best management practices). No new NFS roads proposed for this
project would be maintained for public use. New NFS roads would be closed and placed
in storage at the end of timber harvest activities. New NFS roads would also utilize BMPs
listed in 33 CFR 323.4.
DA -2
The Forest Service notes that reconstruction of Saginaw Bay LTF and/or modifications to
Rowan Bay LTF may require DA authorization.
Kuiu Timber Sale FEIS
Appendix C • 21
Comment Letter #5 - Organized Village of Kake - OVK
Organized Village of Kake
P.O. Box 316
Kake, Alaska 99830-0316
, Telephone 907-785-6471
Fax 907-785-4902 / email KeexKwaan@starband.net
(Federally Recognized Tribal Government serving the Kake. Alaska area)
March 17, 2006
Kris Rutledge, Team Leader
USD A Forest Service
P.O. Box 1328
Petersburg, Alaska 99833
RE: Kuiu Timber Sale
Dear Ms, .Rutledge: — -
The Organized Village of Kake (OVK), a federally recognized Indian Tribe, is organized pmsuant to the
authority of the Federal Indian Reorganization Acts (hereinafter IRA) of 1934 & 1936 with the IRA Council as
the duly elected governing body formed under its Constitution and By-laws to protect customary and traditional
resources used by tribal membership on pubhc and other lands.
From time immemorial, north Kuiu Island has been, and continues to be, an important customary and traditional
use area for tribal members of OVK. In spite of your agency’s responsibihty to consult and collaborate with
OVK and to implement projects in a way that does not disproportionately impact minority and low-income
communities, such as Kake, the Forest Service continues to propose timber sales that completely fail to
accommodate the concerns of OVK for its tribal membership.
Executive Order 13175, the U.S. Forest Service Manual, and the position of OVK, as shared by over 250 other
American Indian Tribes represented by the National Congress of American Indians, all require that adequate
consultation involve tribal input before agency action is taken. Although there were open houses in June and
November, 2004, the range of alternatives proposed by the Forest Service falls far short of any effort to
accommodate the real concerns of OVK with fiirther destruction of our ancestral lands. There was no tribal
consultation with OVK regarding the Kuiu Timber Sale.
Executive Order 13175 was issued on November 6, 2000, which revoked Executive order 13084, issued by
President Clinton on May 14, 1998. The latter Executive Order was the first to order consultation and
coordination with Indian Tribal Governments. Both of these orders were issued after the Forest Service
approved the revised Tongass Forest Plan on May 23, 1997. Consequently, the Forest Service did not consult or
coordinate with OVK during the planning process that resulted in the 1997 Revised TLMP.
In NRDC V. USFS, the 9* Circuit Court of Appeals found fimdamental defects in the 1997 Tongass Forest Plan
based on the substantial error made by the Forest Service in estimating the market demand for Tongass Timber.
As the court explained, this error “fatally infected [the agency’s] balance of the economic and environmental
considerations...” NRDC v. USFS, 421 F.3d797, 816 (9* Cir. 2005) As a result, the court directed the Forest
Service to revise the Tongass Forest Plan. Until that court-mandated revision is complete, OVK urges the Forest
Service to halt all planning activities related to the Kuiu Timber Sale project Forty years of industrial scale
logging on our ancestral land is enough.
We further remind the Forest Service that the Record of Decision (ROD) approving the 1997 Jj
Plan directed “Forest Supervisors and District Rangers to increase their efforts in cqj
within the commxmities of Southeast Alaska. Collaborative stewardship means brin]
22 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #5 - Organized Village of Kake - OVK
OVK
3 cont.
OVK
4
OVK
5
Comments to the Kuiu Timber Sale
By Organized Village of Kake
Page 2
in the decision making in implementing Forest Plan direction.” Tongass Forest Plan ROD at 42. Furthermore,
consistent with its duty to consult and collaborate with OVK, the Forest Service should have worked with OVK
to limit any permissible logging on North Kuiu Island to methods and volumes that would not significantly harm
customary and traditional uses of our ancestral lands. Its efforts fell far short of these requirements.
jm a recent news story explaining why the Forest Service had withdrawn its approval of the 4 milhon board foot
Overlook Timber Sale, Petersburg District Ranger Grantham is quoted as saying, “It’s very important to
accurately describe our projects so that the pubhc has a clear picture of what is being proposed.” (“U.S. Forest
Service to Review Mitkof Sale,” Juneau Empire, Mar. 16, 2006, A2) While we wholeheartedly agree with
Ranger Grantham, the Draft EIS for the Kuiu Timber Sale Area utterly fails to satisfy this basic objective. In
particular, the analysis in the DEIS of the impact of past, existing, and future habitat conditions on the customary
and traditional himting of deer on north Kuiu Island is severely flawed and appears designed not to inform the
pubhc about the project but to rationalize the proposed action.
In 1998, OVK challenged the Crane and Rowan timber sale decision because the Forest Service rehed on
absolute deer habitat projections and faulty demand projects to support its findings that the project would not
cause a significant restriction to customary and traditional uses of deer. To support our argument on the faulty
demand projections, we submitted the testimony of six actual himters fi'om Kake, who himted on Kuiu between
1960 and 1968. In its decision denying our appeal, the Forest Service promised “to work coUaboratively with
Kake residents m reviewing and possibly revising the data on hunter demand for Kuiu Island.” (fi'om ARO
recommendation to Regional Forester at 18, October 16, 1998). Nonetheless, the DEIS continues to use this
contradicted and unrehable data See DEIS at 3-82 (“ADF&G also estimated himter demand for deer in WAA
5012 to be 68 deer, based on estimated annual harvest during the years 1960-1968.”).
Instead of relying on theoretical or imrehable data, the Forest Service should have based its conclusions on the
readily available information. The 1998 Crane and Rowan Final EIS asserted that the ADF&G estimated “an
average of approximately 200 deer were killed on Kuiu annually in the 1960’s.” See Crane and Rowan FEIS at
3-63. Even if it is assumed that these numbers accurately reflect the number of deer harvested by Kake hunters,
the most recent data fiom 1993 to 2003 show that on average only 18 deer are harvested fiom Kuiu Island, as a
whole, thus indicating a severe reduction in deer population due to past timber harvests. See DEIS, Table 3-28 at
3-82.
As more old growth habitat disappears to clearcuts on Kuiu, tribal members will have to expend even greater
efforts to find and kill deer in the project area, regardless of the Forest Service’s estimate of how many deer the
Kuiu project area can theoretically support. As a matter of common sense, the Forest Service must conclude that
the need by OVK iiunters to spend more time and greater effort to harvest deer on Kuiu Island constitutes a
significant restriction to subsistence uses. Clearly, OVK himters’ customary and traditional acti'vities are
significantly restricted when we have to travel farther fiom home to hunt deer at a time of year with dangerous
and life-threatening weather conditions. Sadly, in recent years, three OVK hunters faced the ultimate restriction
when they lost their hves attempting to make the 24 mile run across Frederick Sound to Admiralty Island for
yeer. One of these hunters was a young man not yet out of high school.
Another example of inaccuracy, and a clear indication of the shallowness of the consultation effort conducted by
the Forest Service with OVK for this project, is the outdated community profile contained in the DEIS. In 2003,
the reported population for Kake was 682 residents. See DEIS at 3-76. Yet the current population of Kake is
Table 3-92, identifying Kake’s population at 663 in 2004. In the last two years, however, Kake’s population has
dropped over 12 percent to 598. The description of Kake’s employment and income is also inaccurate and
outdated. See DEIS at 3-253. The DEIS states that seafood processing at Kake Foods “contribute[s]
considerably to the economy.” Unfortunately, the Kake Foods has not operated at all in the past two years; tribal
members are forced to seek seasonal employment in Petersburg and Sitka, returning home when these seasonal
▼jobs are over. The DEIS also references employment of residents logging on village and regional corporation
Kuiu Timber Sale FEIS
Appendix C • 23
Comment Letter #5 - Organized Village of Kake - OVK
OVK
5 cont.
OVK
6
Comments to the Kuiu Timber Sale
By Organized Village of Kake
Page 3
lands. For the record, Kake Tribal recently sold all its logging equipment, so like Kake Foods, these logging jobs
are minimal at best. Logging by the regional corporation employs less than a dozen local men and these jobs are
an extremely short season. Tribal members who were hired for these jobs had to eventually leave Kake to work
in Kensington Mine because of the few hours they were even called to work.
Reliance by the Forest Service on this outdated and incomplete information makes its attempt to evaluate the
human health and environmental effects of the proposed action, pursuant to Executive Order 12898 arbitrary.
While the DEIS attempts to evaluate the social and economic effects of the proposed Kuiu timber sale on Kake,
it completely fails to consider how past and future significant impacts to customary and traditional activities in
the project are impacting the cultural and social lives of OVK members.
The environmental justice analysis contained in the DEIS fails to disclose current unemployment statistics for
Kake, compare the median incomes of Kake households with the regional medium, evaluate the access of
residents to potential jobs. For the record, the Denali Commission has recently classified Kake as a “distressed”
community due to the dire economic. situatiprL An ‘economically distressed ctaximunity.’..as defined by the
Denah Commission Code are:
1 . Per capita market income no greater than 67% of the U.S. average; and
2. Poverty rate at 150% of the U.S. average or greater, and
3. Three-year unemployment rate at 150% of the U.S. average or greater, or
4. Twice U.S. poverty rate and either ( 1 ) or (3) above
For the record, many of our tribal members are not even included in the State’s unemployment statistics because
they are not even drawing unemployment.
During times of economic downfall, tribal membership depend even more so on gathering of customary and
traditional foods and we see no reflection of this in your DEIS, nor the fact that our community is severely
economically impacted.
In summary, the Organized Village of Kake is opposed to further logging on north Kuiu due to previous
^dustrial scale logging impact that has had a cumulative effect on fish and wildhfe habitat and watersheds,
which directly impacts the customary and traditional gathering (subsistence) of our tribal membership. The
Organized Village of Kake prefers the No-Action Alternative, Alternative A. Thank you for your attention to
OVK’s concerns and issues regarding the DEIS of the Kuiu Island Timber Sale on behalf of our tribal
membership.
OVK President
24 • Appendix C
Kuiu Timber Sale FEIS
Response to OVK
OVK-1
At this time the Forest Service and the Organized Village of Kake (OVK) are working
towards a Memorandum of Understanding which establishes a general framework for the
exchange of information and defines the expectations of meaningful consultation between
OVK and officials on the Petersburg Ranger District (District). However, at this time the
agreement is not complete and at the time of the planning of the Kuiu Timber Sale this
agreement had not been written. The District strives to conduct meaningful consultation.
The intent of the agreement is to provide guidelines to make consultations satisfactory to
both parties.
The District met with OVK, who has a cultural affiliation with the lands associated in the
Project Area and on Kuiu Island, with the intent of providing an opportunity for the
exchange of information. On June 3, 2004 and again in November 22, 2004, Forest
Service Resource Specialists and Patricia Grantham, Petersburg District Ranger, met with
Henrich Kadake, Sr., OVK President, and other OVK staff members to discuss the
proposed project (DEIS Chapter 1-15, 16, Chapter 3-261, FEIS Chapters 1 and 3). These
meetings included written information-sharing and government to government meetings
between the District Ranger and OVK staff. In addition, the District held two Open
Houses in Kake during these dates. The open houses included Project Area maps and
District personnel available for discussions. On March 21, 2006, Patricia Grantham,
Petersburg District Ranger, again meet with Henrick Kadake, Sr., OVK President and
other OVK staff members to discuss the Kuiu Timber Sale Project. A subsistence hearing
was held in Kake as per ANILCA Section 810 requirements in conjunction with this
meeting. On May 21, 2006, the District Ranger and several District Specialists met with
OVK staff to discuss ongoing district activities including the Kuiu Timber Sale project.
The Forest Service solicited comments from OVK regarding cultural resources in the
Project Area. As stipulated in Section 106 of the National Historic Preservation Act, the
Heritage Resource Specialist report was presented to OVK for review and comment. The
District Archeologist made several contacts in order to update the City of Kake
community profile.
OVK -2
The request urging the Forest Service to halt all planning activities related to the Kuiu
Timber Sale project until the Forest Plan revision is complete has been noted.
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
Kuiu Timber Sale FEIS
Appendix C • 25
Response to OVK
The court listed its findings in Natural Resources Defense Council v. U.S. Forest Service
but did not list any requiremenfs within that document. In response to the court’s decision
the Tongass chose to amend the Forest Plan. This ruling did not put the Forest Plan “out
of commission.” Projects will move forward, with the Forest Plan continuing to be the
guiding document and contract with the public. It would be irresponsible to stop
providing raw materials to help locally-owned businesses survive and to help Southeast
Alaska communities. The Forest Plan is currently being amended, but the Forest Service
land-management mission cannot be put on hold. The Tongass National Forest will
continue to be managed in compliance with Section 101 of the Tongass Timber Reform
Act of 1990 (TTRA), which modified the Alaska National Interest Lands Conservation
Act (ANILCA). TTRA states that the Secretary of Agriculture “...shall, to the extent
consistent with providing for the multiple use and sustained yield of all renewable forest
resources, seek to provide a supply of timber from the Tongass National Forest which (1)
meets the annual market demand for timber from such forest and (2) meets the market
demand from such forest for each planning cycle.” To provide a steady flow of timber
harvest volume, timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand. This is described more fully in
Appendix A of the FEIS.
OVK -3
The Eorest Service made several attempts to involve the people of Kake with the
planning process and to address the responses received. Scoping comments included the
desire for small scale projects that could increase employment, and concerns over
competition for subsistence items and the concern over low deer populations on Kuiu
Island.
• Small timber sales were considered but dropped because they were not
economical
• The competition for subsistence was analyzed in the DEIS (p. 3-86), and
• The proposed activities are not expected to result in a significant restriction of
subsistence uses (DEIS p. 3-95)
• See paragraph 1 of OVK - 1
OVK -4
The Organized Village of Kake feels the 1960s deer use figures substantially
underestimate what the use was in those years, and that this carries over into
underestimating current and future demand estimated by the Alaska Department of Fish
and Game. Several declarations from Kake residents attest to their remembrance of deer
taken from Kuiu during the 1950s and 1960s. Several residents recall that more than 30
deer were taken by them or their families alone, and others estimate around 80 for an
extended family to more than 100 for Kake people.
Kake residents have pointed out that their recent (since 1975) reliance on Admiralty
Island for deer hunting is not their preference, and that as the Kuiu herds increase more of
their hunting will shift back to Kuiu Island. Kake residents on average (based 1993 to
1995) take about 250 deer annually (TEMP Revision FEIS, Appendix H, p. H-76, based
on 75% of their harvest being 185 deer). If all of these deer were harvested from Kuiu
26 • Appendix C
Kuiu Timber Sale FEIS
Response to OVK
the minimum deer needed to support that demand would be 2,500 deer. Table 3-29 shows
that WAA 5012 would be able to meet this demand in all alternatives.
All action alternatives would result in reductions of deer habitat capability. Alternatives 2
and 3 would result in less than one percent decline in deer habitat capability. Alternatives
4 and 5 would result in a one percent decline in deer habitat capability in WAA 5012.
WAA 5012 has the habitat capability to meet the population objects and support a deer
population sufficient to meet the State of Alaska’s population objectives and the hunter
demand for the people of Kake at this time, even after applying the 36 percent reduction
factor for wolf predation (DEIS, p. 3-83 Table 3-29).
OVK -5
The FEIS has been updated to include current population estimates and uses the
following income and employment information.
U.S. Census data for Kake from the year 2000 shows the median household
income was $39,643, per capita income was $17,41 1, and 14.61 percent of
residents were living below the poverty level.
A letter dated February 2006 from the Denali Commission confirmed Kake’s
classification as a distressed community. Based on 2003 data, the Denali
Commission estimates Kake average market income as below the $14, 872
threshold level and that more than 70% of residents age 16 and over earned less
than the threshold.
The FEIS has been updated as much as possible with the following sites used as sources:
1 . Alaska Department of Commerce, Community and Economic Development
community database (www.dced.state.ak.us),
2. Denali Commission website (www.denali.gov),
3. Kake Community Economic Development Strategy (2004) (the page provided)
4. U.S. Census Bureau, Census 2000 (http://censtats.census.gov/pub/Profiles.shtml),
and
5. Personal communication with Kake Schools, OVK, the City of Kake and Jeannie
Monk (Denali Commission).
The Forest Service notes that Kake Foods has not operated for the past two years and that
Kake Tribal recently sold all of its logging equipment. The Forest Service also
acknowledges that as income has dropped, reliance on subsistence has increased. The
FEIS Environmental Justice section (FEIS Ch 3 - Socioeconomics Section) has been
expanded to recognize the above-mentioned conditions in Kake and acknowledge that
during times of economic hardship tribal members depend even more on the gathering of
customary and traditional foods. As a result of the project, the analysis shows conditions
are not expected to worsen and there may be opportunity for employment (FEIS
Socioeconomics Section)
OVK -6
The preference for Alternative 1 , the No- Action Alternative has been noted.
Kuiu Timber Sale FEIS
Appendix C • 27
GSS
1a
GSS
1b
GSS
1c
GSS
2
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Kris Rutledge, Team Leader
Attn: Kuiu Timber Sale ’ March 20, 2006
USDA Forest Service
POBox 1328
Petersburg, AK 99833
Re; Comments on Kuiu Timber Sale DEIS
Sent via 1*‘ Class Mail
Dear Ms. Rutledge;
The following comments are submitted on behalf of the Sitka Conservation Society, Greenpeace,
The Wilderness Society, Natural Resources Defense Council, and the Sierra Club on the Kuiu
Timber Sale Draft Environmental Impact Statement (DEIS).
All of the organizations have a long history of involvement in the planning process on the Tongass
National Forest, especially related to proposed plans for logging and road building. The
organizatons’ memberships include hundreds of Alaskans many of whom 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, and hunters and guides. The organizations also represent thousands of
Americans living outside of Alaska all of whom have a stake in the continued sustainability of the
Tongass and its wildlands. The groups are committed to preserving the integrity of Southeast
Alaska’s natural environment and protecting its wildlands fi'om unnecessary development.
The Kuiu Project is Based on an Arbitrary and Unlawful Forest Plan
Planning on the Kuiu Project is directly reliant upon the 1997 TLMP. However, the^*^ Circuit
^Court of Appeals recently invalidated the TLMP in NRDC v. U.S. Fohst Seiyice. The decision
Hn NRDC V U.S. Forest Service requires the Forest Service J^repare a new forest plan for the
Tongass. The Forest Service has begun this planning process The National Environmental Policy
^Act specifically prohibits the Forest Service from making decisions that prejudice the ultimate
decision on a programmatic EIS. By expending considerable agency resources to complete the
NEPA analysis on the Kuiu timber project prior to completing the court-mandated revision of the
Tongass Plan, the agency is prejudging the likelihood that the Kuiu project area would be
considered for non-timbecLUDs status, including wilderness, prior to the completion of that
^court mandated revision^ For this reason we request that no fiirther planning of this project
continue until the new Forest Plan is finalized and an appropriate appeal period has expired.
This Project Must Comply with the Clean Water Act and Disclose Potential Water Quality
Impacts from Violations of State Water Quality Standards
Section 3 13(a) of the Clean Water Act provides that all federal agencies “engaged in any activity
resulting, or which may result, in the discharge or runoff" of pollutants,” miisf colfiply^with the
Clean Water Act’s requirements, including limits imposed by states through the Act. 33 U.S.C. §
MAR 2 a 2uUb
FOREST SERVICE
28 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
1323(a). The logging and road building activities approved by the Forest Service in this sale will
likely violate the standards for turbidity and sediment. As a result, the Forest Service will likely
violate the Clean Water Act. In addition, NEPA requires the Forest Service to discuss the likely
water quality violations and their impacts in an EIS. The Forest Service has not done this in the
DEIS for Kiui.
Under the Proposed Alternative (Alternative 4), there will be the construction of 19 miles of new
roads. DEIS at 2-3. This will result in a total of 41 stream crossings (Classes I - IV). DEIS at
2-19. For streams classified for all fresh water uses under 18 AAC 70.020, such as the streams in
the project area, the standard for turbidity is;
May not exceed 5 nephelometric turbidity units (NTU) above natural conditions when the
natural turbidity is 50 NTU or less, and may not have more than 10% increase in turbidity
when the natural turbidity is more than 50 NTU, not to exceed a maximum increase of 25
NTU.
18 AAC 70.020(b)(12). As the most recent monitoring data indicates, the turbidity standard is
often violated following the commencement of construction activities. See Forest Service’s
Annual Monitoring & Evaluation Report - 2004, Soil and Water at 21. This data suggests that
activities associated with the Kuiu project will violate the water quality standard for turbidity.
Moreover, the Forest Service has not collected data on turbidity exceedances from the use of
forest roads. See id. (“Additional data will be collected to evaluate turbidity during timber hauling
and, eventually, road storage activities.”)
The sediment standard for streams classified for water-supply uses is: “No measurable increase in
concentration of settleable solids above natural conditions, as measured by the volumetric Imhoff
cone method.” 18 AAC 70.020(b)(9). The sediment standard for streams classified for growth
and propagation of fish does not permit increases more than 5% by weight above natural
conditions. Id. The Forest Service’s own studies show that logging and road building activities
violate the sediment standard. For example, a 1987 report by Steven Paustian which concluded
that “[s]ome short term degradation of water quality from increased turbidity and suspended
particulates is unavoidable, particularly during road building.” Consequently, this project will
result in violations of the sediment standard.^
^ The Forest Service has previously acknowledged that sediment, turbidity, and temperature “are
the most likely water quality parameters to be affected by activities implemented under the Forest
Plan” and that sediment is “the most important of these.” 2003 Annual Monitoring & Evaluation
Report at 9. Yet, the Forest Service has not monitored sediment loading in streams since the
1980s “because it is very difficult and costly to directly measure sediment transport rates with
reliability.” Id. at 10. The Forest Service is thus in violation of the Forest Plan’s monitoring
requirements. See 1997 TEMP at 6-10. Given the Forest Service’s admission that short-term
degradation of water quality from sediment loading is unavoidable, the Forest Service should
explore cost-effective ways to monitor sediment loading in streams from logging and road
▼ building activities.
2
Kuiu Timber Sale FEIS
Appendix C • 29
GSS
2 cont.
GSS
3a
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Since this project will result in violations of the turbidity and sediment standards, the Forest
Service is in violation of the Clean Water Act. Moreover, the FSEIS fails to disclose these water
quality violations and therefore misleads the decision-maker and the public, in contravention of
NEPA
The NFMA Requires the Forest Service to Provide Valid Reasons for
Adopting Clearcutting as a Logging Method
The NFMA imposes significant restrictions on the use of clearcutting in the national forests and,
in particular, prohibits the Forest Service from selecting a logging method primarily because it will
provide the greatest financial return or output of timber. 16 U.S.C. § 1604(g)(3)(E)(iv); 36
C.F.R. § 219.27(b)(3). For the Kuiu logging project, the Forest Service has proposed
clearcutting on nearly three-fourths of the acres to be logged (1,026 out of 1,425).
The NFMA provides that “the harvesting system to be used [cannot be] selected primarily
because it will give the greatest dollar return or the greatest unit output of timber.” 1 6 U.S.C.
§ 1604(g)(3)(E)(iv). This provision is part of a statutory scheme in which Congress imposed
substantial restrictions on the use of clearcutting. Clearcutting may be used only where “it is
determined to be the optimum method” to meet the objectives and requirements of the relevant
land management plan 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.” 16 U.S.C. § 1604(g)(3)(F)(i), (v). Courts have observed that these
restrictions limit the discretion of the Forest Service to use clearcutting as a logging method. See
SiejTa Club v. Thomas, 105 F.3d 248, 251 (6th Cir. 1998) (clearcutting may “be used only in
exceptional circumstances.”), vacated on other grounds, Ohio Forestry 'n v. Sierra Club, 523
U.S. 726 (1998); Sierra Club v. Espy, 38 F.3d 792, 799 (5th Cir. 1994) (Forest Service must
“proceed cautiously in implementing an even-aged management alternative and only after a close
examination of the effects that such management will have on other forest resources.”).
There are sound reasons for Congress’s decision to impose limitations on clearcutting.
Clearcutting removes important habitat and therefore negatively affects wildlife populations.
This, in turn, harms sport and subsistence hunting opportunities. Clearcutting also increases the
occurrence of landslides three-fold, as compared to unlogged areas, thereby creating risks to
water quality and fish. Selective logging methods also have less visual impact. Since scenery and
wildlife are the main reasons people visit and use the Tongass, changes from the natural settings,
especially clearcuts, harm recreation and tourism uses. Conversely, selection logging methods
that mimic natural, small-scale disturbance patterns are likely to protect significantly more of these
resources.
In the DEIS, the Forest Service sates clearcutting would improve “[fjorest health and commercial
productivity ... by removing dwarf mistletoe-infected trees and trees infected by disease; and by
creating younger, faster-growing forests.” DEIS at 3-171, Clearcutting based on these reasons,
however, serves no ecological purpose. These reasons are merely different ways of seeking the
“greatest dollar return or the greatest unit output of timber,” in violation of the NFMA.
16 U.S.C. § 1604(g)(3)(E)(iv).
3
30 • Appendix C
Kuiu Timber Sale FEIS
GSS
3a cont.
GSS
3b
GSS
3c
GSS
4a
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Dwarf' mistletoe is a naturally occurring, native parasitic plant which, in southeast Alaska, atfects
only western hemlock. When an area is clearcut, the chance for infestation of the future stand is
reduced. Eradicating or preventing the spread of dwarf mistletoe, however, serves no purpose
other than to promote future timber production. Dwarf mistletoe is native to and an important
ecological component of the Tongass, influencing stand structure, species composition, and
wildlife habitat. It provides nesting sites and food sources for many species of wildlife. Similarly,
wood decay fungi create canopy gaps and wildlife habitat and “play an important role in nutrient
cycling.” DEIS at 3-169. There is therefore no ecological reason to prevent the spread of dwarf
mistletoe or decay fungi, other than to achieve the “greatest output of timber,” which cannot be a
primary reason for selecting clearcutting. 16 U.S.C. § 1604(g)(3)(E)(iv). Moreover, as the DEIS
admits, the “occurrence of dwarf mistletoe is relatively light” in the project area. DEIS at 3-169.
c
The DEIS also suggests that the Forest Service may rely on windthrow as a potential justification
for clearcutting. Windthrow is a naturally occurring event that plays an ecological function in the
forest renewal process. According to the TEMP FEIS, windthrow may be part of “the most
important natural process in renewing the forest in Southeast.” TEMP FEIS at 3-270. While the
fallen trees serve an ecological function, they do not benefit timber production. Thus, to avoid
the “risk” that some of the remaining trees will blow down, the Forest Service has simply chosen
to cut them all, /.c., clearcut. Accordingly, this justification is intended to maximize “output of
>^timber” and cannot be a primary reason for selecting clearcutting. 16 U.S.C. § 1 604(g)(3)(E)(iv).
In sum, the Forest Service has elected to clearcut most of the acres to be logged and the reasons
for that decision are to achieve the greatest dollar return or greatest output of timber.
Consequently, the proposed sale will violate the NFMA.
The DEIS Relies On Outdated And Demonstrably Inaccurate
Protections Of Market Demand
The Kuiu DEIS relies on erroneous market demand calculations, and the Forest Service must
revise the DEIS to consider whether this logging is necessary to meet the demand.
The Tongass Eand Management Plan relies on projections developed in 1997 to project market
demand for Tongass timber. See TEMP ROD at 25 (citing Brooks & Haynes, Timber Products
Output and Timber Harvest in Alaska: Projections for 1997-2010 at 1 (1997)). These
projections rely on a series of assumptions about domestic and foreign markets and the ability of
the industry to use and sell low-grade logs and other “manufacturing residues.” Brooks & Haynes
at 4-5.
In light of the end of long-term timber contracts and declining Japanese markets, the Brooks and
Haynes demand forecasts have proved to be significantly too high. See Eisa K. Crone, Rural
Manufacturing and the U.S. Wood Products Industry: Trends and Influences on Rural Areas, in
Economic Growth and Change in Southeast Alaska (Rhonda Mazza tech ed.. United States Dep’t
of Agriculture, Forest Service July 2004), at 43-54 (general technical report) (discussing changes
in the Southeast Alaska timber market)); Forest & Eand Management, Inc. & Anderson &
4
Kuiu Timber Sale FEIS
Appendix C • 31
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Associates, \nc.. Market Outlook for Alaska Mental Health Trust Timherlands 2004)
(detailing the decline of the Japanese export market for Alaska timber). During the first three
fiscal years after the projections were made, Ketchikan Pulp Company (KPC) was completing the
logging required under its long-term contract and a cancellation agreement. See KPC Settlement
Agreement. In 1999, the Agreement was extended to allow KPC one extra year to cut the
allocated timber. See KPC Contract Extension. During the fiscal years 1998, 1999, and 2000,
with the stimulus provided by the KPC cancellation agreement and its extension, logging averaged
138 MMBF/year. See logging graphs. As soon as those agreements expired, however, cutting
levels plummeted to a level far below the Brooks and Haynes projections:
B&H Hieh
B&H Medium
B&H Low
Actual Volume
tMMBFl
(MMBF)
(MMBFl
Cut (MMBFl
FY 2001
158
129
105
48
FY 2002
173
135
114
34
FY 2003
189
141
123
51
FY 2004
205
147
132
46
FY 2005
221
152
132
50
Average
189
141
121
46
See Kuiu DEIS at A-4 (Table A-1). These are approximately the cutting levels that prevailed
before the 50-year pulp mill contracts, when the average yearly cut was about 4 1 MMBF. See
1997 TEMP FEIS at 3-259.
Declining markets and logging levels led Gateway Forest Products, Inc. and Silver Bay Logging,
Inc. to file for bankruptcy protection after 2000. The steady market decline also led to an
emergency extension of time for companies to log Tongass timber under contract, and later the
cancellation of 20 timber sale contracts. See Extension of Certain Alaska Timber Sale Contracts,
67 Fed. Reg. 51,165, 51,166-67 (Aug. 7, 2002)); timber sale cancellations. The Forest Service
has continued to offer more timber volume than the average volume sold or harvested. See Lisa
K. Crone, Southeast Alaska Economics: A Resource-abundant Region Competing in a Global
Marketplace, in 72 Landscape and Urban Planning 215, 230 (2005).
GSS
4b
The Kuiu DEIS relies explicitly on the market demand projections made in 1997 to justify its
decision to offer timber. Those projections have not been updated to reflect dramatically changed
market conditions. Actual logging levels show that even the lowest of the 1997 projections have
proven dramatically too high. Thus, the continued reliance on these outdated market demand
projections misleads the public by presenting an inflated view of the market for Tongass timber
and by creating the false impression that this sale is needed to meet demand.
A. The Kuiu DEIS Relies Explicitly on the 1997 Projections
to Justify the Decision to Offer Timber.
The proposed Kuiu timber sale is justified in large part by the stated need to meet market demand.
See DEIS at 1-3 (Part of the purpose and need for the project is to provide “a timber supply
5
32 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
sufficient to meet the annual market demand for the Tongass National Forest” and to meet the
market demand for the planning cycle.). Appendix A of the DEIS summarizes the process by
which short and long term market demand is forecast. See Kuiu DEIS at A-6 to A- 18. This
discussion of market demand reveals that both the projections and the planning process rely
fundamentally on the 1997 projections. See DEIS at A-7 (stating that the formulas and
procedures used to forecast annual market demand are derived from two reports: Responding to
the Market Demand for Tongass Timber (Morse, April 2000) and Tongass National Forest
Timber Sale Procedures (Morse, October 2000)).
The Morse formula, which provides the formula for determining market demand, relies critically
on the 1997 Brooks and Haynes projections. See Morse Report at 8-10 (explaining the
projections and describing them as ‘Ten-Year Harvest Projections”). Indeed, the model
specifically “incorporates” the 1997 projections. Id. at 28. Further, the model operates on the
“assum[ption] that, at a minimum, processors will want to replace the volume removed fi'om
inventory.” Id. Each year, the “amount removed from inventory” is assumed to be, at a
minimum, the 1997 projections. Id. (stating that the model uses “[hjarvest projections developed
by the PNW Research Station”); see also 2001, 2002, & 2003 Offer Projections and 2006 Annual
Demand) (using 1997 projections in line K of formula). The DEIS also presents annual logging
level projections from 1998-2007 in a table entitled, “Projected and Actual Tongass Harvest
(MMBF).” DEIS at A-4. A footnote to the table indicates that it is based on the Morse report
from April 2000 and the Brooks and Haynes 1997 projections. DEIS at A-4, n. 1 . The table was
created in 2000, and the Forest Service has not changed the projections in it at all since that time.
Compare id. (Table A-1) with Morse Report at Table 1.
GSS
4c
B. The 1997 Market Demand Projections are Outdated, and The Forest Service Has
Recognized That Changed Conditions Have Undermined Several Important
Assumptions Underlying Them.
A few years after the 1997 demand projections were made, the market for Tongass timber
declined dramatically and has remained at that lower level. Since 2000, when the last timber was
cut pursuant to the long-term contracts and KPC Settlement, the average cut from the Tongass
has been about 46 mmbfryear, less than half of the “low” scenario projected in 1997. This decline
in logging levels has been accompanied by changes in the world market, including lower prices,
reduced share of the Japanese market, and the inability to sell chipped logs. These market
changes undermine several of the basic assumptions on which the 1997 projections were based,
and continued reliance on the outdated and demonstrably inaccurate projections misleads the
public in violation of NEPA.
The 1997 projections are based on a series of explicit assumptions. See Brooks & Haynes at 6-8.
These assumptions include predictions about Japanese markets, the ability to sell chipped logs and
other “manufacturing residues,” and the share of Alaskan lumber shipped to domestic markets.
In short, the entire “annual market demand” calculation assumes the need to meet the 1997
Brooks and Haynes projections. If the 1997 projections are too high, the annual market demand
calculation will be too high.
r>
Kuiu Timber Sale FEIS
Appendix C • 33
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Id. at 8; see also 1997 TLMP FEIS App. M at M-6. Each of the three demand scenarios
projected (low, medium, high) included different assumptions with regard to the variables. See
Brooks & Haynes at 5. Even thd assumptions included in the “low” scenario, however, have
proven too high. For each variable, market conditions have proven worse than projected.
In the low scenario, the 1997 projections assume that North America supplies “70 percent ... of
Japanese softwood lumber imports . . . .” See Brooks & Haynes at 9. In fact, “North America
accounted for just 61 percent of Japanese softwood lumber imports in 1999.” Wilderness SEIS at
3-288; see also id. at 3-253 (“the value of [Tongass timber exports to Japan] has declined by
more than half over the last five years.”); See at 1 (USFS letter to the editor) (“Extremely soft
Asian markets are the principal reason for [the] lack of interest in our timber oSerings. Demand
actually declined about ten percent per month from July to November.”); See at 1 1 (2001-02
Section 706(a) Report at 9) (explaining declining Japanese markets). In July 2003, the Forest
Service explained: “The Pacific Rim market for timber products has considerably changed due to
new suppliers and modifications to Japanese building codes. The Alaska industry struggles to
replace the demand.” See 1 (USFS briefing paper). A recent report confirms these trends in the
Japanese market, yet speculates that the dwindling export market is still a “better option for
Alaska timber markets” than the domestic market. See Market Outlook for Alaska Mental Health
Trust Timberlands at 12); See Crone, Southeast Alaska Economics (discussing the same trends);
and Crone, Rural Marmfacturing and the US. Wood Products Industry at 55 (stating that,
despite efforts to revive the market for Alaskan wood products, “most observers . . . believe it is
unlikely that production and employment will return to their previous levels” in the southeast
Alaskan wood products industry).
GSS
4d
Second, the 1997 projections assumed that 15 to 35 percent of the lumber produced in Southeast
Alaska would go to supply domestic markets. See Brooks & Haynes at 4. The loss of Japanese
markets, however, has greatly increased the relative share of production going to domestic
markets, where prices are considerably lower. Wilderness SEIS at 3-253. Seventy-one percent of
Southeast Alaska lumber production now goes to domestic markets, more than double what
Brooks and Haynes assumed. See id. (62% to continental U.S. plus 9% to Alaska); see also at 3
(2001-02 Section 706(a) Report at 1) (“evidence suggests that a substantial proportion of
^regional product is now being shipped to domestic markets. . . .”).rThis substantial increase in the
percentage going to domestic markets triggers a requirement contained in the Morse Report to
update the Brooks and Haynes projections: “If it can be documented that sales to domestic
markets account for more than 35 percent of lumber production in Southeast Alaska, revise the
ten-year harvest forecast.” Morse Report at 34. Thus, according to the Forest Service’s own
criteria, the Forest Service should have updated the Brooks and Haynes projections years ago^
Another assumption that did not materialize was the prediction that, following the closure of the
Alaska pulp mills, new markets would be found for low-grade timber. See Brooks & Haynes at 4
(“For these revised scenarios, we assumed that alternative markets, either export or domestic, can
be developed for chips, low-grade saw logs, and utility grade logs. In the absence of markets,
low-grade saw logs and utility logs may be left as logging residues.”); TLMP FEIS App. M
at M-6 (“All the projections assume that lower grade material that was previously directed to pulp
production, including the low-grade sawtimber previously directed to the KPC pulp mill, can be
7
34 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
exported.”). The Forest Service has acknowledged that there is no such market any longer:
“While these data indicate that a market existed for chips in 2000, this is no longer the case.”
Wilderness SEIS at 3-252 to 3-253.
r
Thus, several of the fundamental assumptions underlying the 1997 projections have not come to
fhiition, and markets have declined much further than those projections contemplated.
GSS Nonetheless, the Kuiu DEIS relies on the 1997 projections without disclosing the changes in
4e market conditions or explaining that the annual offer level determination is based on the outdated
projections. Without that information, the DEIS presents the misleading impression that offering
timber from Kuiu is necessary to meet demand. This presentation violates NEPA.
The Restriction Of Subsistence Uses Caused By The
Kuiu Project Is Not “Necessary.”
GSS
5a
^Pursuant to section 810(a)(3)(A) of the Alaska National Interest Lands Conservation Act
(ANILCA), 16 U.S.C. § 3 1 20(a)(3)(A), the Kuiu DEIS includes a finding that the possibility of a
significant restriction on subsistence uses of deer is “necessary, consistent with sound
management principles for the utilization of public lands.” DEIS at 3-96. The explanation for this
finding is that “the Kuiu Timber Sale is necessary as a component of the timber management
program designed to implement the Forest Plan and to meet TTRA direction.” DEIS at 3-93.
Because both the Forest Plan and the market demand calculation to meet TTRA direction were
^arbitrary, this finding is also arbitrary.
In Natural Resources Defense Council v. United States Forest Service, the Ninth Circuit held that
the Forest Service acted arbitrarily in adopting the Forest Plan. 421 F.3d at 806-10. The agency
mistakenly doubled its projections of demand for Tongass timber, a mistake that was significant in
the agency’s selection of an alternative to adopt as the Forest Plan. Id. at 807-10. The court also
held that the EIS prepared by the agency in support of the Plan was inadequate, because, among
other things, the agency had failed to consider reasonable alternatives that would have allocated
less land to logging while still meeting market demand for timber. Id. at 813-14. The premise of
the decision was that, had the agency correctly understood the projected demand for timber, it
could have fully met the market demand goals without logging lands most sensitive to
disturbance. See 421 F.3d at 808 (“if the demand for timber was mistakenly exaggerated, it
follows that the timber harvest goal may have been given precedence over the competing
environmental and recreational goals without justification sufficient to support the agency’s
balancing of these goals.”); see also id. at 814 (“Because the range of alternatives considered by
the EIS omits the viable alternative of allocating less unspoiled area to development [Land Use
Designations], we hold that the EIS is inadequate, in violation of NEPA.”).
The Kuiu Project Area is within the traditional subsistence use area of Kake, and the DEIS
recognizes that deer on Kuiu Island are “extremely important” for subsistence users in all of the
communities in the region. See DEIS at 3-49, 3-76 to 3-77. Kuiu Island provides a great deal of
high value winter habitat for deer, and the proposed logging and road building will impact much
of that habitat. See DEIS at 3-23. Thus, even if the Kuiu Timber Sale were based on a rational
projection of market demand (rather than the erroneous projections of the Tongass Land
8
Kuiu Timber Sale FEIS
Appendix C • 35
GSS
5b
GSS
5c
GSS
6
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Management Plan), the “necessary” finding would still be arbitrary. That demand could have been
met from areas less sensitive to Fogging.
However, the Forest Service also acted arbitrarily in calculating the market demand in the Kuiu
DEIS, which forms part of the basis for the agency’s conclusion that the significant restriction to
subsistence was “necessary.” See DEIS at 3-93 (discussing the need to meet market demand).
While the DEIS does not repeat the doubling error of the Tongass Land Management Plan, it
does fail to consider abundant, compelling evidence that actual market demand is significantly
^ lower than projected.
In short, the finding that the significant possibility of significant restriction to subsistence uses
caused by the Kuiu Timber Sale is “necessary, consistent with sound management principles for
the utilization of the public lands,” is not supported by the Forest Service’s own acknowledgment
that actual demand levels are significantly lower than the levels projected. The failure to consider
this evidence renders the finding arbitrary.
The Kuiu Timber Sale DEIS Lacks
A Meaningful Economic Analysis
r
There a lack of accurate information on the costs that have been, and will be necessary, to
prepare, ofier, and administer the Kuiu Project. That information is required as part of the
Financial Efficiency Analysis, and its omission prevents the public and decision makers from
accurately evaluating the financial costs and benefits of the alternatives and fi’om measuring the
return to the public for its investment in administering any potential logging in the Kuiu Project
Area. Information in the DEIS on expenditures already made for ‘pre-roading’ the project area is
totally absent. The DEIS contains no discussion of the effects of exporting round logs, for
species other than AYC.
V-
The DEIS Does Not Disclose Public Costs and it
Misleads the Public and Decision-makers
In plaiming a timber sale project, the Forest Service is required to compare the public money it
will spend administering the project with the prospective returns to the agency. That analysis,
which “compares estimated Forest Service expenditures with estimated financial revenues”,
allows the decision maker and the public to gain some understanding of “the future financial
position of the program if the project is implemented.” Forest Service Handbook § 2409. 18 30.
This comparison of public costs and returns, called a Financial Efficiency Analysis, is required by
the Forest Service Handbook and by NEPA. See Forest Service Handbook §§ 2409. 18 20 at 5-
6, 2409. 18_10 at 10, 2409. 18 30 at 7; 40 C.F.R. § 1508.8(b) (“Effects includes ecological . . .
aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative.”);
Hughes River Watershed Conservancy v. GUckman, 81 F.3d 437, 446 (4th Cir. 1996) (“NEPA
requires agencies to balance a project’s economic benefits against its adverse environmental
effects.”).
9
36 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
7
Indeed, the DEIS states in its section on Economic Efficiency (DEIS 3-259), “Economic
efficiency compares the costs and benefits of resources, whether or not they can be quantified. It
is another tool used in the decision making process to gain fiill information, both quantitative and
qualitative, about a project and differences among alternatives”. The DEIS then only discusses
non-quantifiable values. The only information revealed regarding ‘Public Investment’ costs is
when the DEIS states that “The average Region 10 budget allocation costs and management
expenses are subtracted Ifom net stumpage values to determine net value and gives the an
allocation figure of $101.00 per mbf (DEIS 3-107-108). That analysis, however, does not
contain any discussion or estimation of the public costs that have been or will be incurred by the
Forest Service in, planning, preparing, and administering the Kuiu Timber Sale Project.
Accordingly, the DEIS does not comply with the Forest Service Handbook or its own description
qf the Financial Efficiency Analysis.
This failure is particularly egregious given the central role played by economics in the decision
making process for the Kuiu Timber Sale Project. Economics is identified in the DEIS as one of
four “significant issues” for analysis and is a major component of the Purpose and Need statement
of the DEIS. Moreover, the benefits associated with logging in the Kuiu Project Area are almost
entirely financial. Indeed the DEIS devotes pages to discussing ‘Timber Sale Economics’ in terms
of profitability for sale operators (DEIS 3-97-105) and only a couple of short paragraphs to the
public costs of the sale. Thus, economic benefits fi'om logging - whether to timber companies,
mills, local economies, or the Forest Service - provides the basic justification for offering timber
in this area.
GSS
7 cont
The Budget Allocation Costs Used in the DEIS are Inaccurate
To remedy this deficiency, the Forest Service must supplement the Kuiu DEIS with an accurate
estimate of the costs that will be incurred by the public. That cost must then be factored into a
Financial Efficiency Analysis to allow the public and decision maker to understand fully the
financial ramifications of any approved logging in the Kuiu Project Area.
Even the limited analysis undertaken in the planning record is insufficient. The “project costs”
identified in the DEIS are based on the “Region 10 Budget Allocation Estimates” (DEIS 3-107-
108). Those estimates are outdated and dramatically understate actual Forest Service expenses.
The Forest Service actually loses millions of dollars annually administering the Tongass timber
sale program and those losses are not reflected in the budget allocation estimates.
(335 The Forest Service is required to maintain annual records of its expenses involved in administering
8a the Tongass timber sale program. Pursuant to the 1997 TEMP, the Forest Service must monitor
its annual expenditures and evaluate whether the “costs associated with carrying out the planned
management prescriptions (including those of producing outputs) [are] consistent with those
estimated in the Plan.” These expenses are reported and the monitoring questions analyzed each
year in an Annual Monitoring & Evaluation Report. See 1997 Tongass Land Management Plan
Revision at 6-16 (Forest Service must monitor annual expenditures and evaluate whether the
, , “costs associated with carrying out the planned management prescriptions (including those of
10
Kuiu Timber Sale FEIS
Appendix C • 37
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
producing outputs) [are] consistent with those estimated in the Plan ”). These monitoring reports
reflect the actual expenditures made by the Forest Service each year on timber-related activities
and, accordingly, provide a more accurate basis for estimating Forest Service costs associated
with timber sale projects. The following analysis is taken in part from the ‘Administrative Appeal
of the Emerald Bay Timber Sale Project ROD’ filed on January 5*^' by the Southeast Alaska
Conservation Council, the Sitka Conservation Society, the Tongass Conservation Society, The
Wilderness Society, the Natural Resource Defense Council, Greenpeace, and the Sierra Club. We
incorporate that document by reference here.
According to the 1997 FEIS for the Tongass Land Management Plan, six categories of
expenditures are “related to timber management activities:” Timber Sale Management,^ Timber
Road Construction,^ Road Maintenance,"* General Administration,^ Ecosystem Planning,
Inventory and Monitoring,^ and Forest Vegetation Management. See 1997 TLMP FEIS at 3-505.
For FY 98-03, the Monitoring Reports disclose the following annual logging-related expenditures
in those categories:
GSS
8a cont.
^ “Timber Sales Management includes project level timber sale planning (including resource
support), silvicultural examinations, sale preparations (including resource support), and harvest
administration.” 1997 TLMP FEIS at 3-505.
^ “Timber Road Construction includes engineering, planning, and administration of road contracts
for timber sale road building.” 1997 TLMP FEIS at 3-505.
"Road Maintenance supports the main transportation s> stem to provide safe and efficient access for the multiple
uses of National Forest lands that is compatible with ecosj stem management principles." 1997 TLMP FEIS at 3-
505.
^ “General Administration provides line management and indirect administrative support and
common services to the extent that benefiting programs or projects cannot be identified.” 1997
TLMP FEIS at 3-505.
® "Ecos) stem Planning, Inventor) and Monitoring" is defined by the FEIS to include
all resource planning costs of fulfilling the requirements of the National Forest
Management Act, including appeals and litigation related to forest planning, the
inventory and assessment of resources on NFS lands at the Forest Plan level, and
the monitoring and evaluation of forest plan implementation over time. The costs
vary by alternative due to the monitoring plan, which is tied to output level; those
alternatives with less timber harvesting will have less areas to be monitored.
1997 TLMP FEIS at 3-505.
11
38 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
8a cont.
FY 1998
FY 1999
FY 2000
TY 2001
FY2002
FY 2003
Timber
Management
$19,842,546
$19,842,546
$14,524,473
$21,192,221
$17,923,470
$12,833,100
Road
Construction
$7,685,131
$7,685,131
$3,763,542
$13,180,325
$15,039,240
$17,961,400
Road Maintenance
$3,082,257
General
Administration
$5,689,191
$5,689,191
$3,842,025
Ecosystem
Planning/
Inventorying/
Monitoring
$3,112,283
$3,112,283
$1,404,772
$2,613,940
$3,040,030
$2,071,200
Forest Vegetation
Management
$1,577,701
$1,577,701
$933,105
Total:
$37,906,852
$37,906,852
$27,550,174
$36,986,486
$36,002,740
$32,865,700
Logging Level
(MMBF)
120
146
147
48
34
51
Cost/mbf
$316
$260
$187
$771
$1056
$577
Cost/CCF
$155
$127
$92
$378
$517
$283
Using these more accurate numbers, the actual cost incurred by the Forest Service in
administering the Tongass timber sale program between 1998-2003 averaged $5 16/mbf logged —
more than five times the $101.0/mbf average cost reflected in the Forest Service’s assessment of
the costs and revenues of the various alternatives. After the end of its long term timber contracts
in 2001, the Forest Service’s average cost rose to $786/mbf logged — more than eight times the
‘Budget Allocation’ cost estimates used in the Kuiu DEIS.
Those numbers present a stark contrast to the income received by the Forest Service from timber
logged on the Tongass. In FY 1998, income to the Forest Service for timber logged in the
Tongass totaled approximately $4,992,000 (1998 Cut and Sold Report). That number rose to
approximately $5,456,000 in FY 1999 (1999 Cut and Sold Report), and again in FY 2000 to
approximately $5,582,000 (2000 Cut and Sold Report). Revenue then declined to approximately
$1,855,000 in FY 2001, approximately $1,242,000 in FY 2002, and approximately $1,464,000 in
FY 2003 (2001, 2002, 2003 Cut and Sold Reports). In the last two years, it has declined even
further to approximately $792,000 in FY 2004 and approximately $578,000 in 2005. (2004, 2005
Cut and Sold Reports). These expense and receipt numbers paint a picture of dramatic losses to
the public occasioned by the timber sale program on the Tongass
12
Kuiu Timber Sale FEIS
Appendix C • 39
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
8a cont.
The budget estimates used by the Forest Service to present the likely costs to the public of
planning, preparing, and administering the Kuiu Timber Sale Project grossly understate the actual
expenses that will be incurred by the agency.
Cost Benefit Analysis Tiers to an Invalid Forest Plan
The DEIS states “Economic efficiency analysis or cost/benefit analysis is best done at a scale
much larger than a project area. A regional scale economic analysis is presented in the Forest Plan
^EIS Part Two, which balances resource uses and values for the Tongass National Forest” (DEIS
3-108). Not only must a financial efficiency analysis be done at the project level, comparing
Qgg quantifiable costs and benefits, as we have made clear in the proceeding section, but the Forest
8b Service can’t tier to a Forest Plan that has been declared invalid precisely because it failed to
achieve a proper balancing of uses due to a faulty ‘Market Demand Analysis”.
Forest Service Spending on Kuiu Roads Prejudices the NEPA Process
GSS
9a
During the summer of 2005 the Forest Service contracted with Channel Construction of Juneau to
up-grade the Kuiu Project Area roads (Kuiu Roads Maintenance, Forest Development Project,
solicitation number IFB-Rl 0-05-07 1). Specifically Roads 6402, 6448, 6404, and 6415 were re-
constructed and were done so prior to the Kuiu Timber Sale Project’s NEPA process being
completed. As the DEIS states “None of these roads connect to any community, other public
roads, or other public transportation system. All of the forest roads were constructed in support
of timber sales. . .” (DEIS 3-217). This demonstrates that there is little or no public transportation
purpose for reconstructing these roads. The Public Works Contract involved widening the
/Surface, removing stumps, and other activities that demonstrate that the contract’s purpose
included getting the Kuiu Timber Project Area ready for the proposed sale. Having already
expended $161,465.90 on ‘pre-roading the project area prejudices the outcome of the NEPA
process. It was done without any public process or evaluation of the environmental impacts
resulting from the re-construction. The DEIS failed to disclose that these expenditures had
already been made. Kuiu is not an isolated case of pre-decisional road-building using maintenance
as the guise. Other cases are Traitors Cove (Francis Cove roads project), Zarembo roads project,
and the Overlook roads project. The DEIS must discuss all quantifiable public investment costs.
The DEIS Fails to Disclose The Public Investment Costs of ‘Pre-roading’
^re-roading has become a standard practice on the Tongass to make sales more ‘economic’ for
operators. Road building contracts have been solicited, and in most cases awarded, for all of the
FY 2005 large timber sales that involve new road construction. These sales are Skipping Cow,
pre-roaded for $1,138,000.00, Upper Carroll n, pre-roaded for $1,555,000.00, Lindenburg, pre-
GSS $391,800.00, Luck Lac II, pre-roaded for $244,566.88, and Buckdance Madder (bid
9b not awarded at this time). Other large sales have been pre-roaded in other years, including Finger
Point for $680,991.50, Fusion for approximately $1,031,854.42, Summore Change II for
$2,073,739.60, Kogish-Shinaku for $875,292.62, and Midway for $2,695,547.00. These numbers
demonstrate a consistent trend, not an aberration. The DEIS must discuss all likely public
investment costs and the market context in which the project is taking place.
13
40 • Appendix C
Kuiu Timber Sale FEIS
GSS
10a
GSS
10b
GSS
10c
GSS
11
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Markets and the NEAT Model
A non-competitive market for large roadless area sales has existed for several years on the
Tongass National Forest. This is made evident by the fact that the overwhelming majority of large
sales between 1998 and 2005 only received one bid or no bid at all. In 2005 all large sales
received only one bid. These sales. Upper Carroll II, Luck Lac II, Lindenberg, Shady, and
Skipping Cow accounted for the overwhelming volume sold in FY 2005. In 2006 Buckdance
Madder was also offered and received only a single bid. The DEIS’s statement “In the past timber
sales on the Petersburg Ranger District have had multiple bidders. . .” (DEIS 3-97) is a
misrepresentation of the situation regarding large sales.
The DEIS states “ Maintaining a consistent small sales offering is a component of the Petersburg
Ranger District timber sale program. Due to the distance of the Kuiu Timber Sale Area from
processors, it is unlikely individual units will be offered for sale (DEIS 3-105). This is an
^^mission that any offering from the Kuiu project will be a large sale. The few mills that will be
able to bid on any sale offered under the Kuiu Timber Sale Project do not constitute a competitive
market for a timber sale under the Kuiu Project or any of the other large sales the Forest Service
^as been offering.
The existence of a non-competitive market is important to the proper functioning of NEAT
(NEPA Economic Analysis Tool) because NEAT is a transactional system that bases its
calculations of Fair Market Value on what was bid for past sales of the same size and
Characteristics. As shown in the above discussion most if not all of the transactions that would or
will be providing input to the model have received only a single bid and have also been pre-
roaded. There is no discussion of this in the Timber Economics section of the DEIS, or in the
nearly non-existent public investment discussion.
The DEIS cites Wrangell’s processing facility as being a possible beneficiary of the Kuiu Timber
Sale Project with no substantiation for this claim. There is information to cast doubt on it
however. Recent sales such as Skipping Cow, even though it would be pre-roaded and it is
located much closer to Wrangell then the Kuiu Project Area, did not receive a bid from Silver Bay
Logging. Another sale located on North Etolin Island, Red Mountain, has been offered with a
'blanket export waiver for all species, and including both salvage and green wood. ®iat the Forest
Service is indicating that a nearly 6 million bf sale located very close to Wrangell will be un-
economical for Silver Bay to process, is an indication of just how misleading it is to characterize
the Kuiu Timber Sale Project as being likely to benefit Wrangell.
The DEIS Fails to Discuss the Likely Impacts of Round Log Exports
While the Forest Service has accounted for the export of AYC in their discussion of the economic
impacts of the Kuiu Project, the DEIS does not discuss the likelihood that other species will be
exported as well. Moreover, the Forest Service has failed to disclose readily available information
on the permits they have granted in the recent past for the export of un-processed logs. As shown
▼ above, at least some sales are now receiving blanket export waivers. As the probability that timber
14
Kuiu Timber Sale FEIS
Appendix C • 41
GSS
1 1 cont.
GSS
12
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
will be exported from the region un-processed bears directly on the number of jobs that may be
generated by the project, this information is critical to the reviewing public and to decision
makers. In regards to the Kuiu Project Area specifically, the Forest Service has granted permits
for the export of un-processed Hemlock and Sitka Spruce harvested from both the Rowan Bay
and Saginaw Bay areas as recently as CY 2000.
The DEIS states “Federal policy requires that timber harvested from the Tongass be processed
within Southeast Alaska, supporting wood products jobs and income throughout the region’
(DEIS 3-251). This statement, as shown above, is a misrepresentation of what the Forest Service
actually is allowing.
DEIS Provides Inadequate Analysis of Impacts to Inventoried
Roadless Areas (IRAI and Wilderness Character
We are very disturbed to see that under the preferred alternative (Alternative 4) the proposed
Kuiu Timber Sale Project will enter into IRAs (North Kuiu Roadless Area and Security Roadless
Area). This is of particular concern in light of the very heavy fragmentation that has occurred
across the Kuiu landscape from past harvest and road construction. This project would directly
impact 663 acres within the North Kuiu IRA (DEIS Table 3-2) and an additional 134 acres in the
Security IRA (DEIS Table 3-2). In total, 797 acres within IRAs would be negatively impacted.
Additionally, approximately one mile of new road would be constructed within an IRA. Of the
five action alternatives outlined in the DEIS, the preferred alternative (Alternative 4) “could have
the greatest direct effect on the roadless area” (North Kuiu; Roadless Areas Resource Report for
Kuiu Timber Sale Planning Area; K. Rutledge 2005). (jiven the strong scientific support for
protecting Tongass roadless areas, including that of the TEMP Peer Review team, and the strong
public sentiment that these areas should be protected, we can see no valid reason for moving
forward with this sale.
We are concerned 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 DEIS fails to
adequate^ ana&yze fne pRJlentia'i 'imparts of frie project on vritdemess c^arartefiXncs TneT>SEi?)
does mention wilderness and includes excerpts from the Tongass Land Management Plan
Revision Final Supplemental Environmental Impact Statement (TLMP SEIS) description of the
wilderness characteristics of the North Kuiu Roadless Area (but not of the Security Roadless
Area; DSEIS 3-9). The only attempt at an analysis is two sentences of vague text (DEIS 3-9).
The final EIS should include a thorough analysis of the potential impacts of the proposed action
on the wilderness characteristics of the North Kuiu and Security IRAs. The DEIS therefore fails
to satisfy the Forest Service’s obligations under NEPA to consider the environmental impacts of
its proposed action.
The North Kuiu Roadless Area is especially critical to maintain as undeveloped because it is
virtually the last un-logged, un-roaded fish and wildlife habitat of this portion of Kuiu. The North
Kuiu IRA serves a variety of non-timber values, including important benefits to wildlife,
subsistence, and recreation. This roadless area is one of the last remaining unroaded portions of
^ North Kuiu Island. The public has repeatedly highlighted the value of maintaining the roadless
15
42 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
1 2 cont.
quality of undeveloped areas on North Kuiu. For example, during the forest plan revision and
appeals, “The City of Kupreanof commented that the general area (North Kuiu Island) should be
preserved as a wilderness because of its subsistence value” (TLMP FSEIS App. C at 381).
Further, with regards to other timber sales on North Kuiu (Crane and Rowan Mountain); “The
City of Kake commented that subsistence use would be adversely affected by timber harvest,
including the cultural and spiritual value of participating in traditional subsistence harvests in the
old-growth forests used by the residents of Kake for countless generations” (TLMP FSEIS App.
Cat 381).
The DEIS states “all effects would occur along the edge of the roadless area. With the ongoing
influence from roads and managed stands, the effects to the overall roadless area characteristics
and values would be minimal” (DEIS 3-18). This conclusion is arbitrary; the following
information, addition to information above, clearly discounts the preceding statement. The North
Kuiu Inventoried Roadless Area is about 9,544 acres (DEIS Table 3-1), including about 5,932
acres of high- volume, old growth forest (TLMP FSEIS App. C at 382): “The roadless area does
have a relatively high amount of contiguous old growth in contrast with the surrounding lands
where timber harvest has heavily fragmented the stands of old growth” TLMP FSEIS App. C at
383.
Road systems and logging activities surround this roadless area on all sides (TLMP FSEIS App. C
at 377). The clearcuts that are proposed in the narrowest portion of the IRA (units 307 and 308)
will effectively fragment the Kuiu IRA into two patches of isolated roadless areas surrounded by
highly developed areas. This fragmentation would significantly degrade the wilderness character,
ecosystem integrity and landscape connectivity important to healthy fish and wildlife populations.
The Security Inventoried Roadless Area is about 35,497 acres (TLMP FSEIS App. C at 364).
This IRA was given a high rating in the Wilderness Attribute Rating System (WARS; 22 or 25;
TLMP FSEIS App. C at 368). Again, the public has repeatedly highlighted the value of
maintaining the roadless quality of undeveloped areas on North Kuiu (as with regards to North
Kuiu IRA above). For example, during the forest plan revision and appeals, “The City of Kake
suggested that Security Bay be designated as wilderness because it was the most important
subsistence area left to the Village of Kake. They wanted old growth protected, especially on the
west side of Security Bay (i.e. the Security Roadless Area). The City of Kupreanof commented
that the area should be preserved as a wilderness because of its subsistence value” (TLMP FSEIS
App. C at 371). Further, with regards to other timber sales on North Kuiu (Crane and Rowan
Mountain); “The City of Kake commented that subsistence use would be adversely affected by
timber harvest, including the cultural and spiritual value of participating in traditional subsistence
harvests in the old-growth forests used by the residents of Kake for countless generations”
(TLMP FSEIS App. C at 372).
It is particularly disappointing that the Forest Service has elected to pursue roadless area entry in
this sale, given the U.S. House of Representative’s bipartisan passage of the Chabot-Andrews
amendment to the FY05 Interior and Related Agencies Appropriations Bill, which prohibits
spending any more of taxpayers’ dollars subsidizing wasteful and economically unfeasible
roadbuilding projects in the Tongass National Forest. Moreover, the overwhelming majority of
ir>
Kuiu Timber Sale FEIS
Appendix C • 43
GSS
13a
GSS
13b
GSS
14
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
the interested public supports protecting roadless areas, including - and in many cases especially -
those of the Tongass. In the past few years, the Forest Service has received literally millions of
public comments supporting protections for Alaskan roadless areas, through inclusion of the
Tongass (and Chugach) in the Roadless Area Conservation Rule (RACR or “Roadless Rule”).
More that 7500 Alaskans participated in the RACR, and 82% of them favored protecting roadless
areas in the Tongass. The American public has communicated in no uncertain terms that it feels
the most valuable use of roadless areas may be realized when they are left in their unroaded
condition.
We oppose the Tongass National Forest’s decision to enter roadless areas of the Kuiu Timber
Sale for several over-arching reasons related to the management of roadless areas. The agency
lacks an adequate rationale for entering roadless areas on North Kuiu Island. The attached letter
to Chief Bosworth, dated September 2, 2003 details why roadless area entry is not needed to
maintain current logging levels on the Tongass. Indeed, demand from future facilities, e g. the
would-be veneer operation in Ketchikan, that the Forest Service speculatively cited as a reason
for suspending the Roadless Rule has not materialized.
The DEIS Violates NEPA By Failing To Evaluate The Effects Of Committing The Kuiu
Island Project Area To Development Before The TLMP Is Revised
r . .
NEPA bars the Forest Service from taking certain actions while preparing a programmatic EIS.
See 40 C.F.R. 1506. 1(c). Under the illegal 1997 TLMP, this timber sale would illegally settle the
fate of this roadless area by committing it to developed status and eliminating options for
preserving it for other multiple uses through the court-mandated revision of the 1997 TLMP.
Section 1 506. 1 bars the Forest Service from working on a proposal covered by the pending
programmatic decisions unless;
V
l)The Kuiu Ttimber Sale is justified independently of the programmatic decision. The NFMA
mandates that all management activities approved on national forest system lands, such as the
tongass, be consistent with a lawfully adopted forest plan. See 16 U.S.C. 1604(i).|^he Forest
Service cannot rely on the 1997 TLMP to justify proceeding with this timber sale because the
court invalidated TLMP in NRDC v. U.S. Forest Servic^
^)The Kuiu Island DEIS is adequate, and 3) the decisiorrto approve this project will not tend to
limit alternatives in the court-mandated TLMP revision.
None of these factors is satisfied in this case.
The DEIS Has an Inadequate Ran2e of Alternatives
^he Kuiu project area has an extensive road network, much of which has had little or no
maintenance. By tying reduced open road densities in the Kuiu project area to increased timber
harvest associated with this project, the DEIS creates an artificial incentive to proceed with an
action alternative. We specifically request an alternative be developed that responds to the high
open road density and poor state of such roads without new road construction, road
reconstruction and timber harvest.
17
44 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
The Comparison of Alternatives Is Insufficient
Alternative Comparison Based on POG
/Table
2-2 (p.2-17) purports to compare the effect of project alternatives on wildlife habitat and
subsistence; however, we contend that the table does an inadequate job. The various kinds of data
on acres "maintained" (of POG, deer habitat, and coarse canopy forest) are largely irrelevant
without some context. A more meaningful analysis is shown in the following table .
Alternative:
1
2
3
4
5
Remaining POG (acres)
27,112
26,628
26,329
25,710
25,906
Total POG Lost (acres)
-10,393
-10,877
-11,176
-11,795
-11,599
Total % POG Lost
28%
29%
30%
31%
31%
New POG Loss (acres)
0
-484
-783
- 1,402
- 1,206
New % Change in POG
0%
- 5%
-8%
- 13%
- 12%
For comparison of alternatives, the most important quantities here are the two rows giving
percentage losses. Both rows should be included in Table 2-2, in place of the existing POG row.
The analysis on p.3-39 should also incorporate this approach to show clearly the effect of the
direct and cumulative effects.
Alternative Comparison Based on Coarse Canopy Stands
/Similarly, Table 2-2 of the DEIS reports the remaining acres of coarse canopy forest, by showing
the number of remaining acres. Those numbers are largely irrelevant without some context. A
more meaningful comparison would show the loss in acreages and percentages, with the
percentages being the key quantities, as shown here:
Alternative:
1 2 3 4 5
Remaining Coarse Canopy Acres
Total Coarse Canopy Lost (Ac)
Total % Coarse Canopy Lost
New Coarse Canopy Loss (Ac.)
13,009 12,781 12,675 12,196 12,456
-13,549 -13,777 -13,883 -14,362 -14,102
-51% -52% -52% -54% -53%
0 - 228 - 334 - 813 - 553
New % Change in Coarse Canopy
0% - 2% - 2% - 6% - 4%
We note that the rows with percentages are shown in Table 3-12, but they are conspicuous in
their absence in Table 2-2. The discussion on pp.3-40 should have discussed the meaning of these
percentages.
Alternative Comparison Based on Loss of Low-Elevation POG
GSS
15c
Regarding the loss of low-elevation POG, Table 2-2 and the related discussion on pp.3-18 & 19
are deficient because they show only the incremental loss of such habitat. An analysis similar to
18
Kuiu Timber Sale FEIS
Appendix C • 45
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS those above is needed, including the original (1954) and remaining acres of such habitat and the
1 5c cont total and incremental percentages of change.
Alternative Comparison Based on High Value deer habitat losses
GSS The row in Table 2-2 showing remaining deer habitat in the project area should be removed and
1 5d be replaced with the second and third rows from Table 3-25 (p.3-58). This is the kind of data that
has been described above. We note, however, that the data in these rows of Table 3-25 should be
Negative quantities.
Alternative Comparison Based on Subsistence
Data should be presented rather than the sentence that was embedded in Table 2-2 for the
subsistence issue. The relevant data is estimated maximum carrying capacity for deer, based on
GSS use of a deer multiplier’ of 100 deer/sq-mile for an HSI of 1 .3. Additional rows could include
1 5e ability to satisfy estimated subsistence needs for deer and the state deer population objective for
the area. However, a substantial factor of safety should be incorporated to account for imprecise
modeling methods (including this proscribed use of the model) and data, and to account as well as
possible for severe winters (since the deer model only estimates for average winters).
Alternative Comparison Relative to the Forest Plan Wolf Standard & Guideline
GSS
15f
The alternative comparison should include effect on wolves, and the corrected deer carrying
capacity multiplier specified the section above is one way of doing this.
The Comparison of Alternatives Embedded in Chapter-3 Is Also Misleading.
There is also a comparison of alternatives on pp.3-69 to 71 . All the above comments also need to
^e incorporated into that section.
Direct & Cumulative Effects on Forest Habitat
Inadequate Habitat Loss Data Necessitates Preparation of an SDEIS
Analysis we have done on data in DEIS Tables 3-1 1 & 3-12 reveals a significant problem with the
data. As shown in the table below (derived from the DEIS data), the DEIS suggests that the loss
of coarse canopy forest in the project area exceeds the loss of productive old- growth forest. But
this is impossible.
Alternative: 1
2
3
4
5
Total POG Lost (acres) -10,393
Total Coarse Canopy Lost (acres) -13,549
-10,877
-13,777
-11,176
-13,883
-11,795
-14,362
-11,599
-14,102
As discussed later, this is a correct expression of the deer multiplier, and the expression of it used in the DEIS
(100 deer/sq-mile at an HSI of 1.0) is incorrect and over-estimates canning capacity by about 33%.
10
46 • Appendix C
Kuiu Timber Sale FEIS
GSS
16
GSS
17
GSS
18
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
One reason the figures are not comparable is that Table 3-12 is footnoted as including losses from
“natural events such as windthrov/’ in addition to those from logging and roadbuilding. The
DEIS does not explain what was included in Table 3-1 1, other than “timber harvest.” It
apparently does not include POG lost in natural events, and also might not include losses from
roadbuilding. The POG table should be updated to be comparable to the coarse canopy table in
every respect, and if possible natural and directly or indirectly man-caused losses should be shown
separately in both tables.
Fatal weaknesses of the DEIS are that it does present complete data for both the loss of POG and
of coarse canopy forest and that it does not sufficiently describe the nature of the data. These
weaknesses make it impossible for us to evaluate and comment on the likely impacts of the project
alternatives to wildlife and subsistence.
It is necessary that the next Kuiu EIS evaluate impacts to POG in the same way such impacts
have been evaluated for coarse canopy. The combined effects of natural and human-caused losses
of POG must be evaluated, and the percent changes in amount of POG from historic and current
conditions must be considered. The proportion coarse canopy in the POG losses also needs to be
evaluated. Similarly, losses of the better habitat quality stands of TimTyp Class 5 forest need to be
evaluated too.
Analyses of Direct and Cumulative Effects on the Forest Matrix Were Incomplete
The DEIS states (p.3-41) that “within the project area (at) least 35 percent of the matrix lands are
unavailable for timber harvest consideration” and that “they will remain standing throughout the
100 year planning horizon” (sic). Then on the next page the DEIS purports to discuss direct and
indirect timber program effects on the matrix in the project area. In reality, however, the
discussion is entirely about the amounts of POG and coarse canopy forest that would remain
generally throughout the project area, not how much of those kinds of forest in the matrix remain
now or will remain in the future.
We contend that the discussion of forest in the matrix needs to consider POG, TimTyp, elevation,
and aspect in evaluating direct, indirect and cumulative effects on the matrix. The contexts
considered need to be historic (1954), current, project, and other foreseeable logging (each
expressed in terms of post-canopy closure conditions where applicable).
Use of the Yol-Strata Dataset in Wildlife Modeling and Analysis Should Be Abandoned.
The Vol-Strata dataset and the DeGayner (1997) deer model (which uses that dataset) are not
appropriate for wildlife analysis. A recent Forest Service study said this about the Vol-Strata
dataset; “Although the 1997 TEMP timber- volume map* adequately portrays timber- volume
information, the revised map^ does not adequately portray or model forest structure, ecosystem
diversity, or wildlife habitat.” (Caouette and DeGayner (2005), p.51) Another Forest Service
** This is an expression of the Vol-Strata dataset in the form of a map.
^ This refers to the same map (the "1997 timber-volume map") and its underljing Vol-Strata dataset.
20
Kuiu Timber Sale FEIS
Appendix C • 47
GSS
1 8 cont.
GSS
19
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
study also commented on the Vol-Strata and datasets like it: “There seems to be no correlation
between timber volume and forest structure,” and that “any forest stratification that has timber as
its primary^ objective’*^ will necessarily group together stands of similar timber volume regardless
of differences in forest structure.” (Caouette et al. (2000), pp,9 & 17) Therefore, Vol-Strata
should not be used at all for wildlife analysis (contrary to what has been done throughout the Kuiu
DEIS).
The principles described above are evident in further documentation provided in Attachment 1 of
our comments.
TimTyp Should Be Used In Place Of Vol-Strata For Wildlife Modeling & Analysis.
The TimTyp dataset should be used instead of the Vol-Strata dataset for all wildlife modeling and
analysis, until such time that it may be replaced by a better dataset.*^
The Forest Service replaced the TimTyp dataset with Vol-Strata only because the agency
misinterpreted a court order and because it misunderstood the true nature and applicability of the
two datasets.
The Court Order: In responding to comments on the Scott Peak DEIS, the Forest Service
revealed that it believes abandonment of the TimTyp dataset for wildlife analysis was dictated by a
court order in The Wildlife Society v. Barton (1994). (See Scott Peak FEIS, p.C-50. The court
Order is in Attachment 2; please add it to the planning record.) We believe that notion has been
disproved in the Greenpeace et al. (2006) appeal of the Scott Peak FEI S/ROD, and incorporate
that argument here by reference (and ask that it be included in the project record and be
considered). Briefly, the ruling was specific to the particular use of the TimTyp volume classes for
determining the “proportionality” of timber sales under two long-term timber contracts in a
manner specified in the Tongass Timber Reform Act.*^ The ruling did not proscribe any other uses
of TimTyp (such as those we advocate for wildlife modeling and analysis) - the order ruled out
the specific use of TimTyp to determine timber inventory volumes because TimTyp is inaccurate
for that particular application. Forest Service scientists familiar with TimTyp and the court order
have similarly recognized the Order’s narrowness, by saying the “judge ruled that the Forest
Service’s timber- volume classes represented arbitrary and capricious information for meeting
requirements of the proportionality law.” (Caouette & DeGayner 2005, p .50 in jml, emphasis
added.)
Reliance on Vol-Strata Rather Than TimTyp Is Arbitrary & Capricious: We contend that the
Forest Service’s reliance on the court order for abandoning the use of TimTyp in wildlife
Significantly, TimTjp foiled in this objective, but because of how it was constructed through forest
photointerpretation it accidentally is a good indicator of forest structure instead. Therefore, while this statement
applies to Vol-Strata it does not apply to TimTjp.
" The Forest Service has been working on a prospective dataset, but it is untested regarding habitat.
The long-term contracts are no longer in force, and the Forest Service no longer uses the TTRA prop>ortionality
requirement saying it applies only to those contracts.
21
48 • Appendix C
Kuiu Timber Sale FEIS
GSS
20
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
modeling and analysis was unreasonable because the court order did not address those uses and
because TimTyp is in fact useful for those purposes. Although TimTyp was originally intended to
report net timber volume/^ it failed at that purpose but turned out to be a good indicator of forest
structure (Caouette et al. 2000), and has been recognized by wildlife biologists as a good
indicator of old-growth habitat quality. (Sources are numerous.) In fact, the Forest Service itself
has reverted to using TimTyp for evaluating coarse canopy forest (while still rejecting it for other
wildlife analysis purposes), as is evident in the DEIS.
The abandonment of TimTyp would not necessarily have been a problem if the dataset that
replaced it (Vol- Strata) had a strong correlation to habitat quality and was therefore a suitable
replacement. That, however, was not the case. Such being the case, we believe the Forest
Service’s continuing use of Vol-Strata for wildlife modeling and analysis and its refusal to replace
Vol-Strata with TimTyp for those purposes is arbitrary and capricious.
“Canopy Texture Classes” Should Be Used To Augment the TimTyp Dataset
Caouette et al. (2000) tested the theory that canopy texture is an obvious and intuitive forest
attribute that can be recognized and delineated from aerial photos. The test compared
photointerpretation (done by an experienced Tongass photointerpreter) of four forest canopy
“texture classes”^^ against ground-measured forest structure attributes. The test found a
correlation between the texture designations and forest structure. (See Caouette et al. 2000,
pp. 14-15 and Fig. 9.) In its Discussion section the paper concluded that “differences among
texture classes coincide with the long axis of the TPA-QMD^^ data cluster similar to differences
observed among” TimTyp classes.” In fact, superimposing Fig. 6-B (showing TimTyp) and Fig. 9
(showing canopy texture classes), the clusters are very close.
c
Therefore, at the project level a usefiil analytic tool can be created by delineating and digitizing
canopy texture classes on aerial photos of the project area and other larger areas of analytic
interest (e.g. the ecological subsection and WAAs that are relevant to wildlife considerations).
Creating this database for the Kuiu project EIS is vitally important because of know limitations of
the TimTyp and VolStrata datasets that are relied upon heavily in project-level wildlife analysis.
These limitations include large polygon sizes and some inaccuracies. The lirhitations are not a
hindrance for Forest-level planning, but can result in non-disclosure of site-specific habitat
characteristics and impacts that become important in NEPA analysis and planning at the project
level.
TimTjp segmented the forest into "volume classes,” which we call "TimT>p classes” to avoid the significant
confusion that the term "volume" creates. TimTjp shows forest structure, not timber volume.
Vol-Strata is, however, suited to estimating timber inventor volumes.
Caouette et al. (2000) alternately refers to "canopy texture classes" as "canopy texture descriptors.” We use the
fonner term here because it is more intuitive and because it is the only one of the two that is used in the Discussion
section of the paper. In recent EIS comments and appeals we have used the latter equivalent term.
TPA = trees per acre, and QMD = quadratic mean diameter.
' ' Caouette et al. (2000) refers to TimTyp classes as the "timber volmne strata” from 1977 (id., p.lO), and it refers
to what is commonly called Vol-Strata as "revised timber volume strata” from 1997 (id., p.l2). We have
substituted the correct common-usage term in parenthesis.
22
Kuiu Timber Sale FEIS
Appendix C • 49
GSS
21a
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
One way in which such non-disclosure impedes public and decision-maker understanding of the
project is that; (1) timber stands likely to have above good economic value are identified from
aerial photos or visually during visits to the area; (2) such stands are then likely to be included in
the project unit pool, if they are in the suitable timberbase and are reasonably accessible; (3) some
of the stands can be identified only by methods such as those described because the stands’
economic value is not apparent from the Vol-Strata or TimTyp datasets; (4) for these high-value
stands whose physical characteristics not accurately represented in the datasets, other
characteristics relating to habitat quality are also understated by the dataset; (5) unless the related
inaccuracies or poor resolution of the datasets are somehow compensated both regarding
economic considerations and wildlife considerations, the one-side compensation that allows
preferential selection of high economic value stands for logging will result in undisclosed impacts
to wildlife.
NEPA requires disclosure, and at a minimum the compensations that the Forest Service makes for
imperfectness of its forest datasets regarding one resource must be mirrored by compensation for
related shortcomings than concern other forest resources. Otherwise the Forest Service will not
be fully disclosing the known shortcomings in its data and will be making an imbalanced
comparison of alternatives.
More broadly (beyond avoiding an unfair disparity in the comparison of alternatives) the Forest
Service needs to assure that at the project level its datasets accurately describe the environment
and allow an accurate evaluation of impacts.
Delineating canopy texture classes for comparison with and corrections to the forest character
dataset (e.g. TimTyp) is essential to providing the disclosure, full and fair discussion of impacts,
and accuracy of analysis that NEPA requires for this project.
Habitat Capability Modeling Errors Are Significant.
1 . The Kuiu DEIS relied on the DeGayner (1997) deer model, which is based on the Vol-
Strata dataset. As discussed above, that dataset has no direct correlation to forest structure or
habitat quality. We believe this may be especially a problem for the Kuiu project area, which has
had significant wind disturbance. The result of this disturbance may be that the forestland of
interest has a significant area in forest stands that score as High Vol-Strata because of a high
density of relatively small trees that are not of high habitat value. To the extent this is true, the
DeGayner deer model will over-estimate habitat capability and understate the loss of habitat
caused by past and planned logging. |We therefore believe that habitat capability modeling for this
project should be done with the Suring et al. (1992) deer model, which is based on the TimTyp
dataset. Caouette et al. (2000) found that the TimTyp dataset reflects differences in forest
structure. Use of the Suring model instead of the DeGayner model is consistent with the opinions
of wdldlife scientists voiced in Ford (1995), Robertson (1995), and Hanley (1997).
23
50 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
[[ We note but discount that the project’s Wildlife Specialist’s Report says (p.6) that Doerr et al.
(2005) determined that “timber volume strata should be used in place of volume class*** in the
forest-wide model,*** as it seems to more eifectively represent forest types chosen or used
disproportionately little by deer during deep snow conditions ...” We believe this conclusion of
Doerr et al. (2005) is in error and that it results from peculiarities of the study area’s nature and
the effects of past logging there. The observations are related to the well known problem with
habitat models (Kiester & Eckhardt 1994, and the individual reviews therein) that habitat
juxtaposition and accessibility must be taken into account. ]]
We request that fiirther planning on the Kuiu project not proceed further until the Forest Service
is able to replace (through a Forest Plan amendment or by other means) the use of Vol-Strata data
with TimTyp data in wildlife modeling and other analysis. This request includes using the Suring
deer model instead of the DeGayner deer model. If Veg-Mod is later proven superior to TimTyp
for these purposes, another substitution can be made then.
X- The DEIS states (p.3-42) that habitat capability models are intended to be used to rank
planning alternatives, and that they “should not be used to predict animal population numbers at
some future date.” Nonetheless, the DEIS does precisely what it says should not be done, by
projecting deer populations on p.3-83 and stating whether or not the population will satisfy the
State of Alaska’s deer population objective for the WAA.
3. We note further that the deer population numbers estimated in Fig. 3-29 (p.3-83) are
presented with four significant digits of precision (down to the individual deer, actually), which is
far beyond the precision of the deer model that was used. All instances of such false precision
should be sought out in the DEIS and corrected.
4. The DEIS attempts to defuse the issue of using the deer model for the inappropriate
purpose of predicting deer populations by calling the population estimates “phantom deer” (p.3-
43); however, comparing the population estimates (phantom or not) to the State of Alaska’s deer
population objective (as on p.3-83) is a small and unavoidable reach for the reader and the
decisionmaker. Calling the estimates phantom deer does not excuse this inappropriate use of the
deer model.
5. The DEIS engages in incomplete and misleading disclosure and fails to provide the
NEPA-required full and fair discussion when, on p.3-44, it refers the reader to what it calls an “in-
depth discussion of the reliability of habitat capability models” in DeGayner (1992). A
comprehensive list of references should have been provided on the topic, and there should have
been a full and fair discussion of the issue of the reliability of such models. Important references
include, among others: (1) Kiester & Eckhardt (1994); (2) many of the individual peer reviews in
that reference; (3) Person (2001), especially its discussion of the problem with linearity of the deer
model where there is wolf predation; (4) scientist reviews of the deer model submitted to the US
Fish & Wildlife Service in 1997; (5) Person et al. (1997), Attachment 2; and (6) a selection of
^ r That is, TimTjp.
The DeGayner deer model.
24
Kuiu Timber Sale FEIS
Appendix C • 51
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
21c cont
recent EIS conunents and appeals that have raised model reliability issues. (We ask that any such
documents that are not already in the planning record be included.)
r
6. For marten, habitat capability and road density are related. The Suring et al. (1992-b)
marten model documentation includes an appended graph that was intended to be used to correct
the marten model’s results to account for the effects of road density. DEIS Tables 3-14 and 3-15
report marten model results; however, no mention is made in the tables or the accompanying text
GSS whether a road density factor (determined from the graph) was applied. The next EIS needs to
2 1 d apply a road density factor, and needs to state the value that was used.
In addition, the value of the factor should be based on total road density, not the open
road density. Person has noted in a number of his papers about wolves that all roads need to be
considered regarding wolf trapping and hunting, and we believe the same principle applies to
Jharten.
GSS
21e
GSS
21f
7. The DEIS notes (p.3-52) that habitat capability models will “probably” over-estimate
wildhfe populations by about 30 percent. This fact was referenced to Person et al. (1997), and
although that document states (p.4) that “deer habitat capabihty likely overestimates the carrying
capacity for deer,” the DEIS needs to provide clarity on how the planning team determined the
30% figure and how it should be reflected in analysis of impacts to deer.^** We ask the planning
^am, in preparing the next EIS, to consult the Person et al. (1997) authors on how to do this.
r
8. The DEIS states on p.3-52, “these models were designed to make distinctions between
alternative treatments and they do this relatively well.” This is true for comparing action
alternatives that are somewhat similar. However in a place like Kuiu Island (where wolf predation
on deer is a factor) this method of analysis may greatly under-estimate the difference between
alternatives (including especially the No-Action Alternative) that are quite dissimilar (with timber
volumes differing by a factor of three). This is because the deer model assumes a linear
relationship between changes in habitat capability that result from loss of habitat as measured by
^rea, while the relationship is actually non-linear. (Person 2001) (The problem with the model’s
assumption of linearity is discussed elsewhere in our comments.)
9. The DEIS is explicit that “the deer model assumes that an area with an HSI value of 1 .0
could support 100 deer per square mile.” (DEIS p.3-53) Use of this expression of the deer
multiplier is a very serious error that has resulted in deer carrying capacities and populations to be
over-estimated in the DEIS by about 33%. Briefly, that expression of the deer multiplier was
derived in Attachment 2 of Person et al. (1997), and it was designed to apply to best quality
habitat, as portrayed by an HSI of 1.0 in the Suring et al. (1992) deer model. The DeGayner
(1997) model used for the DEIS portrays best quality deer habitat as having an HSI of 1.3, and
therefore the deer multipher specified in the DEIS is incorrect and should have been converted to
Person el al. (1997) says "the actual deer population should be about 70% of K (carrjing capacitj )" (p.33) "to
produce a net recruitment of at least 30%, a condition upon which our criteria for the minimum density of deer is
based (see the detailed comments)." (p.3, with reference to the section with the former quote.) We note that the
multiplicative rather than additive difference between populations at 100% and 70% of K is what is important
here, and that the over-estimate caused by taking the deer model results literally is a factor of about 43% not 30%.
25
52 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
2lg
GSS
21h
GSS
21i
GSS
21j
GSS
21k
another value. See the Greenpeace et al. (2006) appeal of the Scott Peak FEIS/ROD
(incorporated by reference - please add to the planning record), which suggests using a
provisional deer multiplier value for use in the DeGayner (1997) deer model of 75 deer/sq-mile
for that model’s HSI of 1 .0. The appeal also provides a detailed explanation of the error that has
been made. The appeal also asks for an emergency amendment of the Forest Plan to formally
adopt through interagency process an equivalent deer multiplier for the DeGayner model - a
request we hereby repeat.
[[ Regarding this topic we include personal communications with David Person (who derived the
deer multiplier) in Attachment 3 and ask that they be added to the planning record, along We also
ask that Stangl 2005 (which misinterprets the information appended to it) and Person et al. 1997,
which the Forest Service has, be added to the planning record. ]]
10. Tables 3-19, 3-20, and 3-22 (which report deer model results) need columns for the year
2045, when canopy closure will have occurred for past logging and logging from this project. The
loss of higher quality deer habitat by that year is a particular concern because the deer model
predicts habitat capability only for periods with average winters. Severe winters are truly the
greatest concern in general, but especially for a place like Kuiu Island and major islands to its east
that are known to suffer significantly when severe winters occur. Although the deer model makes
no predictions for severe winters, areas of higher quality deer habitat in the project area and its
WAA will be of heightened importance at such times. The EIS must do a substantial analysis of
the cumulative impact of past and future habitat loss on deer, wolves and hunting in periods with
V one severe winter or more. Key to this is the fate of the higher quality habitat.^*
1 1. The statement on p.3-56 that Table 3-22 gives “a general indication of how previous
timber harvests have changed the area’s ability to support deer” is not true. The table shows the
state of habitat capability only through 2005, but many of the logged units in the planning area
were cut in the 1980s, 1990s and 2000 and that do not yet have closed canopies. (See Attachment
4, a map with logging dates for units.)
12. The changes in deer habitat capability shown in Table 3-24 and discussed on p.3-56 are
based on modeling of average winters, and the DEIS should have said so explicitly. The effect
regarding severe winters can be expected to be greater than shown. In addition, the habitat
capabilities in Table 3-24 are overstated by about 33% because an incorrect deer multiplier value
was used (see above), and in addition we note that such use of the deer model is proscribed
throughout the relevant literature. Pages earlier, the DEIS called such numbers “phantom deer,”
but deer scientists have frequently warned against using the model in this way, even with such a
proviso.
V
13. Person (2001) is cited in the DEIS (p.3-52); however, the DEIS fails to disclose a
critically important issue raised in that paper, much less give it the full and fair discussion NEPA
requires. The issue is that where there is wolf predation on deer, the effect of deer habitat loss on
r the deer population is nonlinear, resulting in greater impact than can be predicted by single-
Fig. 3-22 with 2045 data would be useful for this since, although based on an average-winter approach, it shows
acreages b> 12 gradations of habitat qualit) .
26
Kuiu Timber Sale FEIS
Appendix C • 53
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS species DeGayner deer model the project has relied upon.^1 Instead, it is necessary to model the
21 k cont deer/wolf community, using a population equilibrium model. The Forest Service has known about
this problem for about a decade,- and mentions the need for population equilibrium modeling in the
1998 Forest Plan Clarification of the wolf standard and guidelines. Person (2001) has provided an
additional warning and a refined modeling method which could have been adapted to the Kuiu
project. In past years Tongass National Forest annual monitoring reports have referred to work
underway to institute such modeling, but the effort seems to have languished and to have been
assigned a low priority.
We believe that planning and decision making that is based on linear wildlife analysis assumptions
for an ecosystem that functions non-linearly is irresponsible and contrary to law, unless an
adequate factor of safety is applied to account for the real-world situation. Exponential errors
resulting from ignored non-linearity can be very serious, and the possibility of such errors must be
taken into account and be avoided. The NEPA requirements for disclosure, full and fair
discussion, and a hard look (and other requirements) are of heightened importance in this
situation.
14. IN CONCLUSION: The DEIS’ deer modeling and the analyses for deer, wolves and
subsistence are wholly unreliable because they are based on; (1) The wrong dataset; (2) the
wrong deer model; (3) an incorrect deer multiplier; (4) the substantial avoidance of the severe
winter issue; (5) the failure to account for the deer models’ ignorance of habitat juxtaposition and
fragmentation; and (6) the failure to avoid or compensate for the use of a linear model in a non-
linear ecosystem. These shortcomings are of particular importance because the significant amount
of logging and roadbuilding the area has already experienced (see Attachment 3). A Supplemental
DEIS and another round of subsistence hearings and public comment are necessary as a result.
Partial Cutting
1 . The DEIS speculates (p.3-5 1) about possible benefits of partial cutting in the project,
covering topics of mimicking natural wind disturbance, maintaining a diverse understory, and
maintaining deer and moose use.
GSS
22a
Regarding the mimicking of wind disturbance, what was not mentioned is that the area already has
a high acreage of wind-disturbed forest. Adding to this disturbance by mimicking it must be
analyzed. The impact may be less than clearcutting, but it caimot be dismissed simply because it is
like a natural process in some respects. Because this silvicultural system would be used where
windthrow is not a threat (DEIS p. 3-161), the impact will be in addition to the natural process.
Maintaining a diverse understory and maintaining animal use of the unit is only one element of
GSS evaluating partial cutting. What the section does not discuss is the ability_of partially cut forest to
intercept snow, and the effect of the change in that ability on HSI scoresJ
'' The same problem applies to the Suring et al. (1992) model because it too is a single-species model.
The Wildlife Specialist’s Report (p.34) says, "On Kuiu Island 'as much as 30% of the forests may never reach
late-seral stages because of the frequent, catastrophic wind storms’. (Boimann and Kramer 1998).“
27
54 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
22c
GSS
22d
GSS
22e
GSS
22f
GSS
23a
GSS
23b
Deal (2001) was cited but the paper looks at partial cutting in terms of silvicultural forest
structure and not habitat structure. It can be calculated from data in the paper (p. 183) that after
60 years stands in the study had 12% fewer large diameter trees than originally and 10% fewer
medium-large trees. However, this was for an amalgamation of a range of treatments ranging
from 17 to 96% basal area removal. No definite conclusions regarding habitat can be reached
from that either way with regard to this project’s 50% retention in some units, but it seems there
is clearly a potential to degrade the value of habitat in winter, especially over the next several
decades at least.
The silvicultural prescriptions for two-aged management and group selection (pp.3-164 & 165),
even in combination with the unit cards, leave the reader mystified concerning how forest
-..structure would be affect^ The existing and remaining number and sizes of trees cannot be
determined, even in rough terms. In addition, the cut being “approximately 50%” of basal area can
exceed that take by an unknown amount.^'* For single-tree selection page 3-165 provides some
information, but it is apparent that retaining smaller trees can allow the take of many of the large
spruce and mid-sized hemlock. Again, the effect on forest structure cannot be visualized, much
less the effect on winter habitat quality.
Gravina Island TS IDT meeting notes for March 21, 2000 say, “The current deer model does not
recognize any difference between clear cuts and partial cuts. Furthermore, feedback Jim has
received from commenting agency biologists indicates they do not think partial cutting they have
^een so far should be given any credit in the current deer model.” (Attachment 5 of these
comments.) We do not believe that Deal (2001) or the measurements by Doerr and Brainard
(DEIS p.3-51) have any content that challenges that conclusion. Please request comments from
interagency deer experts and provide a full and fair discussion in the next EIS.
2. The next EIS should include photos showing what such stands would look like in the
^orst case for winter habitat quality, from inside and out.
3. The last row of Table 3-18 should be put in a table that shows the range of HSI scores as
in Table 3-22. Table 3-18 looks at all POG below 800’ elevation as one lump, but the relevant
analysis would be to instead show the percentage changes of the various qualities of winter habitat
in that elevation range. A similar table should also be provided for the 800-1500’ elevation range,
which is also important habitat for deer and marten.
Patches, Fragmentation & Corridors
1 . Attachment 6 is a satellite photo of the project area, and we belief gives a better feel for
the degree of fragmentation than the maps in the DEIS. Please provide a clear copy of such a
photo in the next EIS.
2. Fragmentation of the project area and other areas to the south is already quite severe, and
analyses of fragmentation, patches, and interior habitat are conspicuous in their absence in the
The same language is found in text of Appendix-B and on the unit cards themselves.
25?
Kuiu Timber Sale FEIS
Appendix C • 55
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Q32 DEIS. In addition the discussion’of corridors in insufficient. Regarding all of these topics, the
23b cont DEIS should have made efforts like (but improving on) those in the Scott Peak FEIS,^^ and a
Supplemental DEIS is necessary to provide this vital information for the Kuiu project.
GSS
23c
3. We note from the unit cards that for every action alternative, half or more of the units
close gaps between previously logged units. For one alternative this is true for two-thirds of the
units. In some cases a stream buffer is left in the gap; however, reducing the existing corridor to
this width may serve to increase predation. This loss of connectivity must be addressed in the
body of the next EIS. We believe the subject units should be dropped from the unit pool.
4. Some of the unit cards note that habitat will be isolated. This must be discussed in the body
of the EIS and needs to be accounted for in the wildlife models and various EIS tables. We
believe that units that isolate habitat should be dropped from the unit pool.
5. The DEIS says (p.B-5); “Reduction of fragmentation is also an important component of
maintaining deer habitat.” No contemplated actions in the DEIS will reduce fragmentation,
although some of them may cause less fragmentation than others.
GSS ^ DEIS says (p.B-5), “The use of 50 percent retention of the basal area with the
23(j retention of trees of various sizes and an emphasis on snags and dying trees helps mitigate” the
concern for loss of old-growth habitat. This favor one kind of habitat, but if the composition of
the stand is tilted toward snags and unhealthy trees, the structural other kinds of habitat quality of
the stand may be substantially lost in the foreseeable ftiture. This may be mitigation in one sense,
^ut in another sense may not be effective mitigation in the end.
7. The DEIS says (p.B-5), “... differing prescriptions and corridor retentions will mitigate
many of these concerns for the species selected as MIS for this project." The statement is
meaningless because the mitigation prescriptions have not been clearly described in functional
biological terms, and their biological effects have not been discussed in a way that conveys the
overall result.
Subsistence
GSS
24a
GSS
24b
On p.7 the Wildlife Specialist’s Report quotes the Alaska Dept, of Fish & Game as saying of its
subsistence survey that for many villages including Kake “the annual response rates ... are too
low” and that this “reduce(s) our confidence in the ability of the survey to accurately describe
actual deer hunting effort...” This fact needs to be included in the subsistence section of the EIS.
Numbers in Fig. 3-29 are inflated by use of the incorrect deer multiplier.
Unit Cards in the DEIS are Inadequate
^ We do not consider these analyses in the Scott Peak FEIS to be perfect, but recognize them as a great step
forwar d in timber sale analysis on the Tongass NF. See the Greenpeace et al. (2006) appeal of that project for
improvements in these approaches that we believe are necessary-.
29
56 • Appendix C
Kuiu Timber Sale FEIS
GSS
25a
GSS
25b
GSS
25c
GSS
25d
GSS
25e
GSS
25f
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Scoping comments requested that unit cards show who made the unit visit for each resource, and
that the brief notes be included. Unit cards do not contain the former, and the notations provided
are often lacking in sufficient content.
Scoping comments also request that the character of the stand be described, including percent
composition by tree species, and a description of the unit’s structure and habitat. This was
generally not done, and where done is insufficient.
Scoping comments asked that all units be walked by a wildlife biologist. We have no way of
knowing if this was done because unit cards do not provide the information.
The public needs to know which units were visited by a wildlife biologist and the extent of the
survey and its type (e.g., some past unit cards have said “windshield survey”). A few units reflect
information that obviously came fi'om the field (e.g. Unit 412), although the information could
have come from anyone on the planning team rather than a biologist. Most
unit cards do not contain information that clearly establishes that the unit was visited regarding
particular resources, as opposed to information being filled in from an office data source. (This is
not an accusation, just a statement of need for clarity.)
The unit card wildlife sections report in terms of Vol-Strata and HSI rankings that came from the
deer model (which also used Vol-Strata). Field work should instead be recorded in terms of actual
on-the-ground forest structure, expressed in terms of estimated TimTyp or observed
characteristics. Unit cards are unclear as to whether and how much habitat data came from the
\GIS Vol-Strata database and how much came from field assessment.
Units with two prescriptions for one alternative (e g. Alt-3 in Unit 109) do not explain the extent
to which corridors would be blocked or to which higher elevation habitat would be isolated.
None of the unit card maps show prescriptions or yarding settings.
None of the unit cards have notations concerning buffer widths.
Many units fill gaps between existing clearcuts (sometimes with a stream buffer in the gaps).
Several such unit cards do not mention whether the currently remaining forest is a wildlife
corridor. Unit cards should be explicit regarding whether or not such units are in wildlife corridors
or potential wildlife corridors.
On unit cards with low unit numbers, it is explicitly stated when units do not isolate habitat and do
not remove corridors. Higher numbered unit cards are not explicit in this way, and should be
updated with that information.
With near consistency, unit cards misstate medium HSI deer habitat as having an HSI of "4.0 to
5.0." The HSI scale does not go nearly that high, and this error calls into question who filled out
▼ the wildlife sections of the unit cards and how the information was obtained.
30
Kuiu Timber Sale FEIS
Appendix C • 57
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
25f cont
Language regarding fate of corridors is inconsistent, and the meanings of the terms used are not
explained. Language includes that effects on a corridor would be "mitigated" (e.g. Unit 109) or
that the corridor would be "maintained" (e g. Unit 1 12), "reduced" (e g. Unit 109-B) or "retained"
(e g. Unit 417), or that the prescription would "help retain" the corridor (e.g. Unit 414). In some
cases where some such language seems to fit the situation it is absent (e.g. Unit 209 for
Alternatives 2, 3 and 4). Consistent terms should be used to the extent possible, and all terms
should be defined in the unit card appendix.
Language like "harvest would not isolate habitat and corridors" occurs on several cards, and is
ambiguous concerning corridors. It is unlikely that isolation of corridors is what is meant, (e.g.
Unit 209)
Unit card 412 says "area is not an isolated corridor." What does this mean? Is the area being used
as a corridor?
GSS
26a
GSS
26b
GSS
26c
GSS
26d
GSS
26e
Many Information Requests Made During Scoping Were Ignored
^he willingness of the Forest Service to provide documents from the Kuiu Timber Sale Area
planning record has proven unsatisfactory. Our efforts began early and were repeated often, but
what minor fragments of the record that we were able to obtain came very late in the process. As
one example the Wildlife Specialist Report, a key document for our review of the DEIS, was not
made available until the night of Saturday March 1 8, two nights before the comment deadline.
The team leader had claimed that the document was too large to e-mail; however, after obtaining
it from a Forest Service FTP site, we found that this was not true because the document was less
than 2 mb in size. In fact, this was the first document provided on the ftp site despite earlier
requests to post planning record documents there, and it was posted only after we made a firm
request that Saturday for an extension of the comment deadline because important planning
record documents were unavailable.
Scoping comments asked that Vol-Strata not be used for wildlife analysis. The request was not
disclosed and the issue was not fully and fairly discussed in the DEIS.
Scoping comments asked that several documents be included in the planning record and be
considered. Some were included, but the two joint statement letters concerning the Forest Plan
from peer review scientists who participated in Kiester & Eckhardt (1994) are not in the planning
record index. We ask again that they be included - contact us if you cannot find copies.
>-
Scoping comments asked for detailed analysis of fragmentation, habitat patches, and wildlife
corridors. Analysis of such topics is missing or incomplete in the DEIS.
Scoping comments asked that criticisms of wildlife models be thoroughly discussed in the DEIS.
This was not done, nor was the request disclosed.
Micro-management of Project-Level Analysis
31
58 • Appendix C
Kuiu Timber Sale FEIS
GSS
27
GSS
28
GSS
29
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
include in Attachment 7 an e-mail from Tongass Wildlife biologist Steve Fadden regarding
wildlife analysis in another timber project. (Fadden 2005) Although it is specific to another
reject, it has broad implications for timber projects Forest-wide and for this project in particular
ecause the recipient has been assigned to this project. We believe the policy described is in
conflict with the flexibility needed at the project-level to comply with NEPA and is otherwise
improper. Please add the e-mail to the planning record.
The DEIS Confuses the Public and Decision-makers Bv
Manipulating of Scales of Measurement
/^he DEIS seems to do its analysis based on WAA, VCU, and project area depending on what
provides the most positive outlook for the agency. Sometimes it is unclear even what scale of
analysis is being used. For example, in the project summary it is unclear if the road density
provided is for the entire island, the smaller project area, the WAA or something else. The same
confusion exists in the numbers presented for wildlife habitat and subsistence in the summary and
ghout the DEIS. For example the DEIS 3-39 presents information related to loss of POG
It; however it does not explain what scale this analysis is based on.
It is also unclear if the miles of existing roads reported in the DEIS includes road that delineate
the project area boundary. Road densities should be presented at the project level scale and must
include roads delineating the project boundary as well as all temporary or closed roads as these
^ads continue to provide hunters and trappers with access to the project area.
The DEIS Does Not Adequately Analyze Loss of Biodiversity
^s explained above the DEIS provides some basic numbers related to loss of POG habitat;
however it does not explain what scale this analysis is based on. Further, the DEIS claims that
historic information related to how much high volume POG has been harvested to date is not
vailable (DEIS 3-40). We do not see how this is possible as one simply would only need to visit
le previously harvested sites and measures stumps to get an approximation of what the forest
;ructure looked like prior to harvest. Lastly, the DEIS is devoid of an actually hard-look analysis
lO explain what the impacts of the loss of more than 5 1% of coarse canopy old growth to date has
had on the area and how this and other timber projects in the future will cumulatively have on
biodiversity in the project area, on Kuiu Island and across the Tongass.
Emphasis on Ctearcut logging as a Harvest Method
The National Forest Management Act imposes significant restrictions on the use of clearcutting in
the national forests and, in particular, prohibits the Forest Service from selecting a logging
method primarily because it will provide the greatest financial return or output of timber. 16
U.S.C. § 1604(g) (3) (E) (IV); 36 C.F.R. § 219.27(b) (3). The proposed alternative 4 of the Kuiu
project will clearcut 1, 168 of the total 1,425 acres (82%) of all timber to be logged. While a small
portion of the harvest prescriptions are clearcut with reserves, we have found in many cases it
appears that the FS simply extends the "unit boundary" beyond the edge of the planned clear-cut
into surrounding old grovAh, and labels the addition a "reserve". The "reserves" that are often set
32
Kuiu Timber Sale FEIS
Appendix C • 59
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
aside in the "clearcut with reserves" prescription are areas that are "unsuitable" for logging
anj'way due to topographic elements or oversteepened slopes.
GSS
30
Further, given the heavy emphasis on clearcut logging as a harvest method we find it shocking
that the DEIS continually points to “using timber harvest treatments other than traditional
clearcutting” as a way to minimize impacts on wildlife and other resources (DEIS 3-67). For
example, the Wildlife Specialist’s Report in discussing alternative 4, states, “Deer, marten, wolf
and bear are unlikely be adversely affected by this alternative since applied harvest prescriptions
will result in a large number of uneven aged stands which should help maintain a natural forest
mosaic” (Emphasis added). The report goes on to state, “The amount of habitat fragmentation
occurring through the implementation of this alternative will be reduced using uneven-aged
prescriptions.” We do not see how 18% of the managed stands constitutes a “large number” or
how uneven-aged management on 257 acres of a total 1,425 acres can be considered “significant”
and used as the basis to support the agency’s findings in this case.
V
GSS
31
The DEIS fails to Include Heron or Raptor Surveys
Results For This Project as Required
TLMP requires project level inventories be conducted to identify heron rookeries and raptor
nesting habitat using the most recent inventory protocols. (TLMP 4-116) (Emphasis added)
We see no evidence in the DEIS or in the planning records we possess to date that indicate
surveys for herons or raptors (outside the Queen Charlotte goshawk ) have been performed as
required by law for this project. Survey forms and details for goshawks are missing from the
planning record index we were provided upon request, despite the fact that the Agency makes
claim that such surveys were performed. For the USFS to meet the clear standard of TLMP it
must survey for all raptors, including owls. Owls are clearly intended beneficiaries of the S&G as
they specifically are mentioned. Effective owl surveys intent on finding nest sites must be done
between March and late April with the optimal survey time between April 1 & 1 5. Owls that
respond to vocalization calls in late spring or summer, when Goshawk surveys are typically
performed, are non-breeders; hence it will not be possible to locate nests. For this reason surveys
for all raptors cannot be conducted incidental to goshawk surveys. The Forest Service must
conduct project level inventories for herons and all raptors in the project area, as explicitly
^required by TLMP.
The DEIS Fails to Adequately Identify Impacts to Wolf Populations
TLMP requires a 1200’ forested buffer around wolf dens and prevents road construction within
600 feet of dens. (TLMP 4-1 17). It is implicit in the requirement of TLMP to protect wolf dens,
that in order to do so, the dens must first be located. We have seen no records to indicate that
surveys for wolf dens have been completed in the project area, however numerous documents in
the Administrative record lead to a likely assumption that wolves do indeed den within the Kuiu
Project area.
33
60 • Appendix C
Kuiu Timber Sale FEIS
GSS
32a
GSS
32b
GSS
32c
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
The unit card for unit 208 states that a wolf den exists within the unit but that it is inactive. We
request the entire unit be surveyed each year to insure the den is not again in use. Unit 104 also
has documented wolf activity and what may be a den site. Given that the agency is unsure at this
time whether the site is an active denning area, we request this unit be dropped from any fiirther
consideration.
We are also very concerned about the impacts this project will have on deer, which in turn wiU
impact the wolf population, as deer are wolves’ primary prey. Due to a heavy snowfall, the deer
population on Kuiu Island crashed in the 1970’s. The population has increased to a level where
harvest has again been allowed, but remains well below the recommended population to sustain
wolves. Logging and road construction associated with the Kuiu project will decrease suitable
deer habitat in the long-term and increase hunter access. The design of the Kuiu project will also
create leave-strips between clearcut stands. These areas may serve as magnets for deer in heavy
winter snow months, making them easy prey for wolves. The overall result is that the Kuiu
Project will cause increased pressure on an already low deer population.
As the ADF&G noted in their scoping comments on this project, “ If subsequent entries continue
to target the highest value deer winter range, the impacts to deer and wolves may be amplified as
a result of cumulative impacts. Any additional habitat alteration as a result of timber harvest and
road building will further erode the carrying capacity for deer and wolves at both the project and
biogeographic levels”. (ADF&G Scoping Comments, April 2004) These concerns seem to have
^een dismissed in the DEIS with little to no discussion.
Further, we are very concerned about high road densities shown to have a negative impact on
wolf populations in southeast Alaska. This project will further add 19 new miles of road and
reconstruct many others to an already heavily roaded area. Road densities on the northern portion
of Kuiu currently exceed the established guidelines for wolf mortality in the TLMP. The DEIS
reports within the project Area road densities are at 0.78 mile per square mile. We are confused
about this number as the ADF&G in the scoping comments on this project ("April 2004) calculated
the road density for the project area at 1.68 mile per square mile. We are assuming the Forest
Service calculation has excluded all temporary and closed roads as well as the project boundary
roads.
The DEIS seems to be using Dave Person’s work to assume wolf mortality may increase
substantially when open-road density exceeds 0.7 mile of road per square mile. The DEIS finds
because all action alternatives seek to reduce overall road densities below 0.7 miles there is no
problem. However, Person recommends that the Forest Service should calculate road density
based on all roads, not open roads. Closed” roads still allow easy walking or motorized access,
and many water-barred roads don't effectively prevent access by ATVs. Another point the DEIS
is overlooking is that the Wolf conservation assessment is based on a road density value of 0.66
(-0.7) on all land belcfw 1200 feet, because few roads are built above 1,200 feet, and wolves
spend most time below that elevation. With respect to its effects on wolf mortality, road density
should not be tabulated based on all land within the project area, but rather on lands below 1,200
feet in elevation. We request the road density analysis be redone considering these important
\|actors.
34
Kuiu Timber Sale FEIS
Appendix C • 61
GSS
33a
GSS
33b
GSS
34
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
The DEIS Fails to Adequately Identify Impacts to Black Bear Populations
As the Wildlife Specialist’s report for this project notes-black bears are sensitive to human
disturbance. Elizabeth Peacock PhD has been studying the black bear population on Kuiu Island
for some time now. Ms Peacock and others have expressed concern about timber harvest and its
effects on the black bear population on Kuiu Island (Kuiu Wildlife Specialist’s Report Dec. 2005).
The high road density on northern Kuiu Island also gives us great concern for the island’s black
bear population. As ADF&G noted on their scoping comments on this project, “The recent
expansion in the use of road-based transportation by guided and outfitted black bear hunters has
been of great concern to ADF&G wildlife managers charged with ensuring the long-term
sustainability of Kuiu’s black bear populations.”
Despite the clear concern of one of the leading experts on the Kuiu bear population, the ADF&G,
outfitters and guides and many others, the DEIS does little to no analysis of how this project may
impact the black bear population on Kuiu Island instead it makes broad brushed, unsupported
dismissal over such claims. The agency again appears to be relying on the benefits from partial
harvest as adequate to protect this species. Given this is less than 20% of the harvest prescription
in the proposed alternative we find this reasoning indefensible. Further, reliance on fixture road
closures as a way to protect this species is uncertain as best as such closures have not been proven
^ffective elsewhere across the forest.
Lastly, the DEIS does a poor job of explaining how black bear hunters (as well as hunting guides
and outfitters) may be impacted from this project. For example, how will habitat loss, noise fi'om
logging operations, the presence of a logging camp etc impact hunting over the short and long-
term.
The DEIS Fails to Adequately Identify Impacts to Marbled Murrelet Populations
r
TLMP requires a 600-foot circular buffer of undisturbed forest surrounding marbled murrelet
nests. (TLMP 4-1 17). Because the Forest Plan provides specific direction to protect such areas,
it is implicit that to do so one must first survey for nests. Without conducting site-specific project
inventories, it is impossible to locate, and therefore protect habitat for the murrelet as TLMP
intended. The planning record for the Kuiu project does not disclose any attempt by the Forest
Service to locate nests. The agency must conduct specific inventories to locate marbled murrelet
nests in the project area and this information must be made available in an SEIS.
The DEIS Fails to Adequately Disclose Impacts to Marten and Fails to Consider New
Information as Required bv Law.
Marten are native to Kuiu Island. This species is well documented as preferring old growth forests
below 1 500 feet in elevation. The quality and quantity of such habitat is the limiting factor for
winter survival for the marten. Density of roads affects the quality of habitat for marten, and
increases their vulnerability to over harvest. A habitat capability model used to evaluate marten
habitat on the Tongass National Forest predicts declines in marten densities at road densities as
low as 0.2 miles per square mile, and population declines of 90 percent where road densities
62 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
35
approach 0.6 miles per square mile. Many of the watersheds within this project area already
exceed this road density.
The planning record shows a concern expressed by ADF&G biologist Rich Lowell about low
numbers of marten on Kuiu Island (See Kuiu PR 217). However, the DEIS brushes off any
concerns about marten by claiming the TLMP will mitigate any impacts.
further, the Wildlife Specialist’s Report for this project shows clear concerns for low populations
of marten in this area;
From the September 2001 to December 2003, Rod Flynn and Tom
Schumacher, of the Alaska Department of Fish and Game, studied marten
abundance and prey abundance on the old growth reserve system prescribed by
the Forest Plan on eight study sites including Northern Kuiu Island. They
trapped along the road system and found that marten populations were very
low.
is concern is not reflected in the DEIS.
As discussed above the Forest Plan marten model was used to predict marten habitat capability.
This model is not adequate to access impacts to marten as it fails to account for predator
densities, prey density, winter severity, and trapping pressure.
The DEIS also erroneously rely upon the TLMP to protect marten viability and fail to include new
Vcritical information from the scientific literature regarding this specieUlFive years after the TLMP
was adopted it is clear that several assumptions made in designing TLMP in terms of marten
viability are either unsupported or just plain wrong (Robertson et al 2000). (These assumptions
include the following;
> TLMP assumes that openings smaller than 2 acres will have no adverse effect on martens
if openings occupy < 25% of a stand-this has not been tested.
> TLMP’s assumption that leave trees in partially harvested units should be evenly
distributed rather than clumped, while speculative insights suggest that clumping leave
trees may be better for marten habitat
> No evidence exists in regard to the appropriate width of habitat corridors for dispersal
> No literature exists in regard to the rate of population exchange that must occur between
reserves to maintain metapopulation function
> TLMP assumed that large reserves would support 25 adult female martens; however, a
study on Chichagof Island indicated that a large reserve of minimal size (40,000 acres) will
not support this number of martens during years of low prey abundance, and may not
support 25 adult female martens during years of high prey abundance.
> Due to the heterogeneous nature of the forest in southeast Alaska, it has not been possible
to differentiate demographic factors - productivity, survival and population density -
between high volume and medium volume timber strata, nor between uplands and riparian
areas.
Kuiu Timber Sale FEIS
Appendix C • 63
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Further, male marten home ranges have been documented to be as large as 4,718.46 acres w/
median size of 1,358.7 acres. (Flynn 1994) This is 2.7 to 13.59 times larger than the 100-500
acres listed as utilized by the TLMP Marten table (L5). Additionally, it may be inaccurate to
assume that 200-year-oId stands provide sufficient habitat for marten (Alaback 1982a and 1982b,
Schumacher 1 999). Two hundred-year-old stands may lack the large woody structures and
structural complexity near the ground that martens use for denning and resting, and they may lack
undergrowth sufficient to support small mammal populations.
Rather than disclose or analyze any of this information, the DEIS relies on the TLMP as adequate
to protect this species. TLMP mitigation measures included in the project cannot be relied upon
to be effective for the above reasons and because marten viability is guaranteed only by large,
unfragmented areas of high volume old growth that is not easily accessible to legal and illegal
trapping. We specifically request should planning continue on this project that this information be
discussed in the FEIS.
The DEIS Fails to Adequately Analyze The Loss of
Wildlife Corridors and Connectivitv
GSS
36
TLMP S&Gs related to wildlife specifically call for landscape assessment of “old growth
forest habitat within large and medium reserves and other natural [LUDs] and then
determine whether forest connectivity exists among old-growth blocks in large and medium
reserves and natural setting LUDs” (1997 TLMP at 4-12). We could fiind no evidence of such a
review having been performed in the planning record. Among the areas that are especially
important for wildlife travel in this heavily fi'agmented landscape are the existing leave strips
between bands of clearcuts and areas of high value winter range such as Rowan Peak and other
south-facing, low elevation slopes. However, when we look at the alternative maps provided in
the DEIS it is apparent that many of the units slated for harvest wUl remove these in-between cut
areas creating giant “mega-cuts”. These mega-cuts create relatively large areas devoid of old
growth forest The DEIS analysis fails to look at the impacts of these megacuts will have on
wildlife.
Further, the DEIS is relying on connectivity to be provided by riparian areas, mountain passes,
and beach fringe, yet much of the previous harvest, which took place prior to the Tongass Timber
Reform Act, significantly impacted riparian areas, rendering them ineffective as travel corridors.
We are concerned that important wildlife corridors will be lost and connectivity will be severed if
the preferred alternative is implemented. From the DEIS and the planning record it is clear that at
a minimum the following units have evidence of serving as important wildlife corridors: 101, 102,
112, 206, 207, 209a, 209b, 301 401, 404, 405, 408, 414, 415, 418, 503. We request should any
further planning occur on this project these units be dropped from consideration.
The DEIS Fails to Identify Impacts to Small Endemic Mammals
37
64 • Appendix C
Kuiu Timber Sale FEIS
GSS
37
GSS
38
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
The Forest Plan specifically recognizes that the loss of unique species on the island system of the
Tongass is an issue of concern. Under the TLMP, the Forest Service is required to evaluate the
existence of rare or endemic terrestrial mammals that may represent unique populations with
restricted ranges. A number of endemic species have been documented on Kuiu island to date,
yet the DEIS is devoid of any mention of the existence of such species or the impacts of this
project on their long-term survival. In fact the only small mammal the DEIS even mentions is the
red squirrel. However, the document quickly dismisses the need to present any analysis on
impacts to this species by making a blanket unsupported statement that there is no concern with
red squirrel habitat (DEIS 3-43). We find the lack of discussion of endemic mammals quite ironic
given one of the stated purpose and needs behind this project is to “provide for current and future
habitat needs of endemic wildlife species” (DEIS S-2).
^ is our understanding that Natalie Dawson, a graduate student working with small mammal
expert Joseph Cook, is currently studying endemic small mammals on Kuiu Island. We beheve
between Mr. Cook and Ms. Dawson adequate information exists to discuss what small endemic
mammals are present on the island. Please provide this information and analysis of the impacts
fi-om this project and other past and fiiture harvest planned for the northern part of Kuiu Island on
these species.
V
The DEIS Does Not Adequately Address Effectiveness of Road Closures
Though all new roads proposed for this project are slated to be closed, they will connect with the
many miles of existing roads on the island. The DEIS does not address how the Forest Service
will prevent non-motorized access to local resources, enforce motorized access restrictions and
access violations, or how the agency proposes to exclude traffic fi-om roads during the project
operating years
The DEIS fails to discuss the method(s) that will be used to decommission or close the new
temporary roads as well as the reconstructed roads built in association -with this project.
Particularly, how will the agency ensure that they no longer provide motorized human access
when other similar efforts across the forest have failed. We found little to no mention of the use of
off-highway vehicles on the road system on Kuiu or within the project area, yet we understand
this is a popular way for people to access the interior of the island. This is an important
consideration when discussing road closure effectiveness and hunting impacts. Further, the DEIS
fails to discuss use of the roads by foot traffic- a use that is likely to continue some time after the
roads have been closed.
Given that Kuiu Project area already has an extensive road network, we seriously question how
the Forest Service can meet TLMP’s goals and objectives by building new roads. The DEIS fails
to clearly identify the adverse long-term effects of retaining roads at the project’s close, and how
likely existing and proposed roads are to be maintained to protect water quality and aquatic
resources in and around the project area. The bulk of the DEIS’ road management section
contains generalized information about the road classification system and Forest-wide access
management goals. When roads and stream crossings are discussed in other sections (such as
V Fisheries Resources), the information is quantitative and summary in nature, without providing
38
Kuiu Timber Sale FEIS
Appendix C • 65
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
GSS
38 cont.
GSS
39
GSS
40
GSS
41
GSS
42
any specific information about the potential impacts on the human environment. The Forest
Service must provide detailed analysis of the impacts of roads on the human environment.
Discussion of Management Indicator Species is Grossly Inadequate
Management Indicator Species (MIS) are vertebrate or invertebrate species whose population
changes are believed to indicate some effects of land management activities. MIS species are
selected because their population changes are believed to indicate the effects of management
activities (36 CFR 219.9 (a)(l)).-The discussion ofMIS is the Kuiu DEIS is grossly inadequate.
No mentions of the Vancouver Canada goose or the Red-breasted sapsucker are made at all.
Further, the Red squirrel. River otter. Bald eagle. Hairy woodpecker and Brown creeper are
blatantly dismissed because of TLMP protections, difficulty in monitoring and the potential that
these species may be dropped as MIS in the future. This misses the intent of selecting these
species as MIS in the first place and tails to meet the “hard look” standard required by the
Rational Environmental Policy Act.
The DEIS Contains Inadequate Information on Sensitive Plants
It appears that sensitive plants surveys were focused only on the timber units- not the temporary
and reconstructed roads. Further only 24 units were surveyed- a small percentage of the total unit
pool. We suggest further sensitive plant studies be performed in all units and along all proposed
roads.
The DEIS Fail to Adequately Analyze Inapacts of Logging
in a Recreation River LUD
c
We strongly object to inclusion of 1,246 acres of recreational river LUD within the project area
and specifically to the timber harvest and road construction within the Kadake River Corridor.
This area was set aside in the TLMP to maintain its eligibility status for Wild and Scenic River
designation. We strongly believe timber harvest in this area is inconsistent with the goal of
preserving the Wild and Scenic River eligibility, as well as being mconsistent with recreational
uses and the visual quality objectives for this area.
Information on Small Old Growth Reserves Is Inconsistent
r
We are confiised about an inconsistency related to the small old growth for VCU 398. The
numbers presented in table 3-7 of the DEIS (pg 3-30) do not match numbers presented for this
same VCU in the old growth reserve review in the planning record dated 12/ 20/2005 (P.R. 001).
In particular deer and marten habitat numbers do not match nor do the volume strata and acres at
various elevations. Please explain this inconsistency. Further, we urge should this project move
forward that the biologically preferred interagency old growth reserve be selected. We would like
to point out the recently completed Kuiu Island Landscape Assessment specifically recommended
that interagency changes to old growth habitat reserves be implemented.
39
66 • Appendix C
Kuiu Timber Sale FEIS
GSS
43a
GSS
43b
GSS
43c
GSS
44a
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
The DEIS Fails to Adequately Analyze Impacts to Watersheds
We are very disturbed to see the Kuiu Project seeking to enter watersheds which have had
significant past harvest and road construction. This high level of timber harvest has caused
significant fragmentation of old growth habitat in a relatively short period of time. Two
watersheds within the project area have a 20% or greater cumulative harvest level over the past
30 years and one watershed. Dean Creek, has a 3 1% harvest to date. According to the DEIS
these areas have “a high potential for changes in stream channel condition if sediment load
increase[s]” (DEIS 3-113).
r
TEMP recommends “[a] more intensive, complex, and field-based watershed analysis” for
watersheds with 20% or more of the acres clearcut within in the past 30 years. TEMP also directs
planners to use the basic framework for watershed analysis contained in the “Ecosystem Analysis
at the Watershed Scale: Federal Guide for Watershed Analysis” (August 1995). The Watershed
Assessment Resource Report prepared by Kuiu DEIS, however, falls short of these TEMP
requirements. The report merely contains generalized information and unverified data. This is
inadequate to comply with TEMP or NEPA. See 40 CFR 1502.24. The cursory analysis in the
report fail to address fully the core topics for analysis contained in the Federal Guide, including
erosion processes and wind disturbance regimes, watershed hydrology, stream channel
(^morphology and water quality.
^The sediment risk index (SRI) for the Kadake Creek, Rowan Creek and WS #109-44-10370 are
ranked as “very high”. Two additional watersheds, Saginaw Creek and Security Creek, have
“high” SRI rankings. Despite the Rowan Creek watershed ranking with a “very high” SRI no
detailed field based assessment of stream channel conditions were done for this Creek (DEIS 3-
122). The Agency claims that is because this watershed falls under the 20% cumulative harvest
levels. Given the high risk of modifications to this watershed, we request that a detailed field
^assessment for this watershed be conducted.
Eastly, given the significant habitat modification within several of the watersheds in the Kuiu
project area and the high risk of increased sediment loads from this project we find the brief
cumulative impact analysis presented on this topic grossly inadequate.
The DEIS Fails to Take A Hard Look At Cumulative Impacts
r
Nowhere in the DEIS does the Forest Service take a hard look at the effects from past logging to
forest resources on Kuiu Island and the users of those resources. Given the extent of logging and
road building throughout the northern portion of the island, the Kuiu Project must also be
evaluated in its impacts to regional habitat contiguity, availability of subsistence resources, forest-
wide species diversity, and other large-scale concerns. Without such an analysis, the DEIS
(^violates NEPA.
The DEIS sections on cumulative impacts are mostly cursory in nature, stating that TEMP
standards and guidelines, monitoring and mitigation will redress cumulative impacts.
40
Kuiu Timber Sale FEIS
Appendix C • 67
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Alternatively, some sections contend that not enough information is known to evaluate cumulative
effects.
'^Lastly, the Forest Service has plans for the Bayport timber sale also within the same VCUs as the
Kuiu Project Area in the near future. Due to the large overlap of these timber sales, we are
confused as to why they have not been viewed as a single action. In fact the DEIS seems to
GSS dismiss this project as outside the Kuiu Project area. This is counter to the recent timber planning
44^3 schedule released by the agency which shows the Bayport project in VCUs 398, 399, 400 among
others. Please explain why these two projects are not being considered as a single action. Lastly,
the recently completed Kuiu Landscape Assessment also mentions the Alecks Timber Sale. We
saw no discussion of this project in the cumulative impacts section.
Conclusion:
r
For the aforementioned reasons we strongly urge the no further planning occur on the Kuiu
project. Should such planning move forward we urge the following units that have been identified
GSS as high resource risks and/ or as having importance for wildlife corridors or connectivity value (as
45 identified in the DEIS and planning record) be removed from any further consideration: 101, 102,
106, 109b, 110, 112, 206, 207, 208, 209a, 209b, 211, 212, 301, 401, 404, 405, 408, 410, 412,
^413, 414, 418, 415, 418, 419 and 503.
Thank you for the opportunity to comment on this project.
Sincerely,
Corrie Bosman
Sitka Conservation Society
Box 6533
Sitka, AK 99835
(907) 747-7509
Larry Edwards
Greenpeace
Box 6484
Sitka, Ak 99835
Mark Rorick
Juneau Group of the Sierra Club
1055 Mendenhall Pen. Rd.
Juneau AK 99801
Deborah Perkins
The Wilderness Society
430 West 7 th Ave., Ste 210
Anchorage, Ak 9950 1
Niel Lawrence
Natural Resources Defense Council
3723 Holiday Drive
Olympia, Washington 98501
41
68 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
REFERENCES
Alaback, P. 1982. Dynamics of understory biomass in Sitka spruce-western hemlock forest of
Southeast Alaska. Ecology 63:1932-1948.
Caouette, J.; Kramer, M.; & Nowacki, G (2000). Deconstructing the Timber Volume Paradigm in
Management of the Tongass National Forest. PNW-GTR-482.
Caouette, J; and E. DeGayner 2005. Predictive mapping for tree sizes & densities in southeast
Alaska. Landscape & Urban Planning 72 (2005) pp. 49-63.
Deal and Tappeiner 2002. The effects of partial cutting on stand structure and growth of western
hemlock - Sitka spruce stands in Southeast Alaska. Forest Ecology & Management 159
(2002) 173-186.
DeGayner, E; 1992. The role and reliability of habitat capability models. USDA Forest Service,
Juneau, Ak.
DeGayner, E; 1997. No comprehensive documentation exists. Citation is made to document the
originator of the Forest Service’s current deer model, adopted with the 1997 Forest Plan
revision.
Fadden, S. 2005. E-mail message to Scott Peak project biologist Jim Brainard, subject:
"Discussion regarding Scott Peak deer model." August 26, 2005
Farmer, C; D. Person; & R_T. Bowyer (in-press). Risk Factors & Mortality of Black-tailed Deer
In A Managed Forest Landscape. Jml Wild. Mngmt.
Flynn, R. and M. Ben-David. 2004. Abundance, prey availability and diets of American martens:
Implications for the design of old-growth reserves in southeast Alaska. Alaska
Department of Fish and Game, USFW Service Grant Final Report.
Ford, C. 1995. Notes of the November 7, 1995 deer panel convened as part of the TLMP
revision, by the official scribe for the panel session.
Hanley, T.; 1997. Peer review of the DeGayner (1997) deer model, conveyed to the US Fish &
Wildlife Service (Nevin Holmberg), Juneau, in the form of a memo. February 12, 1997.
Kiester, A and C. Eckhardt; 1994. Review of wildlife management & conservation biology on the
Tongass NF: a synthesis with recommendations. USDA Forest Service, PNW Research
Station, Corvallis.
MacDonald SO, Cook JA (1996) The land mammal fauna of Southeast Alaska. Canadian Field-
Naturalist, 110, 571-598.
Person, D. & Bowyer, R.T. (1997). Population Viability Analysis of Wolves on Prince of Wales
and Kosciusko Islands, Alaska. Final report to the U. S . Fish and Wildlife Service.
Person, D; 2001. Alexander Archipelago wolves: ecology & population viability in a disturbed
insular landscape. Ph.D. thesis, U of Alaska, Fairbanks. 174 pp.
Person, D; Kirchhoff, M; Van Ballenberghe, V; and Bowyer, R.T. (1997). Letter to TLMP Team
Leader Beth Pendleton. Sept. 19, 1997.
Robertson 1995 a & b. Notes and summary of the March 27, 1997 Forest Plan wolf panel, by the
official scribe.
Schumacker, T. 1999. A multi-scale analysis of habitat selection at dens and resting sites of
American martens in Southeast Alaska. MS. Thesis. University of Wyoming, Laramie,
WY.
Stangl, J; 2005. Notes of a June 30, 2005 conference call of Tongass wildlife biologists, including
attachments.
42
Kuiu Timber Sale FEIS
Appendix C • 69
Comment Letter #6 - Greenpeace, Sitka Conservation Society, Juneau
Group of the Sierra Club, The Wilderness Society, and the Natural
Resources Defense Council -GSS
Suring, L; DeGayner, E; Flynn, R; Kirchhoff, M; Schoen, J; & Shea, L, (April 1992). Habitat
Capabilit>' Model For Sitka Black-Tailed Deer In Southeast Alaska: Winter Habitat,
Version 6.5, April 1992.
The Wildlife Society et al. v. Barton & Alaska Forest Association (1994). An unpublished Order
signed April 11, 1994, in case J93-00010-CIV-(HRH).
43
70 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
GSS - 1a and 1b
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
Forest plans are programmatic documents that guide future projects. The decisions to be
made in a forest plan involve whether and how to change existing management direction.
The status quo for a forest plan decision is the pre-existing management direction, not a
complete cessation of all management activities. It would be counterproductive to
sustainable management if all activities were shut down during the periodic amendments
and revisions of forest plans.
In NFMA, Congress directed that forest management continue under existing plans while
the first NFMA forest plans were being developed [16 U.S.C. 1604(c)]. Likewise, under
NEPA, the Council on Environmental Quality has recognized that the “no action”
alternative for forest plans is the current management direction, not a halt of all activities
[CEQ’s “40 Questions” #3]. Even if the Kuiu project is completed, the Project Area is
still eligible to be designated as any of the land use designations, as harvested lands are
included in reserve land use allocations.
GSS -1c
The entire Tongass was evaluated and reviewed for possible Wilderness recommendation
in the 2003 TEMP SEIS. All Tongass National Forest lands were assessed to determine if
they were suitable for wilderness consideration based on the Wilderness Act and
procedures in the Forest Service’s forest planning directives. Appendix C (TEMP SEIS
Volumes II and III) includes documentation of the analysis and evaluation for each
inventoried roadless area, and describes the relative contribution each roadless area
would make to the National Wilderness Preservation System. The SEIS documents the
results of a very intensive additional roadless area evaluation for the Tongass conducted
in 2002 and 2003. This included updated mapping and evaluation of all unroaded lands,
which led to the 109 inventoried roadless areas analyzed in the Final SEIS. The Kuiu
roadless areas were evaluated and not recommended for Wilderness.
The current revised Eorest Plan allows for the activities in Kuiu to take place. Delaying
planning and analysis regarding road building and timber harvest, even for a short time
period, have a significant effect on the amount of timber available for sale in the next
year, due to the time needed for sale preparation, appraisal and advertisement, and to
provide for the time period when sale areas are typically inaccessible (winter months).
Kuiu Timber Sale FEIS
Appendix C • 71
Response to GSS
The settlement agreement for Natural Resources Defense Council v. U.S. Forest Service,
Case No. 1: 03-cv-0029-JKS signed by both parties in April 2007, has been approved by
the District Court on May 23, 2007. As part of this settlement agreement, the Forest
Service will not sign new RODs or other decision documents for timber sales in
Inventoried Roadless Areas or on Kuiu Island. For purposes of this agreement, the Forest
Service will not take this and other actions described below until 30 days after
publication of the notice of availability of the FEIS for the Tongass Forest Plan
amendment in the Federal Register, unless the Forest Service designates a later effective
date for the new plan, in which case the Forest Service will not take these actions until
the effective date designated by the Forest Service.
GSS - 2
The EPA has rated the DEIS for Kuiu Timber Sale as Environmental Concerns- EC-1
consistent with EPA’s rating system (see the EPA letter earlier in this Appendix).
Turbidity monitoring, as described in the 2004 Annual Monitoring and Evaluation
Report, included consultation with the Alaska Department of Environmental
Conservation according to the memorandum of agreement between the agencies. The
preliminary data and analysis, coupled with observations of appropriate BMP
implementation on site, provide assurance of compliance with Alaska Water Quality
Standards for turbidity. There were no violations of state water quality standards for
turbidity issued by the State.
The Eorest Plan Monitoring and Evaluation Plan does not require the collection of
sediment data. The Forest Plan Monitoring and Evaluation Plan, and the Kuiu DEIS (see
p. 2-22 to 23) emphasize monitoring to ensure that 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. No
violations of the water quality standards for sediment are expected to occur as a result of
the Kuiu Timber Sale project.
GSS - 3a
The Forest Plan (p. 4-96) says to use cleareutting 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, cleareutting, in the Timber Production LUD is a way to
increase the commercial timber productivity of the site. As stated in the DEIS, (p.1-6)
the Timber Production LUD is managed for the production of saw timber and other wood
products. Pages 3-160 and 3-161 of the DEIS describe the reasons for using even-aged
management.
These lands are in a Timber Produetion LUD and an objective of this LUD is to increase
the commercial timber productivity. It is for this reason that the removal of stands with
dwarf mistletoe and wood decay fungi through even-aged management, to improve forest
health and commercial productivity, is a valid consideration.
72 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
GSS - 3b
Refer to GSS-3a for the objectives of Timber Production LUDs. The differences between
clearcut logging and windthrow openings is discussed in the DEIS (p. 3-25).
GSS - 3c
The reasons to clearcut are explained in the Timber and Vegetation Resources section in
Chapter 3 of the FEIS, in the above responses and in the Timber and Vegetation resource
report.
GSS - 4a - 4e
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
GSS - 5a
The DEIS findings (p. 3-95) for the potential foreseeable effects from the action
alternatives in the Kuiu Timber Sale Area are not expected to result in a significant
restriction of subsistence uses. The Forest Plan Record of Decision (p. 36) concluded that
the potential cumulative effects of implementation of the Plan could lead to a significant
possibility of a significant restriction to subsistence use of deer in some areas at some
time in the future due to the potential effects of projects on the abundance and
distribution of these resources, and on competition for these resources. The competition
was based on an 18 percent increase in community population growth for each of the first
two decades and a 15 percent increase for each of the next three decades (FEIS Part 2, p.
3-528 and DEIS p. 3-96). An 18% population growth has not occurred, yet.
See reply GSS - 4a - e for a response about the market demand calculations and TTRA
directions.
The Forest Plan identifies all areas as open for subsistence uses and it would be difficult
to identify an area that is “less sensitive to logging.” Logging creates environmental
effects to resources; while logging in a specific area may reduce effects for one resource
it may increase effects to another resource. Examples follow:
When logging is planned on another island it may not affect Kake subsistence hunters but
it would affect other subsistence users.
When logging is planned in an area that has no prior logging many of the effects are
diluted over the area and cumulative effects would be small, but this approach is not
embraced by the general public because of the costs of road building and the potential
fragmentation of old-growth patches.
When logging occurs in an area that is already logged, such as the Kuiu Timber Sale area,
the cumulative effects are compounded by past actions, fragmented forests are further
fragmented, old-growth patches are further reduced in size, and wildlife travel corridors
may be reduced or removed. However, analysis of the subsistence resources does not
show a significant possibility of a significant restriction of subsistence resources, now or
in the future.
GSS - 5b
See reply GSS - 4a-e and 5a
Kuiu Timber Sale FEIS
Appendix C • 73
Response to GSS
GSS - 5c
The DEIS findings (p. 3-95) for the potential foreseeable effects from the action
alternatives in the Kuiu Timber Sale Area are not expected to result in a significant
possibility of a significant restriction of subsistence uses. See reply GSS - 5a.
GSS -6
See reply GSS-7, GSS-9a and GSS- 1 1 .
No “pre-roading” has been done for the Kuiu Timber Sale. Maintenance and
reconditioning of existing National Forest System (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 from documentation in an FIS or an FA unless scoping
indicates extraordinary circumstances (FSH 1909.15, 31.12, #4). The maintenance and
reconditioning of NFS roads on 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, recondition roads to comply with best management
practices, maintain the existing infrastructure for the proposed timber sale or 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. See GSS-9a for further discussion.
GSS-7
NEPA requires the disclosure of effects on the human environment, not the
administrative costs of managing timber sale projects. Unlike socio-economic impacts
considered in the Kuiu FEIS, administrative costs do not have impacts on the larger
public the way the jobs created by timber sales do. Administrative costs play no part in
the economic justification of the project. They are administrative costs, not economic
benefits of the project.
Even though NEPA does not require it, the administrative costs associated with
implementing the Kuiu Timber Sale Area project are addressed. The Kuiu Timber Sale
Area DEIS uses the average costs across the Alaska Region for administering timber
sales (DEIS, pp. 3-107 - 3-108). These costs are based on calculations outlined in the
Declaration of Forrest Cole (Decision Document #838). The Forest Service must use
estimates of costs and revenues for timber sales in project NEPA documents as the actual
costs and revenues will not be finally determined until the sales are sold.
GSS - 8a
The costs displayed in the comments include total expenditures by the Forest Service in
various categories, derived from tables of expenditures by budget line item (BLI) from
Tongass National Forest monitoring reports, 1998-2003. Although total expenditures by
BLI include on-the-ground costs of timber sale planning, sale preparation, engineering
support, and sale administration, timber sale costs to the Forest Service constitute only a
portion of the various BLI totals. The expenditures in a BLI are the expenditures for the
74 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
entire National Forest in a given category in a given year, and cannot be attributed to
specific projects. As outlined in the Declaration of Forrest Cole lodged with the District
Court in NRDC v. Forest Service, (Case No. J04-010CV (JKS) Decision Document
#838), the timber sale process is a multiple year process and there is no expectation that
expenditures and actual harvest will occur in the same year.
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, trail improvements, and fire protection
programs.
The Forest Service is directed to sell commercial timber sales at not less than appraised
rates. The Alaska Region implements this direction by established appraisal
methodologies. Forest Service administrative costs play no part in the calculation of
appraised value.
NEPA requires the disclosure of effects on the human environment, not the
administrative costs of managing timber sale projects. Unlike socio-economic impacts
considered in the Kuiu FEIS, administrative costs do not have impacts on the larger
public the way the jobs created by timber sales do. Administrative costs play no part in
the economic justification of the project. They are administrative costs, not economic
benefits of the project.
Even though NEPA does not require it, the administrative costs associated with
implementing the Kuiu Timber Sale Area project are displayed. The Kuiu Timber Sale
Area DEIS uses the average costs across the Alaska Region for administering timber
sales (DEIS, pp. 3-107 - 3-108). These costs are based on calculations outlined in the
Declaration of Eorrest Cole (Decision Document #838). The Eorest Service must use
estimates of costs and revenues for timber sales in project NEPA documents as the actual
costs and revenues will not be finally determined until the sales are sold.
GSS - 8b
See reply GSS - 4a-e
GSS - 9a
The Eorest Service receives annual road maintenance monies to be used for maintenance
of the road systems for the present and perceived problem areas of the road system.
Petersburg Ranger District is composed of several island road systems and the annual
maintenance monies are generally divided between these island systems. As with Kuiu
Island road system, the maintenance monies were allocated toward the mainline roads
that receive the most usage. Forest Roads 6402, 6448, 6404, and 6415 are maintenance
level 2 and 3 roads as delineated in the Tongass National Forest Forest-Level Roads
Analysis Table D1 and the Kuiu Landscape Assessment Appendix A Tables E and F. It
is the Forest Service’s responsibility to keep roads open for public use, maintained for
Kuiu Timber Sale FEIS
Appendix C • 75
Response to GSS
safety of the publie and the resourees, and address the concern (in items GSS- 14 and
GSS-39) to maintain existing roads to avoid long-term adverse effects.
Originally built for management of the timber resource, many of these roads are used for
recreation, sport hunting, and subsistence use. The maintenance on these roads would
have occurred whether or not timber harvest was planned for this Project Area.
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 on 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.
GSS - 9b
The costs of roads are disclosed in the Transportation section of Chapter 3 and included
in the financial efficiency analysis. As stated, small sales may be offered if there is
interest. Sale size will be determined during implementation.
See response GSS-9a.
GSS -10a
Given the impact that litigation, injunctions and other factors have had on the ability of
the timber industry to purchase and harvest timber during that period, plus the volatile
nature of the markets, it is not unreasonable to expect fewer bidders in years when
demand is low, and more bidders in years when demand is higher.
GSS -10b
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 EEIS, the Kuiu project was analyzed using the Residual Value
Appraisal (RV) version of NEAT, which is the current Eorest Service Handbook
direction. The RV system for appraising timber sales is an accepted Forest Service
method for determining fair market values for products. RV relies on collecting selling
values and costs directly from the purchasers of National Forest Service timber sales and
aggregating those values and production costs annually.
76 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
GSS-10C
The sawmill in Wrangell is currently operating and is the sawmill nearest to the Project
Area. Forest Service handbook direction is to appraise proposed timber sale projects to
the sawmill nearest the timber sale.
GSS -11
The analysis of jobs and income in the FEIS has been updated to reflect the changes in
policy and where logs are being processed. These changes have been necessitated by
several factors including current market conditions and manufacturing costs in Alaska
that make it difficult for the Tongass National Forest to offer economic timber sales.
Economic sales are critical to supply the local processors who depend on a steady supply
of timber from the Tongass to remain in operation.
On March 14, 2007, the Regional Forester approved a policy to allow limited interstate
shipping of unprocessed Sitka spruce and western hemlock logs, and for future timber
sale appraisals to reflect this allowance. This approval authorizes shipment to the lower
48 States of unprocessed Sitka Spruce and western hemlock sawlogs that are: a) smaller
than 15 inches in diameter at the small end of a 40-foot log, or b) grade 3 or grade 4 logs
of any diameter. Shipments will be 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, unless expressly granted an exception in advance based on case-
specific unusual circumstances.
The number of jobs and income that may be generated by the project could be affected by
the interstate shipping policy, and the potential changes as a result of the policy are now
incorporated into the FEIS (see the Timber Economics section in Chapter 3).
See http://www.fs.fed.us/rlO/ro/policv-reports/for mgmt/ for volumes exported from
1999-2005.
GSS -12
Table 3-2 in the DEIS shows that 134 acres of the Security IRA are within the planning
area, and that those acres would not be directly affected by the proposed activities. The
DEIS states (p. 3-9) that no activities are proposed within this Inventoried Roadless Area.
The FEIS shows both direct and indirect effects to the North Kuiu Inventoried Roadless
Area (as defined in the 2003 SEIS). Alternative 4 would have the greatest effect on this
roadless area. Approximately 207 acres would be directly affected by road building and
timber harvest. Indirectly, including the affects to the zone of influence, about 55 1 acres
would be affected. This zone of influence is described in the table footnotes which state
that the total area affected includes a 600-foot buffer around proposed timber harvest
units and a 1 ,200-foot buffer along proposed temporary roads within the Inventoried
Roadless Area.
As stated in GSS - lb the Forest Plan amendment will not address new Wilderness
recommendations. The North Kuiu Roadless Area would still be eligible for Wilderness
consideration in the next round of forest planning and for designation as a non-
development LUD in the current Forest Plan amendment.
Kuiu Timber Sale FEIS
Appendix C • 77
Response to GSS
The DEIS did not analyze the potential impacts to the wilderness characteristics of the
Security IRA because it stated there would not be any harvest within that Roadless Area
(DEIS p. 3-9). (This decision was made in the 2003 SEIS).
Eor the North Kuiu IRA, the opportunity for solitude and serenity, scenic, fisheries,
vegetation, recreation, biological, cultural, and research values, and current uses for the
North Kuiu IRA were discussed in the DEIS (pp. 3-9 to 3-12). These were used as units
of measure to compare effects between alternatives (DEIS p.1-18). These are the same
factors used in the 2003 SEIS. The DEIS compared the expected changes from the
alternatives against the existing conditions. The SEIS found no known significant or
unique features or values, opportunity for solitude low, opportunity of primitive
recreation moderate, overall integrity not pristine, vegetation typical of Southeast Alaska,
known cultural resource sites, and no recreation places within the North Kuiu IRA. Since
the proposed alternatives would remove acres but would not change the above values, the
effects to the overall Roadless Area were considered minimal.
The settlement agreement for Natural Resources Defense Council v. U.S. Forest Service,
Case No.l :03-cv-0029-JKS signed by both parties in April 2007 has been approved by
the District Court on May 23, 2007. As part of this settlement agreement, the Forest
Service will not sign new RODs or other decision documents for timber sales in
Inventoried Roadless Areas or on Kuiu Island. For purposes of this agreement, the Forest
Service will not take this and other actions described below until 30 days after
publication of the notice of availability of the FEIS for the Tongass Forest Plan
amendment in the Federal Register, unless the Forest Service designates a later effective
date for the new plan, in which case the Forest Service will not take these actions until
the effective date designated by the Forest Service.
The North Kuiu IRA is not the only roadless area left on north Kuiu. Figure 3-1 in the
DEIS shows Security, Keku, and Camden IRAs and Table 3-1 (p. 3-8) in the DEIS shows
that North Kuiu IRA is the smallest of these Roadless Areas. All these IRAs provide
values associated with Roadless Areas. In addition, the Forest Plan designated
approximately 73% of the Security IRA into non-development land use classifications.
GSS -13a
The North Kuiu Roadless IRA would still exceed 9,000 acres in all action alternatives
and would not be committed to a developed status or eliminated from options for
consideration as a non-development LUD (DEIS Ch 3 p. 3-21)(see item GSS- lb). None
of the alternatives would change the current condition of the Security IRA (FEIS Chapter
3, Issue 1: Roadless Areas Section.) This project will be consistent with the Forest Plan.
GSS -13b
See response GSS- la
GSS -14
Road maintenance is an ongoing process. See GSS-9b.
78 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
The purpose and need of the Kuiu Timber Sale DEIS is discussed on pp. 1-2 and 1-3.
Road maintenance and reducing the density of roads used during harvest activities is not
part of the purpose and need. Alternative A, the No- Action Alternative, responds to the
request for no new road construction, road reconditioning, or timber harvest.
The ongoing Tongass ATM process responds to road maintenance and road density
objectives on Kuiu Island. The Petersburg Ranger District ATM analysis will look at all
road systems on the District. The ATM decision will include RMOs and any further road
closures. As stated earlier in GSS-9a, road maintenance on Kuiu Island is completed
through annual road maintenance monies. The Kuiu Landscape Assessment also lists
recommendations for road management (Appendix A Tables E, F, and G) including 87.8
miles of roads on Kuiu Island recommended for management as closed to vehicle traffic.
The proposed road closures in the Kuiu Timber Sale FEIS respond to the opportunity to
accomplish some of the recommended road closures during the timber sale.
GSS - 15a
There are many ways to display the effects of harvest on productive old-growth (POG)
forests. Table 2-2 on page 2-17 of the DEIS displays a summary comparison of
alternatives and is not all-inclusive. A more detailed table of the effects within the Project
Area can be found in Table 3-1 1 (p. 3-39) of the DEIS, including the percent changes in
POG.
The Forest Plan FEIS (Part 1, p. 3-387) analyzes the predicted amount of POG remaining
within the WAA at the end of the rotation (2095) rather than the amount of POG
removed. In order to compare current levels with Forest Plan predictions (DEIS p. 3-72,)
the acres of POG remaining within both the WAA and the planning area in the tables are
shown, however, the percent acres of POG removed within the planning area are
discussed in further detail on page 3-40.
GSS -15b
The acres of coarse canopy forest are displayed in Table 3-12 (page 3-41) in the DEIS.
Coarse canopy is also discussed in Chapter 2 of the FEIS.
GSS - 15c
There was no discussion on pages 3-18 and 19 related to low-elevation POG, however.
Table 3-18 on page 3-52 of the DEIS will be clarified with the remaining acres of POG
below 800 feet and the total percent of harvest planned within this habitat. The historic
acres of POG below 800 feet in elevation will be displayed.
GSS-15d
The Forest Plan FEIS (Part 1, p. 3-373) analyzes effects to deer by the predicted amount
of deer habitat that would remain within the WAA at the end of the rotation rather than
the amount of deer habitat removed. In order to compare current levels with Forest Plan
predictions, the acres of deer habitat remaining in the WAA are shown.
GSS-15e
The effects to deer habitat carrying capacity are displayed by alternative (Table 3-21 p. 3-
54 for the WAA and in Table 3-24 p. 3-57) in the DEIS. The summary of the effects of
Kuiu Timber Sale FEIS
Appendix C • 79
Response to GSS
the alternatives for subsistence use is the statement at the bottom of Table 2-2 in the
DEIS.
The correct multiplier is 100 deer/sq-mile for an HSl of 1.0 as noted in the Tongass
National Forest Annual Monitoring & Evaluation Report for Fiscal Year 2000 p. 2-155
and the Emerald Bay Appeal No. 06-10-00-0002 Southeast Alaska Conservation Council,
et. al.
In 1996, an interagency group of biologists met to review and discuss the deer model in
use at the time. One recommendation from the group was that HSI scores be modified,
and subsequently deer model scores were adjusted (from a range of 0 to 1.0) to a range of
0 to 1.3, with the highest score (as in the previous model) assigned to south-facing, low
elevation, low snow level, high-volume old-growth stands. This information is
documented in the Tongass Plan FEIS Part 1 (pages 3-367 and 3-368). The carrying
capacity (deer/square mile) multiplier that equates to an HSI score of 1.0 has been
adjusted several times. Based on information supplied by research, the latest adjustment
equates 100 deer/square mile with an HSI score of 1.0 (TNF 2000 Annual Monitoring
and Evaluation Report released in April 2001 and instructions provided on the deer
model spreadsheet). There is no documentation to support the assertion that the 100
deer/square mile carrying capacity was intended to match an HSI score of 1.3.
GSS-15f
The correct multiplier was used to estimate deer carrying capacity (see response 15e) and
is displayed in a table in the Alexander Archipelago Wolf section of Chapter 3 in the
FEIS.
The effects to wolves would be similar with the implementation of any alternative;
therefore, the effects to wolves are discussed under the Alexander Archipelago Wolf
portion of the Effects Common to all Alternatives section of this Chapter.
The alternative comparisons (pp. 3-68 - 3-71) address the effects of the proposed
alternatives on wolves.
The comparison of effects to wildlife species starts in the DEIS on page 3-67 - 3-68 with
the effects common to all alternatives through 3-73. Comparisons of Effects are on page
3-39 -3-71. The Cumulative Effects are on pages 3-71 - 3 -74.
GSS -16
The acres of POG lost in natural events were removed from the current condition in the
FEIS.
Effects of the proposed alternatives on POG high, medium, and low volume stands are
displayed in Table 3-11 (p. 3-39) in the DEIS.
GSS -17
As described in the DEIS (p. 3-41), the matrix is the availability of management lands
subject to timber harvest. Within the Project Area, 93 percent of the area is in the Timber
80 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
production LUD (p.1-6 and p.1-9). The discussion and analysis of “Matrix” would be the
same as the discussion and analysis of the Timber Production LUD. The Forest Plan
analyzed the amount of forested lands that would remain at the end of the rotation (Forest
Plan FEIS p. 3-387). These projections were not a goal, standard, or guideline that is
required to be followed, and because the information is repetitive and confusing, it has
been removed from the FEIS. The discussion of Matrix lands can still be found in the
Wildlife Specialist Report.
GSS -18
The deer model uses the volume strata map, consistent with Forest Plan direction (TEMP
FEIS, p. 3-365).
GSS -19
The Kuiu deer habitat capability analysis used the approved current habitat capability
model. Components of this model include average winter snow depth, elevation, aspect,
and timber volume strata. Use of the volume strata map is consistent with Forest Plan
direction (TLMP FEIS, p. 3-365).
A recent study published in the Journal of Wildlife Management (69(1):322-331,
DeGayner, Doerr and Ith) concluded that there was a lack of relationship between winter
deer use and volume class. By contrast these researchers “[f]ound a consistent
relationship in habitat selection using timber volume strata.” Research has demonstrated
that the volume strata map is a statistically valid method of stratifying the forest for
timber volume.
It is reasonable that the deer model uses the volume strata map, since it was the only
statistically valid map available at the time and it utilized research findings on deer
habitat selection and timber volume. Currently, a new map is being researched to better
evaluate forest structure. This map is undergoing peer review and is currently being
tested for its utility for evaluating deer habitat.
Challenging the components and application of the deer model is a Eorest Plan-level
issue. It is outside the scope of the Kuiu Timber Sale Project analysis to arbitrarily
rewrite the model. The deer model is maintained and updated at the Forest level. Any
changes to the model will be the result of field observations, thorough analysis, and peer
review.
The Forest Service uses TimTyp for evaluating coarse canopy forest in order to respond
to requests from the State.
GSS - 20
The Wildlife Resource Report states that volume classes 6 and 7 from the Tongass GIS
library were used to portray the currently best available information for coarse canopy
stands and that the historic amount of coarse canopy was extracted from Mylar maps and
pre-harvest aerial photos and added to the GIS library. The report also states that the
mapping based on older aerial photos is not as accurate as those derived from more recent
Kuiu Timber Sale FEIS
Appendix C • 81
Response to GSS
photos and field mapping; however, it does offer a fairly good approximation for the
purposes of comparing alternatives.
The Tongass National Forest does not currently have a peer reviewed method for
delineating and mapping varying levels of canopy coarseness. A model for mapping tree
size and density is being tested for accuracy. As of May 25, 2005, the Tongass Forest
Supervisor has directed that all timber harvest NEPA projects use volume class 6 and 7 to
portray the currently best available information for coarse canopy stands. In addition, the
Forest Plan directs for the use of volume strata for vegetation analysis and mapping. This
direction was followed in the Kuiu Timber Sale.
Current Forest direction (Cole 2005) is to use volume classes 6 and 7 to represent coarse
canopy forest, as stated below:
“Use volume class 6 and 7 to portray the currently best available information for
coarse canopy stands in the wildlife section. A table that displays volume class
by alternative will be included in the wildlife section. The amount of volume
class 6 and 7 will be included as part of the small OCR analysis.”
Coarse canopy was displayed using volume class 6 and 7 within the wildlife specialist
report and in the DEIS (pp.3-40 and 3-41). This corresponds with the high coarse canopy
reported by Caouette and DeGayner (2004).
GSS -21a
As discussed in GSS- 18 and 19, the deer model is maintained and updated at the Forest
level. The model was used as intended as discussed in GSS-15e. Any changes made to
the model at the Forest level will be the result of field observations, through analysis, and
peer review.
GSS -21b
The DEIS (p. 3-52) further clarifies that the wildlife models used for the Forest Plan
analysis are useful for comparing alternatives, but were never meant to predict population
numbers (DeGayner, 1992). The model’s intended use is to make distinctions between
alternative treatments. The models do this by providing numbers that represent habitat
capacity. This is a theoretical long-term carrying capacity, not actual population numbers
given normal winter conditions. These numbers are displayed in the DEIS (Table 3-29
p.3-83). The related comparison of effects by alternatives (pp. 3-69 - 3-71) use those
numbers as intended by comparing the percentage of change to the capacity of the habitat
to support deer.
The deer population numbers set by the State of Alaska were developed using the Deer
Habitat Capability model. While it is unfortunate that actual numbers are used, these
numbers are population objectives and not actual numbers of deer. The models are used
to compare the impacts of the alternatives against the desired condition; in this case the
population objective of the WAA.
It has also been estimated that a deer population at carrying capacity could support an
annual harvest by hunters of up to about 10 percent of winter carrying capacity, with the
82 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
population remaining stable and hunter satisfaction remaining fairly high (Flynn and
Suring 1993 in 1997 FEIS p. 3-361). Without the use of numbers it is not possible to
determine what 10 percent of the winter carrying capacity would be.
Throughout the DEIS and FEIS, readers are reminded that these numbers are theoretical.
The numbers from the model are rounded to the nearest whole number, because further
manipulation of the data to the nearest 10^^ or 100* would imply a greater precision than
the theoretical numbers the model generates. The actual whole numbers from the model
are used in the analysis so as to not skew the data. Again, readers are continually
reminded throughout the DEIS and FEIS that these numbers are theoretical.
The use of the word “phantom” in the DEIS was to try to help the reader to understand
that the numbers derived from the model are not real deer numbers but rather,
information in the form of numbers used as a comparison of effects by alternatives.
GSS -21c
The DeGayner 1992 document referenced on p. 3-14 does contain information on the
reliability of habitat capability models. Additional creditable reviews of habitat
capability models have been cited and are available in the planning record. The Council
on Environmental Quality gives direction to prepare analytic rather than encyclopedic
environmental impact statements (Sec. 1502.2(a))
GSS-21d
Additional information regarding the effects of road densities on marten has been added
to the FEIS in the Wildlife section of Chapter 3. Road density is not a component of the
Habitat Capability Model; however, studies have shown that road density may affect the
quality of habitat for marten through trapping (Ruggerio et al. 1994, Suring et al. 1992).
The road density factor was appended to the 5.0 version of the marten model but never
incorporated. It is also not apart of the current model, version 7.0, used for this analysis.
Road density on Kuiu Island was calculated using open road density because most of the
former temporary roads in the Project Area were decommissioned after their use was
terminated. National Forest System roads that are closed were placed in storage.
Decommissioned roads and roads placed in storage have signs of removed structures;
intact water bars, and are generally grown closed with alder. There is little evidence of
ATV use on most of these roads, mainly due to the remoteness of Kuiu Island and the
impassibility on the roads once the stream crossings have been removed. Most personal
vehicle use on the island is in the form of pickup trucks, which cannot navigate the alder
or the mound and pit type barriers normally found on decommissioned and stored roads.
Foot trails along these roads are common.
The FEIS reports that the current open road density for WAA 5012 is 0.46 mi/mi“ and the
total road density for the WAA is 0.68mi/mi^. All action alternatives would decrease the
open road density within the planning area by placing currently open roads into storage
Kuiu Timber Sale FEIS
Appendix C • 83
Response to GSS
(see the Transportation section Chapter 3 for current and proposed road densities by
alternative).
GSS-21e
The FEIS and Wildlife Specialist Report have been corrected to say: “Deer habitat
capability models likely overestimate the carrying capacity for deer” (Person et al. 1 997).
The model was developed to estimate impacts to habitat capability, not deer population
numbers.
GSS -21f
The deer/wolf model described has not been reviewed by the Tongass National Forest.
Current Tongass National Forest direction is to use the Forest Plan deer model to
determine habitat capability for the planning area and determine if the action alternatives
will meet the 18 deer per square mile requirement to maintain sufficient animals for
wolves and human consumption (Person et al. 1997, Puchlerz 2002, and Cole 2005).
The Wildlife Specialist report acknowledges that the effect of deer habitat loss on deer
populations is nonlinear. The addition of the above mentioned wolf factor is one way the
model has been adjusted as new information is acquired. The Tongass National Forest
Land and Resource Management Plan Implementation Policy Clarification 1998 (TPIT)
recognized that both the deer model and wolf/deer equilibrium model made certain
assumptions and contain a certain amount of variability, which needed to be considered
when using any model. The model represents just one tool to be used in doing project
level analysis. Models are best used to make relative comparisons between alternatives
rather than actual populations. Other factors need to be considered by the professional
biologist rather than solely relying upon model results (TPIT 1998, p.l6).
Changes to models and factors are more properly addressed at the Forest level.
GSS -21g
The personal communications with Dave Person have been reviewed. They were not
relevant to this project and were not added to the planning record because this
communication speaks to the wolf predation rate on Sitka black-tailed deer in southeast
Alaska and the consumption rate of food (deer) per kilogram of wolf body weight per
day. The deer multiplier expresses the theoretical number of deer a given habitat can
support as a function of the HSI score. Although the notes from the May and June 2005
wildlife biologist conference calls do not contain any direction, they are contained in the
planning record.
GSS -21 h
Columns for the year 2046 have been added to Tables in Issue 2 of the FEIS. See also
GSS -21j.
GSS -21 i
Table 3-14 in the FEIS shows the HSI value for the historic condition, current condition
and future condition grown to 2046. As managed stands reach stem exclusion age, which
84 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
the model assumes will occur 26 years after harvest, deer habitat is reduced with the loss
of browse. This assumption is part of the current condition HSI values. This information
is included in Chapter 3 of the FEIS.
GSS-21j
The DEIS explicitly states that deer habitat capabilities are based on average winters. The
DEIS (p.3-52) describes the deer habitat capability model and how the model assigns HSI
values based on normal winter conditions and average winter snow depths. In fact, the
first paragraph states:
The deer habitat capability model developed for the Eorest Plan was used to
predict the potential number of deer that the habitat within the Kuiu Timber Sale
Area can support over time. The result is not an actual population number but a
theoretical long-term carrying capacity given normal winter conditions.
And the next paragraph of that page uses the word average snow depth three times to
describe the winter condition.
The DEIS (p. 3-53) further discusses the deer model ... “This number represents the
theoretical maximum number of deer that an area can support over the long-term,
assuming normal winter conditions.”
Severe winter conditions would have a greater impact than shown in the model.
However, there is no model available for severe winters and no way of knowing when or
if a severe winter will occur.
GSS -21k
The nonlinear deer population concerns were addressed in GSS 21g.
GSS - 22a
The DEIS (p. 3-25) contains a detailed description of the effects of harvest compared to
natural disturbance and includes a discussion which compares the effects of natural wind
disturbance to timber harvest.
GSS - 22b
The effects of silvicultural treatments on deer habitat are discussed in the DEIS (pp. 3-50
- 3-51) with Table 3-18 (p. 3-52) showing acres of POG, and high value wildlife habitat
(below 800 feet) harvested by alternative.
Discussions have been added to the PEIS to make it clear that the model treats partial cut
units as clearcut units in all alternatives. A footnote has been added to the tables that
compare the HSI by alternative. The deer model is not solely relied upon for the
discussion of the biology of deer. Local knowledge and site-specific examples are given
in the DEIS (p. 3-51).
Kuiu Timber Sale FEIS
Appendix C • 85
Response to GSS
GSS - 22c
Please see pages 3-164 - 3-165 in the DEIS for the descriptions of two-aged management
and group selection. In general, the harvests will fall within plus or minus 10 percent of
the targeted retention figure for these systems.
For single-tree selection the DEIS (p. 3-166) states that the single tree selection
“maintains a multi-aged structure by removing some trees in various size classes
distributed across the stand... .[t]his maintains or creates a stand of three or more distinct
size classes.” It is not to be assumed that smaller trees will be retained in the place of
larger trees.
GSS - 22d
The HSI values from the deer model are for clearcuts and no adjustments were made. The
discussion of partial harvest on corridors and important deer winter range has been
increased to address the role of partial harvest on corridors and deer habitat. See also
response GSS-22b.
GSS - 22e
In an attempt to keep costs down, few photos are published in EISs.
GSS - 22f
In the DEIS Figures 3-5 and 3-6 shows the current HSI scores by quartile, with the unit
pool and contour lines. The reader can easily deduct where the important winter range
can be found for deer. Figure 3-4 shows the same thing for marten.
GSS - 23a
Most of the maps in the DEIS include a managed stand layer. The scale of the maps
allows the reader to see the majority of north Kuiu Island and the amount of harvest that
has been completed in that area. The photo included with the comments only shows a
single drainage, and does not include the Project Area. The maps in the DEIS allow the
reader to see the relationships better.
GSS - 23b
Fragmentation was analyzed in the Forest Plan. A large block of productive old-growth
(POG) in the Project Area would be projected in the small old-growth reserve and remain
unfragmented. The largest block of old-growth in the area is the North Kuiu Inventoried
Roadless Area, of which 9,456 acres are forest and over 90% is POG. If any of the action
alternatives is implemented, over 8,300 acres of old-growth would remain unfragmented.
The Forest Plan does not require a site-specific fragmentation analysis. As mentioned in
GSS 22d, the discussion on the function of the corridors has been expanded. The request
to discuss connectivity for units that close gaps between previously logged units is noted.
GSS - 23c
As mentioned in 22d the discussion on the function of the corridors has been expanded.
The request to have units that isolate habitat dropped from the unit pool is noted.
86 • Appendix C
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GSS - 23d
Refer to the DEIS (pp. 3-164-166) for further discussion on the desired future condition
and how the stand is expected to function for wildlife after harvest.
The wording has been changed to better reflect that the action alternatives address the
degree of fragmentation differently, rather than reduce fragmentation.
GSS - 24a
Additional information has been added to the Subsistence portion of the FEIS concerning
the annual response rates to the Subsistence reports and the reliability of those reports.
GSS - 24b
See response GSS - 15e.
GSS - 25a
The team strives to utilize all comments in developing a stronger document. The unit card
is a summary of the field visits and helps to identify the concerns of the specialists and
the appropriate response to that concern. This can then be utilized by the layout and
implementation teams. The unit card is limited in its information but more detailed
information is available from the field notes that are in the planning record.
Unit card information does not include who visited the site. That information is available
in the field notes and cards in the planning record. A statement has been added to the
introduction of Issue 2: Deer Habitat and Subsistence Use (Chapter 3) that a Biologist or
appropriately trained field technician visited the proposed units. When something
relevant was noted in the field cards or notes it was placed on the unit card.
GSS - 25b
The unit cards each contain the Volume Strata by high, medium, and low, and in the
Wildlife/Biological Diversity portion of each unit card is the number of acres of
important deer winter range, high value marten habitat. A more detailed description of
the units is available in the field cards and notes in the planning record.
Timtyp does not come from field visits any more then HSI or Vol-strata data.
More field information was added to the cards as requested.
GSS - 25c
Descriptions of the proposed harvest for units with two prescriptions for one alternative
have been better clarified on the unit cards.
GSS - 25d
The silvicultural prescriptions are located on the unit card which accompanies each map.
The majority of these units are designed for cable logging systems. Where a unit lists
both cable and shovel logging systems the shovel logging systems will be used on slopes
Kuiu Timber Sale FEIS
Appendix C • 87
Response to GSS
less than 35 percent. This can be determined from the topographic lines on the unit card
maps. Units planned for helicopter logging list this system on the unit card narrative.
GSS - 25e
All Class I and Class II stream buffer widths are identified on the Appendix B Unit
Cards. Units with Class I and II streams are 109, 109b, 111, 208a, 307, 308, 401, 402,
403, 404, 412, 414, 415, 416, 418, and 503.
GSS - 25f
The conidor information has been updated on the unit cards and the medium HSI
information has been corrected for the FEIS.
GSS - 26a
Information requests were not ignored. Requests were filled within a few days of when
they were received. The planning record includes a log of requests and when and how
they were addressed. The public is always welcome to come to the office during business
hours and view the planning record, however, when they need to be copied and mailed
the process takes longer.
GSS - 26b
Please refer to GSS-18.
GSS - 26c
Scoping comments are reviewed and pertinent and relevant information is incorporated
into the EIS.
GSS - 26d
Analysis of biodiversity, including fragmentation and connectivity, were addressed in the
DEIS (pp. 3-24 - 3-37) in the Wildlife Resource Report.
GSS - 26e
The wildlife models are discussed in both the DEIS and FEIS in Chapter 3 and in greater
detail in the Wildlife Resource report available in the planning record.
GSS - 27
The Eadden (2005) memo is part of the planning record, however, the memo is not
setting a policy. It is Fadden’s recommendation to continue to use the models in a
fashion consistent with past practice as officially sanctioned by the senior forest
leadership on the Tongass. It is the decision of the Forest Supervisor to use the Forest
Plan deer model (Cole, 2005). To use other models that are untested on the Tongass or to
change the parameters of the current deer model would be irresponsible.
GSS - 28
To analyze a project such as the Kuiu Timber Sale on one scale would not give a
complete picture of the effects to the resources, the public, and the Responsible Official.
Different scales of analysis were completed to best analyze the effects of the sale on that
88 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
particular resource. The rationale for the scales used in each analysis has been clarified
in the FEIS and in the Resource Reports available in the planning record. The FEIS
attempts to clarify which scale of analysis is used.
The DEIS (p. 3-216 Table 3-80) displays all existing designated roads, and their status,
within the Project Area including Roads 6415 and 6402 that delineate the Project Area
boundary.
The FEIS uses the WAA scale as the smallest area for road density following Forest
Supervisor direction (Cole 2005). Wolf was assessed using both WAA and
biogeographical province (island-wide) road density figures.
GSS - 29
The information for historic coarse canopy forests is incomplete and/or unavailable. It is
not logistically or economically feasible to visit each harvested site to measure stumps to
determine the historic habitat condition. The level of analysis needed was accomplished
by assuming that the majority of the past harvest occurred in high volume timber stands.
The assumptions are based on the knowledge that the majority of past harvest occurred
along valley bottoms and in many cases included high volume stands. This leads to an
assumption that most likely overestimates the amount of coarse canopy forests that were
harvested and would not lead to an underestimate the degree of effect past harvest has
had on high volume coarse canopy forests. A “hard-look analysis” was made by
assuming a greater impact than what probably occurred.
GSS - 30
The analysis has been corrected.
GSS - 31
The Integrated Resource Inventory (IRI) crew conducted field surveys for MIS species in
2003. These surveys included 113 plots. The MIS species included: red squirrel, black
bear, moose, river otter, Sitka black-tailed deer, marten, wolf, northern goshawk,
Vancouver Canada goose, bald eagle, red-breasted sap-sucker, hairy woodpecker, brown
creeper, great blue heron, and osprey. Field records are available in the planning record.
The Forest Plan’s standards and guidelines include direction for Wildlife Habitat
Planning. The FEIS provides direction to “[cjonduct project level inventories to identify
heron rookeries and raptor nesting habitat using the most recent inventory protocols”
(TEMP p. 4-116). The TPIT (Appendix A p. A-4) provides the clarification of “most
recent inventory protocols” as:
Herons - “during project field work from April to July, project personnel shall
scan intertidal mudflats within the analysis area for the presence of foraging great
blue herons.”
Kuiu Timber Sale FEIS
Appendix C • 89
Response to GSS
Raptor nests - “report any sightings to the team biologist who will conduct
follow-up site visits to assess nesting raptor presence. Use nonspecific calls
(goshawk or great horned owl) to elicit raptor responses to locate potential nests.”
Inventories for herons and raptors were conducted during surveys for other wildlife
including marbled murrelets, goshawks, breeding birds, and MIS plot surveys.
Herons
Great blue heron inventories occurred during field visits and are noted in the wildlife
survey field notes which have been added to the planning record. Great blue herons were
sighted on three separate occasions in 2003 and on 6/5/03 the area between Rowan Bay
and Clear Creek was searched for signs of a rookery with no rookery found.
Raptors
Other raptors inventoried included goshawk, sharp-shinned hawk, red-tailed hawk, and
great homed owl and are noted in the wildlife survey field notes which have been added
to the planning record. No active nests were located.
The planning record was a work-in-progress during preparation of the DEIS. The record
has been completed and the goshawk survey information is in the planning record.
GSS - 32a
Due to well-trained field crews, two potential den sites were located; site 2003 was
determined to be a den. This site occurs in a unit that has been dropped from the unit
pool, and monitoring during 2004 and 2005 determined the den to be unused both years.
Site 2004 was questionable as to whether it was a den and monitoring in 2005 determined
the site unused.
As described in the DEIS, (p. 3-66) Dave Person, ADF&G biologist, was consulted. He
determined one site was a wolf den and the other site was most likely a resting site. (This
information has been changed from the DEIS which said ‘bear den’). To be on the
conservative side, a 1,200-foot buffer was placed around both locations.
The FEIS (p. 4-117) states, “Design management activities to avoid abandonment of wolf
dens.
a) Maintain a 1 ,200-foot forested buffer, where available, around known active
wolf dens. Road construction within the buffer is discouraged and alternative
routes should be identified where feasible. No road constmction is permitted
within 600 feet of a den unless site-specific analysis indicates that local
landform or other factors will alleviate potential adverse disturbance.
b) If a den is monitored for two consecutive years and found to be inactive,
buffers described above are no longer required. However, in the spring-time,
prior to implementing on-the-ground management activities (timber harvest or
road constmction), each known den site will be checked to see if it has
become active.”
90 • Appendix C
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Response to GSS
As stated in the unit card, this den was monitored from 2003-2005 and no activity was
noted in 2004 or 2005. Although the den has been inactive for the last two years, the unit
boundaries were moved to exclude the site.
The deer population on Kuiu Island remains above the recommended population to
sustain wolves. The DEIS (p. 3-65) discussed that Person, et al. (1996) concluded that
maintaining an average long-term deer habitat capability of at least 18 deer per square
mile over broad areas should be sufficient to both provide for sustainable wolf
populations and meet hunter demand for deer. The deer habitat capability analysis of
Kuiu Island shows enough habitat to currently support 27 deer per square mile.
GSS - 32b
The scoping comments from ADF&G were used to design alternatives that did not target
the highest value important deer winter range. Table 3-25 shows that while there is
harvest planned within the important deer winter range it composes the minority of the
total acres within each action alternative. The following alternative information shows;
• Alternative 2: 128 acres (26%) important deer winter range harvested
from a total of 491 acres,
• Alternative 3: 130 acres ( 1 6%) important deer winter range harvested
from 794 total acres harvested,
• Alternative 4: 311 acres (22%) important deer winter range harvested
from a total of 1425 acres harvested, and
• Alternative 5: 264 acres (20%) important deer winter range harvested
from 1231 total acres harvested.
GSS - 32c
Person (2001) did not make a distinction between open and closed roads in his model.
However, he stated that he was making the assumption that while the U.S. Forest Service
closed some roads by removing culverts and bridges that policy was sporadic and most
roads were open for vehicular traffic.
Within the Project Area, most of the roads currently closed were done so by removing
culverts (including stream crossings) and log stringer bridges. In many cases they are not
accessible to vehicles, including off-road vehicles (ORVs). The proposed temporary
roads will be decommissioned with the removal of all structures, rendering them
impassible.
Person (2001) recognized there was a difference with regard to use on roads for those
areas connected to the main system of roads and for those wildlife analysis areas that
were not connected. Person (2001) found the average harvest for wildlife analysis areas
connected to the main road system was 4. 1 wolves and was much higher than the average
of 1.3 wolves for wildlife analysis areas that were not connected by the road system.
Person (2001) estimated that a total density of roads ^.53 km/km^ (0.33 mi/mi^) for
wildlife analysis areas connected to the main road system would likely result in
Kuiu Timber Sale FEIS
Appendix C • 91
Response to GSS
overharvesting wolves. For wildlife analysis areas that were not connected to the main
road system, the limit for density of roads was 1 .04 km/ km^ (0.65 mi/mi^).
•»
Regardless of whether Person (2001 ) made no distinction between open and closed roads
in his modeling, he recognized the reality of the difference when the road was correctly
closed to vehicular use. He believed that managing human access by closing roads from
motorized use and limiting construction of new roads were measures necessary to
conserve wolves over the long-term.
Harvest records from ADF&G on Kuiu Island show the harvest of wolves since 1984 has
averaged five animals with a high of 16 wolves in 1993 and a low of zero wolves in 1984
and 1990.
The DEIS (p. 3-66) recognized the importance of measuring road densities below 1200
feet.
In a study conducted on Prince of Wales and Kosciusko Islands from 1992 to
1995, Person et al. (1996) found that WAAs with road density of 0.7 miles per
square mile below 1,200 feet in elevation experiences a twofold increase in wolf
mortality. The area was calculated using road density area within a WAA below
370 meters (~ 1,200 feet) elevation as the denominator. Wolves spend most of
their time at low elevations and calculations of road density reflect this relation. In
a concurrent radiotelemetry study, the average annual mortality was 50 percent of
the population, which is not sustainable (Person et al., 1996).
Page 3-68 shows the open road density below 1,200 feet for WAA 5012. The FEIS has
been changed to reflect the above rationale, to remove the road density by planning area,
to add more discussion on road density by WAA (the scale to be measuring road densities
for wolves. Person et al 1996) and to show the total road density in WAA below 1,200.
The density shown was 0.5 mile per square mile, which is still well below the 0.7 mile
per square mile figure. The above road discussion had been added to the Wildlife Report.
GSS - 33a
The DEIS (p.3-73) recognized the short-term potential benefits of logging from increased
berry production and the longer term impacts from the closed canopy which may cause
black bear populations to decline due to loss productive foraging habitat.
GSS - 33b
The DEIS p. 3-257 says
Impacts to recreation and sport activities during logging may prove negative due
to increased traffic and possible noise disturbance. Also, the planned closure of
currently open roads would limit access in the long-term. New temporary road
access might prove beneficial for outfitter and guide activities and subsistence
users. Aceess would be short-term since all new roads would be closed after
harvest. Recreation activities occurring in Saginaw Bay and Security Bay during
logging may be affected by noise disturbance. If the Saginaw Bay LTE were used,
people in Saginaw Bay would be affected by barge activities.
92 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
GSS - 34
The Forest Plan standards and guidelines states: “cooperate and coordinate with State and
other Federal agencies to better understand the life history requirements and distribution
of the marbled murrelets/” There is no requirement to survey project areas to identify
nests. Despite this, stands were surveyed for marbled murrelet nesting activity in 2003,
field survey information can be found in the project record. At this time, no nests have
been found. If a nest or nests are found in the Project Area they will be protected as
required by the Forest Plan.
GSS - 35
All information discussed in resource reports is not displayed in the FEIS. The rest of the
paragraph states that they found that the low marten numbers were related to low
densities of long-tailed voles.
The resource report also covered discussions with Rich Lowell, Area Biologist for the
Alaska Department of Fish and Game located in Petersburg, Alaska, which included the
status of the marten populations on Kuiu Island, the historical trapping records, road
access, and trapping effort.
The Forest Plan identified areas of timber harvest in higher risk biogeographic provinces
to retain the features of forest stand structure. The provinces do not include the Kuiu
biogeographic province (Forest Plan 4-118). As the DEIS (p.1-9 Table 1-1) demonstrates,
170,585 acres are designated as development LUDs (35 percent) on Kuiu Island. Less
than 16 percent of the development LUD acres on Kuiu Island have been harvested. At
this time, marten viability is not a concern.
Additional information from Flynn and Schumacher (2004) was added to the Wildlife
Report.
GSS - 36
“1997 TLMP p. 4-12” refers to providing for maintenance of fish habitat enhancements.
The reference to connectivity is on p. 4-120 in the Forest Plan.
The Wildlife Report has an in-depth analysis of connectivity, which includes a discussion
of the conservation strategy.
Additional analysis of the effects of removal of the leave strips and the method of harvest
has been added to the FEIS.
Riparian reserves which were harvested were not included as corridors in the analysis of
connectivity.
' And to “maintain a 600 foot, generally circular, radius of undisturbed forest habitat surrounding identified
murrelet nests, where available.”
Kuiu Timber Sale FEIS
Appendix C • 93
Response to GSS
The concern over maintaining wildlife corridors is acknowledged and the request for
dropping of several units has been noted. Also see response to 22d.
There are no Units 102, 206, 3T)1, or 408, and while there is a Unit 409 there is no 409a
or 409b. Please refer to the FEIS for unit numbers.
GSS - 37
The forest is evaluating small endemic mammals and the Pacific Northwest Research
Station (PNW) is conducting long-term studies to identify the existence of endemic
mammal taxa throughout the island archipelago of Southeast Alaska (Dr. Winston Smith
and others). These studies will continue and may be accelerated to examine islands less
than 163,000 acres in size for the potential presence of locally endemic taxa that may be
at risk as a result of additional vegetation management activities (TNF Annual
Monitoring & Evaluation Report, 2004).
Marten and small mammal trapping by Flynn and Schumacher occurred on Kuiu Island
between 2001 and 2002 and is mentioned in the wildlife report along with an analysis on
the endemic marten population on Kuiu Island. Additional small mammal trapping by the
Petersburg Inventory Resource Crew in 2003 is available in the planning record. None of
the species collected were rare endemics.
TPIT Appendix A p. A-5 clarifies Forest Plan direction for endemic mammals:
For islands greater than 50,000 acres, if presence or distinctiveness of the taxa is
uncertain and potential management risk posed are high or unknown then apply
the RNA sampling protocol as outlined in TPIT Appendix A p. A-5. If endemic
taxa are already known to be present and the conservation strategy has a high
likelihood of sustaining endemic taxa, no surveys are required.
As noted in GSS-35, only 35 percent of Kuiu Island is in development LUDs and less
than 16 percent of the developments LUDs have been harvested. Because of the large
acreage of non-development LUDs on Kuiu Island, the conservation strategy has a high
likelihood of sustaining endemic taxa.
GSS - 38
There is no requirement or need identified to prevent non-motorized access to local
resources, nor was there any plan to exclude traffic from roads during the project
operating years. The short-term increase in road densities during logging, due to the
temporary road construction, has been analyzed in the DEIS. As Table 3-81 (p.3-218)
shows, there will be an overall decrease in road densities with all action alternatives. The
ongoing Access Travel Management plan (ATM) will address the maintenance levels of
existing forest roads.
The FEIS discusses the methods used to place open NFS roads into storage (see
Transportation in Chapter 3). The FEIS also mentions throughout the document that all
temporary roads would be decommissioned and all new and reconditioned NFS roads
94 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
would be closed after harvest is complete. More detail has been added about road closure
and decommissioning.
More site specific effects of road crossing have been added to the FEIS.
GSS - 39
As discussed in GSS-31, the Integrated Resource Inventory (IRI) crew conducted field
surveys for MIS and other wildlife species in 2003. These surveys included 113 plots,
which recorded any sighting of scat, track, verbal note, trail, feeding station, or actual
sighting of red squirrel, black bear, moose, river otter, Sitka black-tailed deer, marten,
wolf, northern goshawk, Vancouver Canada goose, bald eagle, red-breasted sap-sucker,
hairy woodpecker, brown creeper, great blue heron, and osprey. Field records are
available in the planning record. These surveys help complete the hard-look analysis
required by NEPA.
The Vancouver Canada goose and red-breasted sapsucker have been included in the
FEIS.
The MIS species were chosen for the analysis for this project, rather species that best
represent the affected environment. The rationale for selection is indicated in Table 3-14
in the DEIS (p. 3-43).
GSS - 40
Twenty-four units were surveyed for sensitive plants. The unit pool contains 37 units, so
65% of the units were surveyed. Normally 100% of the units and roads are not surveyed.
The habitats that are most likely to contain sensitive plants are the priority to survey
(DEIS p. 3-149 to 3-151). The Petersburg Ranger District does not have a written
protocol for how intensely to survey for sensitive plants, but the Ketchikan Area had one
written in 1999. That protocol suggested, “At a minimum, 30% of likely harvest units
and 50% of likely roads should be surveyed.” While conducting the surveys within units
on Kuiu, roads within the units were walked as part of the unit survey. Also, while
accessing the units, the access roads proposed for reconditioning were examined (DEIS
pp. 3-149 & 3-150).
GSS -41
The proposed project is consistent with management of Kadake Creek as a Recreational
River under the Wild and Scenic River Act (Public Law 90-542, as amended; 16 U.S.C.
1271-1287).
More information has been added in Chapter 3 of the FEIS to clarify allowable activities
within a Recreational River Land Use Designation (LUD) and to analyze the effects of
the proposed activities on the Kadake Recreational River corridor.
The harvest impact to the Kadake Recreation River corridor would be minimal (less than
one percent of the Recreation River corridor). Within the 6,585-acre Kadake Recreation
River corridor, the project proposes partial harvest treatment of 18 acres in Unit 415 for
Alternatives 2 and 4, and an additional 31 acres of partial harvest in Alternative 4 in Unit
414 (DEIS and FEIS Appendix B Unit Cards). Alternatives 3 and 5 would not harvest
any acres within the river corridor. Road management activity within the river corridor
would be limited to reconditioning existing roads or the construction of temporary roads
Kuiu Timber Sale FEIS
Appendix C • 95
Response to GSS
(DEIS, Unit cards, pp B82-85). These activities are allowable in a Recreational River
LUD.
Appendix E of the Forest Plan (p. E-251) divides Kadake Creek into four segments;
Segment 1 and 3 meet the guidelines for Recreational River classification; Segments 2
and 4 meet the guidelines for Wild River classification. The proposed harvest units in
Alternatives 2 and 4 would be in the Recreational River Segment 1 . Recreational River
areas are defined as those rivers or sections of rivers that are readily accessible by road
that may have undergone some development along their shorelines (Forest Plan p. 3-325).
Forest Plan goals for Recreation River land use designations includes providing
recreation opportunities in a pleasing, though modified, generally free-flowing river
setting, while allowing timber harvest, transportation, and other developments (Forest
Plan p. 3-1 12 and 3-1 18).
The Partial Retention Visual Quality Objective will be applied in areas within the river
corridor. The area outside the river corridor will be managed according to the guidelines
of the adjacent LUD. In Alternatives 2 and 4, the timber harvest has been designed to
meet the Partial Retention Visual Quality Objective as allowed under the standards and
guidelines of the Recreational River LUD (DEIS, pp. 3-232 to 3-234, DEIS and FEIS
Appendix A Unit Cards).
GSS - 42
The numbers have been corrected in Table 3-43 (Small old-growth habitat reserve
options for VCU 398) in the FEIS. The recommendation will be considered when the
decision is made.
GSS - 43a
The watershed analysis does include a more intensive, complex, and field-based
watershed analysis for the watersheds with greater than 20% harvest in 30 years. The
DEIS (p. 3-115 Table 3-40 and p.3-138 Table 3-49) includes a sediment risk analysis for
each watershed affected by the project. The DEIS (pp. 3-117-3-122) also includes a
field-based inventory of stream channel conditions for each watershed with more than 20
percent harvest in 30 years.
The content of the watershed analysis does follow the basic framework outlined in
Ecosystem Analysis at the Watershed Scale, even though it is presented in a different
format. Notably, the watershed analysis addresses all core topics identified in Ecosystem
Analysis, including erosion processes, hydrology, vegetation, stream channels, water
quality, species and habitats, and human uses. The six step process outlined in
Ecosystem Analysis at the Watershed Scale includes: 1) Characterization of the
watershed, 2) Identification of issues and key questions, 3) Description of current
conditions, 4) Description of reference conditions, 5) Synthesis and interpretation of
information, and 6) Recommendation. All six of these steps can be identified in the
watershed analysis, with the exception of Identification of key questions. The watershed
analysis does answer the key questions that correspond to the core topics identified in
Ecosystem Analysis.
96 • Appendix C
Kuiu Timber Sale FEIS
Response to GSS
GSS - 43b
The level of analysis for the Rowan Creek Watershed is consistent with the level
recommended by the Forest Plan.
GSS - 43c
Additional information has been added to the watershed cumulative effects sections of
the document. This includes references to the Catalog of Events that was completed for
Kuiu. The analysis of cumulative effects adequately analyzes the effects to watershed
resources from past, present, and reasonably foreseeable future activities.
GSS - 44a
A hard look at the cumulative impacts to forest resources from past logging was done in
the DEIS and can be found on the following pages:
• Page 1-10, 1-11, and Table 1-2 shows the past harvest in the Kuiu Timber Sale
area by decade.
• Roadless Areas pp. 3-21 - 3 -22
• Wildlife pp. 3-72 - 3-75
• Subsistence pp. 3-90 - 3-92
• Timber Economics pp. 3-1 10 - 3-1 1 1
• Watersheds pp. 3-124-3-1 25
• Timber and vegetation pp. 3-172 - 3-173
• Fisheries p. 3-185
• Soils and geology pp. 3-206 - 3-207
• Wetlands pp. 3-213 - 3-214
• Transportation pp. 3-222 - 3-223
• Scenery pp. 3-237 - 3-239
• Recreation p. 3-250
• Socioeconomics pp. 3-259 - 3-260
• Heritage Resources p. 3-265
The impacts to regional habitat contiguity and large-scale concerns were evaluated on a
Tongass-wide level by the Forest Plan. The Catalog of Events for Kuiu Island was
referenced in determining cumulative effects. Effects boundaries were identified by
individual resources. Those events from the catalog which had measurable overlapping
effects were considered in the individual resource cumulative effects analyses.
GSS - 44b
The Eive-year Timber Sale Plan is a dynamic plan which shows potential timber sale
projects over a five-year period. The Eive-year Timber Sale Plan is reviewed and
adjusted annually. The Alecks Timber Sale, as mentioned in the Kuiu Landscape
Assessment, is a good example. The Alecks Timber Sale project is not listed on the Five-
year Timber Sale Plan signed on November 7, 2005, due to planners foreseeing the need
to adjust the scheduling of timber sales in the area. It is important to keep in mind that a
Landscape assessment is a “snapshot” of the current situation and the Eive-year Timber
Kuiu Timber Sale FEIS
Appendix C • 97
Response to GSS
Sale Plan is a “living” document that is reviewed and updated annually. The current Five-
year Timber Sale Plan no longer lists the Bayport project.
GSS - 45 Conclusion
The request to stop planning on the Kuiu Timber Sale has been noted. A No Action
Alternative is part of the range of alternatives being considered by the Forest Supervisor.
The specific unit comments have been addressed in GSS-36.
98 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #7 - SEACC
Southeast Alaska Conservation Council
via email to: comments-alaska-tongass-Detersburg@fs.fed. us
Patricia Grantham
Petersburg District Ranger
Tongass National Forest
USDA Forest Service, Region 10
PO Box 1328
Petersburg, AK 99833
Re; comments on Draft Environmental Impact Statement for Kuiu Timber Sale
Dear Ranger Grantham:
The Southeast Alaska Conservation Council (SEACC) submits the following comments
on the Draft Environmental Impact Statement (DEIS) published for public comment by
the Forest Service on the proposed Kuiu Timber Sale. The DEIS describes the no-action
alternative and four action alternatives. The action alternatives propose logging between
14.6 million board feet (MMBF) of timber from 491 acres and 42.65 MMBF from 1,425
acres from the project area Kuiu Timber Sale Area on north Kuiu Island. This sale area
includes most of land m Saginaw Bay (VCU 399), the eastern half of Security Bay (VCU
400), and portions of Rowan Bay (VCU 402) and Kadake Creek (VCU 421). Alaska
Department of Fish and Game (ADF&G) identified these VCUs as having the highest
community use values in its Tongass Fish and Wildlife Resource Assessment (1998).
SEACC is a coalition of 18 volunteer citizen organizations based in 14 Southeast Alaskan
communities, including the Customary and Traditional Gathering Coimcil of Kake and
Petersburg’s Narrows Conservation Coalition. SEACC’s membership includes
conunercial fishermen, Alaska Natives, small-scale timber operators and value-added
wood product manufacturers, tourism and recreation business owners, himters and
guides, and Alaskans from many other walks of hfe. SEACC is dedieated to preserving
the integrity of Southeast Alaska’s unsurpassed natural environment while providing for
the balanced, sustainable use of our region’s resources. Even after years of industrial
scale logging on public and private lands in Southeast Alaska, the region continues to
possess magnificent old-growth forests, outstanding fish and wildlife habitat, vital
customary and traditional use and subsistence areas, and excellent air and water quality.
ALASKA SOCIETY OF AMERICAN FOREST DWELLERS, Point Baker • ALASKANS FOR JUNEAU • CHICHAGOF CONSERVATION COUNCIL. Tenakee
• FRIENDS OF BERNERS BAY, Juneau • FRIENDS OF GLACIER BAY, Gustavus • JUNEAU AUDUBON SOCIETY • JUNEAU GROUP SIERRA CLUB • LOWER CHATHAM
CONSERVATION SOCIETY, Port Alexander • LYNN CANAL CONSERVATION, Haines • NARROWS CONSERVATION COALITION, Petersburg • LISIANSKl INLET RESOURCE
COUNCIL, Pelican • PRINCE OF WALES CONSERVATION LEAGUE, Craig • SITKA CONSERVATION SOCIETY • TONGASS CONSERVATION SOCIETY, Ketchikan • TAKU
CONSERVATION SOCIETY, Juneau • WRANGELL RESOURCE COUNCIL • YAKUTAT RESOURCE CONSERVATION COUNCIL
printed on recycled paper^H^
419 6th Street, Suite 200, Juneau, AK 99801
(907) 586-6942 phone • (907) 463-3312 fax
www.seacc.org • info@seacc.org
March 20, 2006
Kuiu Timber Sale FEIS
Appendix C • 99
Comment Letter #7 - SEACC
Southeast Alaska’s rugged, wild landscape allows Alaskans to pursue a lifestyle no
longer available to most Americans.
I. Inadequate Agency Consultation and Collaboration with Organized
Village of Kake
SEACC
1a
SEACC
1b
Both Executive Order 13175 and the 1997 Revised Tongass Forest Plan (TLMP) direct
the Forest Service to consult and collaborate with Indian Tribal Governments, such as the
'Organized Village of Kake (OVK), before agency action is taken. Although the Forest
Service met with OVK representatives, the proposed action and other action alternatives
considered in the Kuiu DEIS indicate that the agency has n^ade little actual effort to
accommodate the real concerns of OVK over additional logging on its ancestral lands on
^orth Kuiu Island.
The proposed action and other action alternatives further are evidence that the Forest
Service proceeded ahead with deciding what levels of logging were appropriate without
meaningfiiUy collaborating with OVK in violation of TLMP. The 1997 TLMP ROD
directs “Forest Supervisors and District Rangers to increase their efforts in collaborative
stewardship within the communities of Southeast Alaska. Collaborative stewardship
means bringing people together to share in the decision making in implementing Forest
Plan direction.” TLMP ROD at 42. Instead of collaborating with OVK, the Forest
Service appears to have dismissed their concerns as insignificant or beyond the scope of
the DEIS. See DEIS at 1-21 (no more logging and road building on Kuiu Island); 1-22
(don’t log anymore fi*om this project area).
According to the DEIS, the Kuiu timber sale implements the management direction
contained in the 1997 TLMP. Planning this sale without adequate consultation and
collaboration with the OVK is particularly problematic because of the yet-to-be
completed, court-mandated revision of the 1997 TLMP. In a decision issued on August
5, 2005, the 9* Circuit Court of Appeals found fundamental defects in the 1997 TLMP
based on the substantial error made by the Forest Service in estimating the market demand
for Tongass Timber. As the court explained, this error “fatally infected [the agency’s]
balance of the economic and environmental considerations.” NRDC v. USFS, 421 F.3d 797,
816(9*Cir. 2005).
Given that there is more than enough timber on the existing road system of north Kuiu
Island to allow logging to continue at prevailing levels on the Tongass, we urge the
Forest Service to halt planning associated with this timber sale while the agency corrects
the defects in TLMP. See DEIS, Appendix A, Table A-1 at A-4 (indicating that forest-
wide logging levels fi'om 2000 to 2005 averaged 45.6 MMBF). This data substantially
undercuts the Forest Service’s conclusion that “[djelaying the completion of this . . .
project should be avoided because it would substantially undermine the Forest Service’s
ability to respond to timber demand.” See DEIS, Appendix A at A-4. To proceed with
planning this controversial sale will prejudice the court-mandated plan revision process
by predetermining the outcome for the Kuiu project area before the agency conducts a
reasoned balancing between managing this area for timber development or other valuable
^ economic and non-commodity uses. Such uses include customary and traditional hunting.
SEACC Comments on Kuiu DEIS Page 2
March 20, 2006
100 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #7 - SEACC
fishing and gathering, and salmon and steelhead production to support commercial and
sportfishing opportunities.
II. Alternatives
^One reasonable action alternative that was not proposed in the DEIS is a timber sale
program similar to the microsale program developed on Prince of Wales Island. Under
that program, the Forest Service makes available minor amounts of down or dead trees
from the existing road system to supply small purchaser’s operations. Such an alternative
could meet the needs of small operators in Kake and minimize the impacts to deer habitat
from clearcutting that have already caused significant restrictions to Kake hxmters’ use of
^this traditional use area.
This alternative could also provide economic benefits to Kake by contracting with local
residents to repair the 44 “red” culverts in the project area, 1 1 of which are on Class I
streams. “A red fish crossing is one that cannot pass juvenile fish at some or all flows.”
See DEIS at 3-180. Given that all the stream systems were identified by the Alaska
Department of Fish and Game (ADF&G) as primary salmon producers, fixing these red
culverts should be as a management priority for the Forest Service not as an afterthought.
DEIS, Table 1-3 at 1-13 (“Evaluate 44 red culverts as opportunities arise”).
III. Faulty Deer Habitat Suitability and Hunter Demand Analysis
Despite the extensive loss of critical deer winter range in the past on north Kuiu Island
and evidence of significantly reduced hunter success, the Forest Service appears posed to
accept “an immediate decline in habitat capability” under any of the action alternatives.
DEIS at 3-83. In fact, the Forest Service concludes that “[t]he potential foreseeable
effects from the action alternatives in the Kuiu Timber Sale are not expected to result in a
significant restriction of subsistence uses of Sitka black-tailed deer.” DEIS at 3-95. This
conclusion is based on faulty deer habitat suitability and hunter demand analyses.
The analysis also suffers because it mixes and matches habitat suitabihty and hunter
demand data for the project area, for WAA 5012, and for the island as a whole. While all
the watersheds in the project area are contained in WAA 5012, this WAA also includes
nearly 24,000 acres of contiguous forest habitat in Roadless Area 240 (Security). Harvest
effort by OVK hunters, however, is generally focused more specifically in those portions
of Security, Saginaw, and Kadake Bays closer to the community of Kake within the
'^project area. To better inform the public about the direct, indirect, and cumulative effects
from this proposal, we request the Forest Service provide specific information, in a clear,
concise format, regarding historical, present, and future conditions for the project area,
^WAA 5012, and Kuiu Island as a whole.
The DEIS relies, in part, on the deer habitat capabihty model to determine an estimate of
the potential supply of deer available for subsistence use. DEIS at 3-80. As discussed in
the appeal of the Emerald Bay Timber Sale filed with the Forest Service on January 5,
2006, the agency’s use of the deer model has been seriously flawed for a variety of
V reasons. See SEACC, et al. Appeal of Record of Decision for the Emerald Bay Timber
SEACC Comments on Kuiu DEIS Page 3
March 20, 2006
Kuiu Timber Sale FEIS
Appendix C • 101
Comment Letter #7 - SEACC
SEACC
3b cont.
SEACC
3c
SEACC
3d
Sale at 49-55 (excerpts attached as Exhibit 1). For example, the Forest Service has
applied an incorrect deer carrying capacity multiplier of 100 deer/sq. mile in an area with
a Habitat Suitability Index ofd .0; this is the same multiplier used in Kuiu DEIS. See
DEIS at 3-53. NEPA requires the Forest Service disclose the shortcomings of their use of
the model and provide a new analysis based on a corrected interpretation of the model.
The DEIS also emphasizes that important deer habitat is productive old-growth below
800 feet in elevation. Id. at 3-51. This is precisely the habitat that has been logged in the
past . Id. at 3-195. Nevertheless, about a third of the acres targeted for clearcutting under
the preferred alternative is similar low-elevation habitat. . Id., Table 3-18 at 3-52.
Another approach to evaluating the impacts of additional logging on north Kuiu
subsistence hunting is simply to look at historical harvest levels. This approach is
consistent with the statement in the DEIS that “[t]he evaluation of deer is based on
comparison of supply and demand.” DEIS at 3-80. The DEIS goes on to explain that “[i]f
the demand for deer exceeds the supply, then a significant possibility of a subsistence
restriction exists.” Id. Despite the theoretical habitat capacity estimated for the project
area, the fact is that the data shows that deer hunter success is significantly below that
theoretical capacity. We suggest that historical data on himter success may be a more
accurate indicator of the quality of deer habitat within the project area than the theoretical
^ results of the agency’s deer habitat capability model.
The Kuiu DEIS tabulates deer subsistence harvest data for the entire island for the years
1993 through 2003. For these 1 1 years, the average annual harvest is only 19 deer. DEIS
Table 3-27 at 3-81. The DEIS provides no explanation for why actual deer harvest is so
far below the habitat capability estimated but only suggests a handful of reasons why the
die-off of 1971-72 was more severe on Kuiu than Prince of Wales or Admiralty Island.
DEIS at 3-50. Indeed, the DEIS acknowledges that “[wjhile Kuiu Island seems to be
getting more use, there has been no significant change in the number of deer harvested.”
DEIS at 3-58.
f The Forest Service also draws umeasonable conclusions about the purported benefits of
past and proposed logging prescriptions on habitat capability. The agency proposes
harvest prescriptions that retain 50% of basal area even though the discussion in the DEIS
presents no scientific justification that such a prescription will protect deer habitat. See
DEIS, Table 2-1 at 2-10. For example, the agency relates apples to oranges by citing to
the 1995 Doerr study that analyzed the favorable effects of removing 20 and 40 percent
of stand volume, not basal area. The DEIS also cites to the 2001 Deal study and
concludes “plant structures. . .appear to be more resilient to moderate ranges of partial
cutting (below 50 percent basal area removal).” DEIS at 3-51. However, the proposed
prescriptions are for 50% retention, not less than 50%. Additionally, while the DEIS
describes the benefits of enhanced plant understories, it ignores questions about the
ability of the remaining forest canopy to intercept snow and maintain important deer
winter habitat..
SEACC Comments on Kuiu DEIS Page 4
March 20, 2006
102 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #7 - SEACC
We also urge the agency to acknowledge newer studies of forest management effects on
vegetation and habitat. In particular, the agency should address Hanley’s statement in his
2005 study that “[e]mpirical results demonstrating a benefit of within-stand clearcut gaps
and residual patches do not yet exist, except of the smallest scale of individual-tree
selective cutting.”* Because the Forest Service failed to provide a clear scientific basis
for their selection of partial clearcutting prescriptions, these prescriptions do not qualify
as reasonable mitigation measures for anticipated impacts to customary and traditional
deer harvest.
A comparison of Unit 414 in Figures 3-5 and 3-6 further illustrate the illusory effect of
these clearcutting prescriptions on deer habitat. Figure 3-5, which illustrates deer winter
range in 2005, indicates that most of the 72 acres in unit 414 is high value deer habitat.
^The prescriptions proposed for this unit call for two-aged management or clearcutting
50% of the basal area in this unit. DEIS at B-82. Figure 3-6, however, which shows deer
winter range as of 2045, shows no change in the habitat capability for unit 414. The
DEIS presents no scientific evidence to support the contention that clearcutting a
substantial portion of the high volume timber strata in this unit, three-quarters of which is
Mocated below 800 feet, will result in no loss of habitat capability.
^The DEIS Jilso relies on ADF&G estimates of hunter demand fi’om 1960-1968 to support
its conclusion that there is sufficient habitat to meet hunter demand in WAA 5012. See
DEIS at 3-82. When it appealed the Crane and Rowan timber sale in 1998, however,
OVK submitted the testimony of six tribal hunters who hunted on Kuiu during this
period. These declarations established that ADF&G lacked a reasonable basis for its
hunter demand estimates. In its decision denying OVK’s appeal, the Forest Service
promised “to work coUaboratively with Kake residents in reviewing and possibly revising
the data on hunter demand for Kuiu Island. The information gained will be used in planning
for future projects.” See ARO’s Recommendation to Regional Forester at 18-19 (Oct. 16,
1998)(attached as Exhibit 3). Nevertheless, the Forest Service continues to rely on this
contradicted and unreliable data. See DEIS at 3-82. The DEIS does not indicate that the
\j>romised collaborative effort with Kake residents ever occurred.
In sum, the DEIS’ discussion of impacts on deer numbers and habitat fi'om the proposed
action is severely compromised by mixing and matching data for the Project Area, for the
WAA, and for the island as a whole, relying on a flawed interpretation of the deer habitat
capability model and the unsupported conclusions as to benefits fi'om proposed two-aged
management, and by failing to provide readily available historical subsistence harvest
data.
’ See Hanley, T. A.: Potential management of young-growth stands for understory vegetation and wildlife
habitat in southeastern Alaska. Landscape and Urban Planning 72, 95-112, at 106 (2005). Available on-line
at; httD://www.treesearch.fs.fed.us/. accessed March 20, 2006.
^ See Exhibit 2 (OVK’s appeal of the Crane & Rowan Timber Sale (Sept. 14, 1998) and the six declaration
submitted as exhibits to that appeal).
SEACC Comments on Kuiu DEIS Page 5
March 20, 2006
Kuiu Timber Sale FEIS
Appendix C • 103
Comment Letter #7 - SEACC
SEACC
4a
SEACC
4b
SEACC
4c
SEACC
4d
IV. Watershed Analyses
The Tongass Fish and Wildlife Resource Assessment (ADF«&G, 1998) identified the
stream systems for the Saginaw, Security, Rowan, and Kadake Value Comparison Units
(VCUs) 399, 400, 402, and 421 as primary salmon producers. ADF«&G also identified
Kadake Creek, the largest salmon producer on Kuiu Island, as a primary sportfish
producer and one of 19 “high value” watersheds in Southeast Alaska for sportfishing. ^
Despite this ranking and the Forest Service’s decision in 1997 to recommend 23 miles of
Kadake Creek as a recreational river under the Wild and Scenic River Act because of its
high historic, recreation, and fisheries values, the action alternatives propose logging
between another 124 acres (Alternative 2) and 283 acres (Preferred Alternative) in this
valuable watershed .
Given the extent of previous management activities in the project area watersheds, both
NEPA and TLMP require the Forest Service to prepare watershed analyses to evaluate
^ direct, indirect, and cumulative effects. The revised Forest Plan states that “[wjatershed
analysis shall use the basic framework relating to aquatic resources and riparian resources
as described in: ‘Ecosystem Analysis at the Watershed Scale: Federal Guide for
Watershed Analysis’ (August 1995).” Revised TLMP at J-1. The “basic watershed
analysis” presented in Chapter 3 and Appendix C of the DEIS, as well as in the Kuiu
Island Landscape Assessment, provide little more than descriptions of existing data;
analysis or interpretation of referenced data is completely lacking. For example, the
DEIS notes that “[d]ata for Kadake Creek were excerpted from an unpublished report
prepared in 1994 by the Forestry Sciences Laboratory in Juneau.” DEIS, Appendix C at
^ C-24. This reference must refer to the Kadake Pilot Watershed Analysis Report (1994),
which followed the format of the Federal Guide, in support of the Anadromous Fish
Habitat Assessment (1995). Although the assessment is listed as a reference in the DEIS,
the Kadake Pilot Watershed Analysis Report is not. Please clarify whether the referenced
assessment includes this pilot watershed analysis. If it does not, please include it m the
administrative record for this project. For the record, we note this pilot watershed
analysis emphasized the need for field verification during project planning and identified
“common verification needs,” including stream channel stability, riffle stability,
streamflow, and macroinvertebrate sampling. See Kadake Pilot Watershed Analysis
Report at 7-10, 11,7-13, 14.
While the Federal Guide and TLMP intended a systematic analysis of a watershed’s
features, conditions, processes and mteractions, the discussion in the DEIS is little more
than a sediment risk analysis. Although an evaluation of the effects of logging and road
building on sediment production is an important factor for assessing direct, indirect and
cumulative effects to watershed resources and fish habitat, it focuses on effects of flows
on stream channel equilibrium. By doing so, the evaluation completely ignores the
potential adverse cumulative effects to salmon and aquatic resources from the long-term
^ reduction in summer low streamflows resulting from logging. See Hicks, et al., at 224-
^ See USDA, Forest Service. 2003. Tongass Land Management Plan Revision, Final Supplemental
Environmental Impact Statement. Roadless Area Evaluation for Wilderness Recommendations, Appendix
C, Vol. I at C-379.
SEACC Comments on Kuiu DEIS Page 6
March 20, 2006
104 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #7 - SEACC
3EACC
4d cont.
5EACC
4e
5EACC
4f
5EACC
4g
5EACC
5
225 (199 la). Although the DEIS considers the effect of logging on water jdeld, this
analysis focuses on peak flows; neither the DEIS nor watershed analyses consider
baseflows and the possible long-term reduction in summer flows in assessing cumulative
watershed risks and risks to the project area’s valuable fishery resources. Consequently,
no assessment is made regarding the effects of logging on low flows. It is also unclear
whether the standard for “hydrologic recovery” used in the DEIS incorporates these
>^effects or not. The narrow scope of the watershed analyses is insufficient to adequately
identify, evaluate, and disclose the direct, indirect and cumulative effects of timber
development activities on watershed functions, resources, and uses as required by TEMP,
the National Forest Management Act (NFMA), the Clean Water Act, and NEPA.
We also specifically question the adequacy of the cumulative effects analysis for the
Kadake watershed. For example, when assessing stream channel condition, the DEIS
limits its analysis to the main stem of Kadake Creek. See DEIS, Table 3-48 at 3-122.
The fork of Kadake Creek, however, most directly affected by the proposed alternatives
is the West Fork, not the main stem. According to the Kadake Pilot Watershed, the
subwatersheds on the West Fork have the highest natural sensitivity and the highest
natural potential risk of sediment production. Kadake Pilot Watershed Analysis Report at
5-54, 6-12. As a result, the DEIS fails to provide a hard look at the effects of the action
alternatives on the West Fork of Kadake Creek because direct and cumulative effects are
masked by focusing the description and effects analysis in the DEIS on the entire Kadake
watershed.
The DEIS also identifies a variety of mitigation measures to address the cumulative
^watershed effects in the project area. Absent fi-om this hst is the non-system road in the
West Fork watershed, off of Forest Road 6416. According to the 1994 pilot watershed
analysis, this temporary road “failed directly into a Class III stream immediately,
upstream of Class I habitat.” Kadake Pilot Watershed Analysis Report at 5-47. Please
^clarify the status of restoration work on this road.
V. Removal of Fill from Temporary Roads Required
The DEIS explains that shot rock will be used as fill “[wjhere temporary roads will cross
wetlands.” DEIS at 2-7. To qualify for an exemption under Section 404, however,
construction of the proposed temporary roads in the Kuiu sale must comply with the
baseline provisions contained in the Corps of Engineers’ regulations. See 33 C.F.R. §
323.4(a)(6). These regulations explicitly require removal “in their entirety” of all
temporary road fills and restoration of the area to its original elevation. Id. at §
323.4(a)(6)(xv).
According to the DEIS, the Forest Service will “decommission” the temporary roads by
removing drainage structures and constructing additional water bars. See DEIS at 2-21.
The Forest Service does not commit to removing the fill from these temporary roads as
required by the Corps’ regulations. Therefore, the Forest Service has not demonstrated
This study is listed in the references of Chapter 4 of the DEIS.
SEACC Comments on Kuiu DEIS Page 7
March 20, 2006
Kuiu Timber Sale FEIS
Appendix C • 105
Comment Letter #7 - SEACC
SEACC
6
that construction of these roads will comply with the baseline conditions specified in the
Corps’ regulations for exemption of temporary roads from Section 404.
VI. Log Transfer
The DEIS states that either the Saginaw log dump or Rowan Bay barge facility may be
used. While reconstruction of the Saginaw dump is required, the Rowan Bay facility is in
good condition. DEIS at 3-186, 3-220. Although the Forest Service reports the extent of
existing bark accumulation at both sites, no effort is made to describe specifically the
existing marine environment or the status of recovery of these waterbodies. Both
waterbodies were previously hsted as “impaired” because of excessive bark
accumulations. Although the Alaska Department of Environmental Conservation has de-
listed the waters, that decision was premised on the reduction of existing bark
accumulations below an arbitrary one-acre threshold, not on whether this water quality
limited segment will provide for the protection and propagation of a balanced population
of shellfish, fish, and wildlife, and allow recreational activities in and on the water. To
comply with NEPA, the Forest Service must provide current data describing the existing
condition of the areas previously used for log dumping and storage and assess the effects
fi’om the discharge of any additional bark at the Saginaw site on the recovery process.
The Forest Service should also consider other alternatives for reconstructing this dump,
including the shot-rock fill ramp design. A design like this could support a barge loading
ramp and avoid further degradation of the marine waters of Saginaw Bay. Without
providing specific information regarding beach slope and water depth, however, it is
^^mpossible for the public to determine if such a design is reasonable.
Thank you for your careful consideration of these comments.
Best regards.
Buck Lindekugel
Conservation Director
SEACC Comments on Kuiu DEIS Page 8
March 20, 2006
106 • Appendix C
Kuiu Timber Sale FEIS
Response to SEACC
SEACC - 1a
Refer to OVK-1 and MAJ-6.
SEACC -1b
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
SEACC - 2
The microsale program on Prince of Wales Island referenced in the comments is a
program set up for the microprocessors and individuals from the numerous communities
located around that island. Although microsales could be offered, Kuiu Island does not
have the same level of community development as Prince of Wales, and without this
community structure it is unlikely the same demand will exist for minor amounts of down
or dead trees from the existing road system.
Due to the expense of mobilization to and from Kuiu Island, lack of any local processing
facilities, and the distance to established processing facilities, it is unlikely that an
operator will be interested in purchasing timber sale offerings with volumes less than
1,000 MBF from this Project Area (DEIS Chapter 3 p.3-105 and the FEIS Chapter 3 -
Timber Sale Economics section).
SEACC - 3a
The scale of analysis reflects the resource that is being analyzed. Deer habitat is analyzed
by WAA and Project Area for historic, present, and proposed future conditions (DEIS
pp.3-54 - 3-57), and island-wide deer densities are analyzed as prey species to support
wolf populations (DEIS p. 3-68).
Road densities are analyzed on a WAA basis below 1200’ elevation for wolf (DEIS p. 3-
68) and in the Project Area for black bear hunting pressure.
The information has been presented for historic, current and proposed future conditions
in most cases, and can be found throughout the document.
SEACC - 3b
The multiplier used in the Kuiu DEIS is 100 deer/sq-mile for an HSI of 1.0 as noted in
the Tongass National Forest Annual Monitoring & Evaluation Report for Fiscal Year
2000 p. 2-155 and the Emerald Bay Appeal No. 06-10-00-0002 Southeast Alaska
Conservation Council et al.
Kuiu Timber Sale FEIS
Appendix C • 107
Response to SEACC
In 1996, an interagency group of biologists met to review and discuss the deer model in
use at the time. One recommendation from the group was that HSI scores be modified,
and subsequently deer model scores were adjusted (from a range of 0 to 1 .0) to a range of
0 to 1.3, with the highest score (as in the previous model) assigned to south-facing, low
elevation, low snow level, high-volume old growth stands. This information is
documented in the Tongass Plan FEIS (Part 1 , pp. 3 - 367 - 3 - 368). The carrying
capacity (deer/square mile) multiplier that equates to an HSI score of 1.0 has been
adjusted several times. Based on information supplied by research, the latest adjustment
equates 100 deer/square mile with an HSI score of 1.0 (TNF 2000 Annual Monitoring
and Evaluation Report released in April 2001 and instructions provided on the deer
model spreadsheet). The Eorest Service has no documentation to support the assertion
that the 100 deer/square mile carrying capacity was intended to match an HSI score of
1.3.
SEACC - 3c
The deer harvest information is reliant on hunters reporting the location and the number
of animals harvested; therefore, the estimated hunter demand may underestimate the
actual demand and attempts to bridge this information gap have been made. See
Response to OVK 4.
SEACC - 3d
The comments on the Doerr 1995 results have been noted.
The FEIS has been corrected to say:
Historic partial harvest treatments (50 percent retention) on the Tongass National
Eorest studied by Bob Deai (2001) show that these treatments could provide deer
food and habitat better than clearcut treatments. The light (1-25% BA) and
medium (26-50% BA) cutting intensity plots were similar to the uncut plots for
both the recently harvested and older sites, and they 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 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 forests of Southeast Alaska appear to be resilient to
moderate ranges of partial cutting (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). (See
Response to ACMP for further information).
The DEIS (p. 3-51) discussed the values of partial harvest as deer and moose forage areas
rather than retaining winter range. Additional information on how these areas may
function as corridors for a longer time period than traditional clearcuts has been added to
the Wildlife section of Chapter 3 in the EEIS.
108 • Appendix C
Kuiu Timber Sale FEIS
Response to SEACC
SEACC - 3e
The figure was meant to show changes from the current condition and does not include
harvest of the proposed unit pool. The unit pool has been removed and ‘From Current
Condition’ has been added to the title to clarify Figure 3-6.
SEACC - 3f
See Response to OVK 4.
SEACC - 4a
Within the Recreational River corridor of Kadake Creek, Alternative 2 proposes to
harvest 18 acres and Alternative 4 proposes to harvest 49 acres. Both silvicultural
prescriptions call for 50% retention of the basal area (DEIS Appendix B, p.B-82 and B-
84).
The proposed activities are not expected to significantly affect sportfishing in Kadake
Creek due to buffers and the implementation of BMPs. The proposed project is
consistent with management of Kadake Creek as a Recreational River under the Wild and
Scenic River Act. (Public Law 90-542, as amended; 16 U.S.C. 1271-1287). The Forest
Plan (p. 3-112) permits timber harvest on suitable timber lands if adjacent lands are being
managed for that purpose in accordance with the standards and guidelines for the stated
VQOs. See GSS-41 for further discussion.
SEACC - 4b
The content of the watershed analysis does follow the basic framework outlined in
Ecosystem Analysis at the Watershed Scale, even though it is presented in a different
format. Notably, the watershed analysis addresses all core topics identified in Ecosystem
Analysis at the Watershed Scale: Federal Guide for Watershed Analysis' (August 1995)
including: erosion processes, hydrology, vegetation, stream channels, water quality,
species and habitats, and human uses. The six step process outlined in Ecosystem
1 ) Characterization of the watershed,
2) Identification of issues and key questions,
3) Description of current conditions,
4) Description of reference conditions,
5) Synthesis and interpretation of information, and
6) Recommendation
All six of these steps can be identified in the watershed analysis with the exception of
Identification of key questions.
SEACC - 4c
The Pilot Watershed Analysis Report for the Kadake Creek Watershed was used as a
general reference. It was not included in the planning record for the project or the list of
references in Chapter 4 because it was not cited specifically in the FEIS or the reports
prepared for the DEIS.
Kuiu Timber Sale FEIS
Appendix C • 109
Response to SEACC
SEACC - 4d
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. The results of the study by Hicks et al. are not conclusive
enough to be broadly applied.
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 that the
change could be due to climatic cycles, not timber harvest (US Geological Survey 2000).
SEACC - 4e
The level of detail in the analysis of watersheds in the Kuiu Timber Sale Project Area is
based on direction in the Forest Plan. The Forest Plan (USDA Forest Service, 1997), in
Appendix J, defines the core topics of the watershed analysis, and guides the scale and
intensity of the analysis. The scale, intensity, and complexity of watershed analysis is to
be commensurate with the level of cumulative risk.
SEACC - 4f
Watershed delineation and identification is described in the DEIS on page C-2. The
Tongass National Forest recognizes the US Geological Survey (USGS) hierarchical
watershed mapping and numbering system. For the sake of consistency, all watersheds
analyzed for the Kuiu Timber Sale project, including the Kadake Creek Watershed,
correspond to the 6^’’ level hydrologic unit code (HUC).
SEACC - 4g
The restoration work is outside the scope of this project and has not been completed at
this time. It has been incorporated into the Watershed Restoration Plan (WRP) for the
Kadake Creek Watershed as a possible watershed improvement project. Watershed
Restoration Plans are internal documents used to compete for funds that are allocated
across the Tongass for watershed stewardship projects. The WRP for the Kadake Creek
Watershed is expected to be complete in Fiscal Year 2007. Implementation of the
restoration work in the WRP will depend upon the project proposal competing favorably
with other restoration project proposals.
SEACC - 5
The DEIS does not characterize temporary roads as “temporary fills.” Temporary roads
are defined in the glossary of the DEIS. The use of the road is temporary, but the
footprint (fill) is not. This is why the effects of temporary roads are included in the
DEIS. Temporary roads used in the past are shown as “decommissioned roads” in Figure
C- 1 . The Forest Service decommissions temporary roads by removing drainage
structures, constructing water bars and blocking the entrance to motorized traffic. These
measures adequately “decommission” the road to allow natural conversion back to the
original state: i.e. timber growth on the road footprint. In their memo of February 10,
110 • Appendix C
Kuiu Timber Sale FEIS
Response to SEACC
2006, commenting on the DEIS (included in this appendix), the Corps of Engineers
concurred that . .all temporary roads proposed for this project are exempt from Clean
Water Act permitting, provided they are constructed according to best management
practices...” These best management practices have been incorporated into BMP 12.5
(ESH 2509.22) and they will be implemented on all roads constructed for the Kuiu
Timber Sale.
SEACC - 6
The status of the LTFs can be found in the DEIS (p. 3-181).
A description of the existing marine environment conditions of the LTFs can be found in
the DEIS (p.3-186).
Descriptions of both the Rowan Bay LTF and Saginaw Bay LET, as well as the location,
size, and condition of the sort yards can be found in the DEIS on page 3-220.
Kuiu Timber Sale FEIS
Appendix C • 1 1 1
Comment Letter #8 - The Committee on Conservation of
Forests and Wildlife - CCFW
March 20, 2006
Kris Rutledge - Team Leader
Attn: Kuiu Timber Sale
USDA Forest Service
P.O. Box 1328
Petersburg, AK 99833
RE: Kuiu Timber Sale
Dear Ms. Rutledge,
THE COMMITTEE ON CONSERVATION
OF FORESTS AND WILDLIFE
230 CAMPFIRE ROAD. CHAPPAQUA, NY 10514
TEL. (914)941-0199
Hunters and anglers consider ourselves to be the original conservationists. One of our
heroes was President Theodore Roosevelt, who created the Tongass National Forest back
in 1907. The Tongass is the largest of our national forests, and represents a substantial
portion of the largest remaining temperate rainforest on the planet.
CCFW
1
It is disturbing to see the Forest Service continue to move ahead with timber sales in
primitive areas of the Tongass when the current forest plan has been deemed illegal and a
new plaiming process is in its beginning stages'
CCFW
2
That is why we are especially troubled to see the plans for the 1,425-acre Kuiu sale. To
date, over 28,000 acres of forest have been cleareut on Kuiu Island. North Kuiu Island is
already heavily impacted, with significant habitat fragmentation due to roads and
clearcuts. Kuiu Island holds many areas and species that are important to sportsmen and
women both inside Alaska and around the country.
Kuiu is perhaps most famous for its record-class black bears. A study by the Alaska
Department of Fish and Game found that Kuiu is home to one of the highest densities of
black bear in North America. 21 Boone & Crockett record book black bears have been
taken on Kuiu Island, ranking only behind much-larger Prince of Wales Island in number
of Alaska trophies. In fact, on a per-acre basis, Kuiu has historically produced a higher
number of trophy black bears than Prince of Wales. Approximately 80% of the black
bear hunters on Kuiu are not Alaska residents, but they do support the seven guide-
outfitters that hold special use permits to hunt on Kuiu as well as bring signifieant
financial benefits to other Alaska businesses through their expenditures on transportation,
lodging, groceries, equipment, and supplies. The Draft Environmental Impact Statement
for this proposed sale states “These businesses depend on the consistent population level
of blaek bears on northern Kuiu Island. Any decrease in population would decrease
income, and could possibly put outfitter/guides out of business if populations dropped
1 12 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #8 - The Committee on Conservation of
Forests and Wildlife - CCFW
low enough.” The growth of logging roads on northern Kuiu Island has increased hunter
access which has led to more restrictions including quotas on bear harvest. Incidentally,
since the road system has had increasing impact on the habitat of northern Kuiu Island,
QQpyy the trends seem to show average harvest levels and skull size of black bears have
3 Ldecreased.
CCFW
4
Other game species on Kuiu include Sitka black-tailed deer (which have seen a drastic
population decrease on Kuiu due to loss of much of the coarse-canopy old growth habitat
jnost capable of supporting deer during the winter months), moose, and wolves. The
heads of Security and Saginaw Bays, which would be impacted by the proposed timber
sale, are important areas for waterfowl hunting, supporting several guiding operations.
Waterfowl and black bear hunting also occur throughout Kadake Bay.
This proposed timber sale would impact 7 watersheds and the associated road
construction could involve as many as 42 stream crossings. The affected watersheds
have already experienced harvest levels ranging from 8.2% to 31.3%. Further logging
QQpyy r^d roading in these watersheds would only serve to increase the negative effects on
5 [these waters and fish populations.
The Kadake Creek watershed is the largest producer of steelhead and salmon on Kuiu
Island and is used by sportfishermen (especially for coho) more than any other stream on
the island.
The Dean Creek watershed holds coho, pink, and chum salmon as well as Dolly Varden.
The Rowan Creek watershed holds coho, chum, and pink salmon as well as Dolly Varden
and cutthroat.
The Saginaw Creek watershed holds coho, pink, and chum salmon as well as steelhead,
Dolly Varden, and cutthroat.
Watershed # 109-44-10370 (unnamed) holds coho, pink, and chum salmon as well as
Dolly Varden and steelhead.
Watershed # 109-45-10090 (unnamed) holds coho and pink salmon as well as Dolly
Varden.
Six anadromous fish streams drain into Rowan Bay v^dth Rowan Creek and Brovm’s
Creek being the greatest producers.
Five anadromous fish streams drain into Saginaw Bay with Saginaw Creek and Straight
Creek being the greatest producers.
To imagine an island with so many fish-producing streams (and to think that some of the
streams are not even named!) and high populations of record-class black bears is to
Kuiu Timber Sale FEIS
Appendix C • 113
CCFW
6
CCFW
7
CCFW
8
Comment Letter #8 - The Committee on Conservation of
Forests and Wildlife - CCFW
dream of the wild Alaska that sportsmen around the country wish to visit once in their
lifetime.
Given that this is a national forest of extremely high value to hunters and anglers, it is
^disappointing that the Forest Service continues to spend millions of taxpayer dollars on
timber projects that end up losing money for the federal treasury. Using the official
agency planning figure of $ 150,000/mile, the 19 miles of possible new road in this
project would cost the American taxpayer up to an estimated $2,850,000. Additional
costs to re-construct another 6.9 miles of road would add to that estimated total.
'^Hunters and anglers would rather see the Forest Service work toward establishing a
timber industry in the Tongass that focuses more on second-growth harvest with less
emphasis placed on high-grading the dwindling remaining old-growth reserves which are
most important for fish and game habitat. By building fewer roads, more funds could be
devoted toward the thinning of second growth ‘dog hair’ forests so these stands come
back as good wildlife areas, the maintenance backlog on the existing road system and the
Repair of culverts that presently impede fish passage on many streams.
We respectfully request that the Forest Service cancel the proposed Kuiu timber sale and
divert the funds to the above forest restoration purposes. You can get the same amount of
jobs in forest restoration as you can by ruining the existing backcountry that is so
important to hunting and fishing and the guiding industry. Thank you very much for
considering our comments on this matter.
Leonard J. Vallender
Chairman, Conservation Committee of Forest & Wildlife
114 e Appendix C
Kuiu Timber Sale FEIS
Response to CCFW
CCFW - 1
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
The Tongass National Forest will continue to be managed in compliance with Section
101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which ( 1 ) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
As described more fully in Appendix A of the DEIS, to provide a steady flow of timber
harvest volume, timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
CCFW - 2
Concern over the acres of clearcuts on Kuiu Island is noted. Note, however, that the
27,856 acres harvested are located on an island 482,101 acres in size of which 64 percent
is in non-development LUDs (Kuiu Island Landscape Assessment). Less than six percent
of the island has been harvested and less than five percent of the major watersheds
include any harvest.
The proposed harvest would have minimal effects to the recreation activities on the island
since they are proposed in areas of previous harvest and mostly roaded areas (DEIS, pp 3-
240 to 3-250).
CCFW - 3
The DEIS p. 3-63 confirms that the Alaska Department of Fish and Game believe the
black bear population on Kuiu Island is stable, and skull measurements have remained
relatively stable with the skull measurements averaging 18.6 inches. It is not the logging
roads that have led to the restrictions but rather the number of hunters. Most of the
logging roads were already in place when the hunting pressure on Kuiu Island began to
escalate in the early 1990’s (DEIS p. 3-81, Table 3-27.) Due to concerns over the steadily
increasing harvest of black bears by nonresident hunters, the Board of Game established a
nonresident harvest guideline of 120 bears per year on Kuiu Island (DEIS p. 3-84).
CCFW-4
The DEIS p.3-50 and the FEIS Chapter 3 Wildlife Habitat section relate the deer crash to
severe winter weather in the late 1960’s and early 1970’s rather than to loss of coarse-
Kuiu Timber Sale FEIS
Appendix C • 115
Response to CCFW
canopy old-growth habitat (at that time timber harvest had occurred on less than two
percent of the island). It should be noted that the era of heaviest logging occurred
between 1970 and 1989 after the deer crash and after these two decades of logging, deer
populations continue to climb to a point that hunting was reopened in 1992. Although
hunting limits remain low and hunting effort is high, it should be recognized that in the
years of the deer crash, less than 4000 acres (8.7%) of the Project Area had been
harvested and less than 7000 acres ( 1 .4%) of the island had been harvested.
It should also be noted that deer herds which crashed at the same time on the much
heavier logged, roaded, and populated Prince of Wales Island have returned in much
larger numbers than those on Kuiu. It must therefore be assumed that factors other than
timber harvest alone are restricting the deer from reaching historic population levels.
These other factors include the heavy predation from large populations of black bear and
wolves (see the Wildlife section in Chapter 3 of the FEIS).
There are no activities planned within Security Bay or Kadake Bay in the Kuiu Timber
Sale FEIS, therefore no impacts to these areas are anticipated.
While Security and Saginaw Bays are important waterfowl hunting areas, waterfowl
hunting is just an incidental part of guiding operations on Kuiu Island.
CCFW -5
Of the 42 stream crossings, there are two proposed Class II stream crossings by NES road
construction, and two Class I and three Class II stream crossings on existing Road 6417
that is currently in storage. All other stream crossings are on non-fish bearing streams.
Best Management Practices identified in the DEIS (Appendix B pp. B-7 - B-9) will be
applied to protect water quality where appropriate.
The DEIS (p. 3-182) acknowledges that there will be an increase in sedimentation from
road construction; however, this effect is expected to meet state water quality standards.
The placement of stream buffers and the implementation of BMPs (DEIS Appendix B pp.
B-7 - B-9) is expected to minimize the amount of sediment entering streams.
Construction timing windows for stream crossings on roads proposed for reconditioning
or storage will be implemented (DEIS p. 3-175). While individual fish may be impacted,
the population as a whole is not expected to be affected.
CCFW-6
The cost of temporary road construction is the responsibility of the purchaser. Forest
Service Handbook direction (FSH 2409.18) directs that a financial evaluation of
alternatives be done for each alternative based upon the appraisal system used to establish
the value of timber sales (FSH 2409.22). The accepted procedure for determining the
value of timber in a timber sale is to estimate the value of the finished products and
subtract all of the costs associated with producing the finished products. Some of these
costs are timber falling, logging, hauling, towing, and road construction.
116* Appendix C
Kuiu Timber Sale FEIS
Response to CCFW
Temporary roads were looked at again in the FEIS and some miles of road were
reclassified as NFS road. The proposed action in the FEIS proposes 6.5 miles of new
NFS road construction with an estimated cost of $170, 000/mile. Additionally, there are
3.9 miles of temporary road construction with an estimated cost of $1 10,000/mile. The
total estimated cost of this road construction is $1,534,000. The cost to re-construct the
NFS road in the Kuiu Timber Sale Area is estimated to be an additional $122,000.
CCFW-7
The Tongass is moving towards providing second-growth timber for industry. Currently,
very few second-growth stands are of a commercial size. Prior to the 1950s there was
only scattered timber harvest on the Tongass. Beginning in the late 1950s two long-term
timber harvest contracts were offered and larger scale harvesting operations were started,
resulting in the conversion of old-growth stands to second-growth stands. The majority
of these second-growth stands are not yet large enough to provide commercial
opportunities. While some second-growth harvest is being investigated in Southeast
Alaska, most of this harvest has been near communities with mills where it is more
economical to harvest second-growth timber. The second-growth timber on Kuiu is
marginal in size for harvest and process, and it is estimated to be another 10 to 20 years
before the oldest of the stands on Kuiu are large enough to provide commercial
opportunities.
The DEIS pp. 3-158 - 3-159, and the FEIS Chapter 3 Timber and Vegetation section
show that the volume strata in the planning area is roughly 78 percent high volume, 18
percent medium volume and 2 percent low volume. All action alternatives would harvest
between 77-83 percent high volume, 13-19 percent medium volume and 2-4 percent low
volume, well within a range of variability which duplicates the existing volume strata
within the planning area.
The Forest Service currently has an active pre-commercial thinning program in most
second-growth stands to enhance growth potential and improve wildlife habitat
capabilities and has precommerically thinned 4,700 acres of second growth stands in the
Project Area. The Forest Service is investigating the replacement or removal of culverts
that impede fish passage on a Forest-wide basis. The proposed timber sale action would
remove two of these culverts.
For discussion on the funding of roads, see the response to CCFW-6.
Funds for the Forest Service are allocated by Congress, and the amount of money
allocated to each resource is beyond the scope of this project. It would be irresponsible
to use money allocated for one project to fund another project.
CCFW-8
The request to cancel the proposed Kuiu timber sale has been noted. To divert the funds
from one resource, such as timber, to another resource, like restoration, is beyond the
scope of this project.
Kuiu Timber Sale FEIS
Appendix C • 117
Response to CCFW
There are many different perceptions of “backcountry”; however, much of the planning
area has been selected in the Forest Plan for timber development (DEIS 1-5 to 1-7 and
FEIS Chapter 1 Forest Plan Land Use Designations section). Much of the infrastructure
(roads) in the planning area already exist, and the area has had past harvest. The area does
not fit the typical definition of bacTcountry.
118* Appendix C
Kuiu Timber Sale FEIS
Comment Letter #9 - Chico Area Fly Fishers - CAFF
"Roger Severs"
<rogerbevers@hotmail .com>
03/15/2006 08:13 AM
To krutledge@fs.fed.us
vbowlby@digitalpath.net, nomopilz@aol.com,
lincoln@tie-fast.com, silvermagi@hotmail.com,
cc danamallard@excite.com, esee@comcast.net,
dnsleeper@yahoo.com, lwvalley@yahoo.com,
gencnsl@aol.com
bcc
Subject Kuiu timber Sale
March 20, 2006
Kris Rutledge - Team Leader
Attn: Kuiu Timber Sale
USDA
Forest Service
P.O. Box 1328
Petersburg, AK 99833
RE: Kuiu Timber Sale
Dear Ms. Rutledge,
CAFF
1
CAFF
2
The Chico Area Fly Fishers has members that fish in Alaska often. We enjoy the pristine forests,
rivers and streams and feel that the sale of this timber deal goes contrary to the best interest of
the environment. If there is any pertinent information we have not considered about this timber
sale, we would like to be informed and kept abreast of the progress. Please email us at the clubs
r-above email address or you can email me at: rogerbevers@hotmail.com. The cutting of roads
through the landscape into the forest just to harvest timber is not in the best interest of the future
generations of Americans.
^^aska is the only frontier left in the entire U.S. and maintainence to the namral state of the
environment is of prime concern for everyone. We welcome your input on this topic. We don't
Svant to be one sided, but we defmately will need to be convinced that this is good for the entire
Island as well as the whole of Alaska. Therefore, we support the letter below and wish to be
involved in the future development of plans.
Sincerely,
Roger Bevers President
Chico Area Fly Fishers
chicoareafl vfishers @ sbc global .net .
Dear Ms. Rutledge,
Kuiu Timber Sale FEIS
Appendix C • 119
Comment Letter #9 - Chico Area Fly Fishers - CAFF
CAFF
3
CAFF
4
CAFF
5
CAFF
6
CAFF
7
Hunters and anglers consider ourselves to be the original conservationists. One of our heroes
was President Theodore Roosevelt, who created the Tongass National Forest back in 1907. The Tongass is the
largest of our national forests, and represents a substantial portion of the largest remaining temperate rainforest on the planet
It is disturbing to see the Forest Service continue to move ahead with timber sales in primitive
areas of the Tongass when the current forest plan has been deemed illegal and a new planning
process is in its beginning stages.
T^hat is why we are especially troubled to see the plans for the 1,425-acre Kuiu sale. To date,
over 28,000 acres of forest have been clearcut on Kuiu island. North
Kulu Island is already heavily impacted, with significant habitat fragmentation due to roads and clearcuts Kuiu Island holds many
areas and species that are important to sportsmen and women both inside Alaska and around the country
Kuiu is perhaps most famous for its record-class black bears. A study by the Alaska Department
of Fish and Game found that Kuiu is home to one of the highest densities of black bear in North
America. 21 Boone & Crockett record book black bears have been taken on Kuiu Island, ranking only behind muchlarger Prince of
Wales Island in number of Alaska trophies In fact, on a per-acre basis, Kuiu has historically produced a higher number of trophy
black bears than Prince of Wales Approximately 80% of the black bear hunters on Kuiu are not Alaska residents, but they do
support the seven guide-outfitters that hold special use permits to hunt on Kuiu as well as bring significant financial benefits to
other Alaska businesses through their expenditures on transportation, lodging,
groceries, equipment, and supplies The Draft Environmental Impact Statement for this proposed sale states "These businesses
depend on the consistent population level of black bears on northern Kuiu Island Any decrease in population would deaease
income, and could possibly put outfitter/guides out of business If populations dropped low enough." The growth of logging roads
on northern Kuiu Island has Increased hunter access which has led to more restrictions including quotas on bear harvest
Incidentally, since the road system has had inaeasing impact on the habitat of northern Kuiu
Island, the trends seem to show average harvest levels and skull size of black bears have decreased
Other game species on Kuiu include Sitka black-tailed deer (which have seen a drastic population deaease on Kuiu
due to loss of much of the coarse-canopy old growth habitat most capable of supporting deer during the winter months, moose,
and wolves. The heads of Security and Saginaw Bays, which would be impacted by the proposed timber sale, are important areas
for waterfowl hunting, supporting several guiding operations Waterfowl and black bear hunting also occur throughout Kadake
Bay.
This proposed timber sale would impact 7 watersheds and the associated road construction could
involve as many as 42 stream crossings. The affected watersheds have already experienced
harvest levels ranging from 8.2% to 31.3%. Further logging and roading in these watersheds
.would only serve to increase the negative effects on these waters and fish populations.
The Kadake Creek watershed is the largest producer of steelhead and salmon on Kuiu island and is
used by sportfishermen (especially for coho) more than any other stream on the island
The Dean Creek watershed holds coho, pink, and chum salmon as well as Dolly Varden
120 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #9 - Chico Area Fly Fishers - CAFF
The Rowan Creek watershed holds coho, chum, and pink salmon as well as Dolly Varden and
cutthroat.
The Saginaw Creek watershed holds coho, pink, and chum salmon as well as steelhead, Dolly
Varden, and cutthroat.
Watershed # 109-44-10370 (unnamed) holds coho, pink, and chum salmon as well as Dolly
Varden and steelhead.
Watershed # 109-45-10090 (unnamed) holds coho and pink salmon as well as Dolly Varden.
Six anadromous fish streams drain into Rowan Bay with Rowan Creek and Brown's Creek being the greatest
producers.
Five
anadromous fish streams drain into Saginaw Bay with Saginaw creek and straight Creek being the greatest producers
To imagine an island with so many fish-producing streams (and to think that some of the
streams are not even named!) and high populations of record-class black bears is to dream of the
wild Alaska that sportsmen around the country wish to visit once in their lifetime
CAFF
8
Given that this is a national forest of extremely high value to hunters and anglers, it is
disappointing that the Forest Service continues to spend millions of taxpayer dollars on timber
projects that end up losing money for the federal treasury. Using the official agency planning
figure of $ 150,000/mile, the 19 miles of possible new road in this project would cost the
American taxpayer up to an estimated $2,850,000. Additional costs to re-construct another 6.9
miles of road would add to that estimated total.
CAFF
9
Hunters and anglers would rather see the Forest Service work toward establishing a
timber industry in the Tongass that focuses more on second-growth harvest with less emphasis
placed on high-grading the dwindling remaining old-growth reserves which are most important
for fish and game habitat. By building fewer roads, more funds could be devoted toward the
thinning of second growth ‘dog hair’ forests so these stands come back as good wildlife areas,
the maintenance backlog on the existing road system and the repair of culverts that presently
impede fish passage on many streams.
Kuiu Timber Sale FEIS
Appendix C • 121
Comment Letter #9 - Chico Area Fly Fishers - CAFF
We respectfully request that the Forest Service cancel the proposed Kuiu timber sale and divert
Q/i^pp I the funds to the above forest restoration purposes. You can get
1 0 the same amount of jobs in forest restoration as you can by ruining the existing backcountry that
is so important to hunting and fishing and the guiding industry. Thank you very much for
considering our comments on this matter.
Sincerely,
Roger Severs President
Chico Area Fly Fishers
P.O. Box 3583
Chico, California 95927
122 • Appendix C
Kuiu Timber Sale FEIS
Response to Chico Area Fly Fishers - CAFF
CAFF - 1
The Forest Service puts out timber sales because of a legal requirement from Congress.
Section 101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the
Alaska National Interest Lands Conservation Act (ANILCA) states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which (1) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
The Kuiu Timber Sale planning area is currently well roaded and would only require
construction of between 3.3 and 10.4 miles of roads to implement.
CAFF - 2
The Forest Service is a multiple-use agency and one mandate is to produce timber.
Maintaining the natural state of the Tongass National Forest is also a prime concern. Of
the approximately 17 million acres on the Tongass National Forest, 78 percent is
Wilderness or designated as Natural Setting. On a state-wide basis ANILCA has
designated Wilderness across the state and looks out for the national interests of the
public.
CAFF - 3
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
The Tongass National Forest will continue to be managed in compliance with Section
101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which (1) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
As described more fully in Appendix A of the DEIS, to provide a steady flow of timber
harvest volume timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
CAFF - 4
Concern regarding the acres of clearcuts on Kuiu Island is noted. Note, however, that the
27,856 acres of harvest are located on an island of 482,101 acres, of which 64 percent is
in non-development LUDs (Kuiu Island Landscape Assessment). Less than six percent of
Kuiu Timber Sale FEIS
Appendix C • 123
Response to Chico Area Fly Fishers - CAFF
the island has been harvested and less than five percent of the major watersheds include
any harvest.
The proposed harvest would have minimal affect to the recreation activities on the island
since they are proposed in areas oY previous harvest and mostly roaded areas (DEIS, pp 3-
240 to 3-250).
CAFF - 5
The DEIS (p. 3-63) confinns that the Alaska Department of Fish and Game believes the
black bear population of Kuiu Island is stable, and skull measurements have remained
relatively stable with the skull measurements averaging 18.6 inches. It is not the logging
roads that have led to the restrictions but rather the number of hunters. The hunting
pressure on Kuiu Island began to escalate in the early 1990s (DEIS p. 3-81 Table 3-27)
long after a majority of the logging roads were already in place. Due to concerns over the
steadily increasing harvest of black bears by nonresident hunters, the Board of Game
established a nonresident harvest guideline of 120 bears per year on Kuiu Island (DEIS p.
3-84).
CAFF - 6
See CCFW-4 for information on the Sitka black-tailed deer population crash.
See OVK-4 for information on significant habitat to support subsistence needs for Sitka
black-tailed deer.
There are no activities planned within Security Bay or Kadake Bay in the Kuiu Timber
Sale FEIS, therefore no impacts to these areas are anticipated.
While Security and Saginaw Bays are important waterfowl hunting areas, there are no
guiding operations for waterfowl hunting on the Petersburg Ranger District.
CAFF - 7
Of the 42 stream crossings, there are two proposed Class II stream crossings by NFS road
construction, and two Class I and three Class II stream crossings on existing Road 6417
that is currently in storage. All other stream crossings are on non-fish bearing streams.
Best Management Practices identified in the DEIS (Appendix B pp. B-7 - B-9) will be
applied to protect water quality where appropriate.
The DEIS (p. 3-182) acknowledges that there will be an increase in sedimentation from
road construction and reconditioning; however, this effect is expected to be short-term
(clarified in the FEIS as 48 hours after construction). The placement of stream buffers
and the implementation of BMPs (DEIS Appendix B pp. B-7 - B-9) are expected to
minimize the amount of sediment entering streams. Road construction, installation of
culverts and bridges, and the removal of culverts is expected to temporarily increase
sediment delivery but is not expected to degrade fish habitat. Increased sediment may
affect individual fish by reducing oxygen levels to developing eggs in spawning gravels
and/or trapping of emerging fry in the gravel, the effect is expected to be short-term (48
124 • Appendix C
Kuiu Timber Sale FEIS
Response to Chico Area Fly Fishers - CAFF
hours or less) and the placement of timing restrictions will minimize impacts to fish (see
the road cards in Appendix B). The BMP implementation will achieve state water quality
standards.
CAFF - 8
Please see the response to CCFW - 6.
CAFF - 9
The Tongass is moving towards providing second-growth timber for industry. Currently
very few second-growth stands are of a commercial size. Prior to the 1950s there was
only scattered timber harvest on the Tongass. Beginning in the late 1950s two long-term
timber harvest contracts were offered and larger scale harvesting operations were started,
resulting in the conversion of old-growth stands to second-growth stands. While some
second-growth harvest is being investigated in Southeast Alaska, most of this harvest has
been near communities with mills where it is more economical to harvest second-growth
timber. The second-growth timber on Kuiu is marginal in size for harvest, and it is
estimated to be another 10 to 20 years before the oldest of the stands on Kuiu are large
enough to provide commercial opportunities.
Congress allocates funds to the Forest Service. The amount of money allocated to each
resource is beyond the scope of this project. The temporary roads proposed in the Kuiu
Timber Sale are funded by the purchaser, not the Forest Service.
The Forest Service currently has an active pre-commercial thinning program in most
second-growth stands to enhance growth potential and improve wildlife habitat
capabilities. The Forest Service is investigating the replacement or removal of culverts
that impede fish passage on a Forest- wide basis. The proposed timber sale action would
remove two of these culverts.
CAFF- 10
The request to cancel the proposed Kuiu timber sale has been noted. To divert the funds
from one resource, such as timber, to another resource, such as restoration, is beyond the
scope of this project.
Kuiu Timber Sale FEIS
Appendix C • 125
Comment Letter #10 - Sealaska
%
3
February 15, 2006
Patricia Grantham
Petersburg District Ranger
USDA Forest Service
P. O. Box 1328
Petersburg, AK 99833
Re: Kuiu Timber Sale Area Draft Environmental Impact Statement
Dear Ms. Grantham:
Sealaska
1
Sealaska Corporation is the regional Native Corporation for Southeast Alaska. Over
5,000 of our shareholders live throughout every community in this region. Therefore,
significant actions contemplated by the Forest Service may have a significant impact on
our shareholders as well as the greater Southeast community. Certainly one class of
significant actions includes the scheduling and volume of timber sale offerings from the
Tongass National Forest. For the benefit of the economy of Southeast Alaska it is very
important that the Forest Service offer viable timber sales to a much greater degree than
has been the case in the recent past. The lack of available stumpage has caused many
saw mills to go out of business much to the detriment of rural village economies.
Therefore, scheduling sales with sufficient economic volume is a very important Forest
Service responsibility because agency decisions have such a great impact on this region.
Sealaska recommends that Alternative 4 be implemented as presented because it best
meets all of the criteria that must be considered in the EIS process. This alternative
provides the greatest timber volume while protecting fish and wildlife habitat. The
increase in cumulative effects generated from the harvest of the volume being considered
can hardly be measured. In addition, if the Forest Service manages the future second
growth that will occur, it will benefit some of the wildlife populations in the future.
Alternative 1 is the least responsive to the needs of Southeast Alaska. It does not
equitably contribute to the requirements of TTRA. Alternative 2 provides so little timber
volume that maintaining such an extensive road system certainly would not support the
volume and costly harvest methods being considered. Alternative 3 is not that dissimilar
to Alternative 2 because the harvest units are very scattered. Alternative 5_.i.s moffi;;;^;;:; —
economic; however, the increased volume being considered in Alternative 4^j
the economic benefits from conventional harvest methods.
iT! ” S
'^1
1-)
i iuUU
T:/?
oio.,., c, ^ru-i . (..no.... M/- aoom _i 97C • /ar\7\ cDc_i Cl 7 • Cov ^^Qn■7^
126 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #10 - Sealaska
Kuiu Timber Sale DEIS
-2-
February 15, 2006
Thank you for considering the Sealaska recommendations.
Sincerely,
SEALASKA CORPORATION
Michele Metz
Assistant Lands Manager
cc: Ron Wolfe, Natural Resources Manager, Sealaska Corporation
Joe Donohue, ACMP Project Specialist, State of Alaska
Kuiu Timber Sale FEIS
Appendix C • 127
Response to Sealaska
Sealaska - 1
The recommendation that Alternative 4 be implemented as presented is noted.
128 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #1 1 - David Beebe
Beebe
1
Beebe
2
Beebe
3
Beebe
4
Beebe
5
David Beebe
<fvjerryo@mac.com>
03/19/2006 10:45 PM
To: comments-alaska-tongass-petersburg@fs.fed. us
cc:
Subject: Kuiu Timber Sale
Forrest Cole
Forest Supervisor
Tongass National Forest
Dear Sir,
I urge you to reconsider your efforts to harvest any more timber from N. Kuiu
Island. Aerial views of this landscape are the only way to grasp the
astonishing scale of extremes to which the Forest Service feels obligated,
espite the stated credo of Caring for the Land and Serving People.
It is hard not to reflect on Judge Gould's opinion in the recent ruling
regarding the Tongass Land Management Plan in which you Forrest Cole, along
with Dennis Bschor, and Mark Rey, were principal defendants. Judge Gould
found you all, and the Forest Service in general, guilty of implementing a
Forest Plan that was "fatally infected". Your legal defense attempted to
argue that projections of a market demand that was twice what it should have
^een was not significant.
That same infection persists in this timber sale that heaps more watershed
deconstruction upon Kuiu Island. One cannot care for the land and add to an
already staggering total of 27,856 acres of clearcuts in 78 major watersheds,
^ne of those watersheds has lost 60 percent of its integrity due to
clearcutting .
One cannot Care for the Land and systematically disassemble its constituent
components .
One cannot care for the land while disregarding the fact that the land and
its myriad inhabitants have evolved together over the last 10,000 years under
a multi-storied, uneven aged canopy. Yet your preferred alternative uses
^ven-aged clear cut management as the dominant harvest method.
One cannot care for the land with these harvest methods and pretend well
distributed, viable populations of oldgrowth dependent species will not
ultimately face genetic tipping points of no return, especially when tipping
>points are often realized only in retrospect.
What we do know is that high quality habitat is being fragmented into
increasingly diminishing oldgrowth reserves which simply get redefined as
corporate commodities in subsequent timber sales.
When mass wasting in the form of clearcut induced landslides is allowed in
Saginaw, Dean, Security, and other unnamed creeks, caring for the land will
always be questioned.
The mass wasting of taxpayer dollars funding systematic destabilization of
watersheds, fails to inspire visions of the " People" being served.
The people are clearly not being served when Environmental Impact Statements
must admit that irreversible and irretrievable consequences associated with
timber harvest will inevitably ensue. The people are not being served when
this agency blithely ignores the legacy of adjacent landholders and the
wholesale destruction of ancestral landscapes by native corporate boards.
Ignoring the impacts to subsistence needs of the residents of Kake is
'^tantamount to environmental racism. I must question, can this timber sale be
Kuiu Timber Sale FEIS
Appendix C • 129
Comment Letter #1 1 - David Beebe
regarded as "Serving People?"
The claim that this timber sale is serving people only makes sense if we
severely restrict the notion of what constitutes the "People". Within that
special group, George W. Bush comes to mind. Even prior to his election to
office by the Supreme Court, .lie never seemed to be able to turn a dime in the
resource extraction industry without making the "other" people pay dearly
while he engaged in the singular pursuit of greater wealth and power.
Mark Rey, President Bush's choice as head of the Forest Service, is surely
one of those special people being served. With two decades of corporate
lobbying on behalf of the timber industry under his belt, as well as his
staunch advocacy for suspending or permanently nullifying environmental laws,
who better than he, to be guarding America's hen house containing America's
National Forest System?
This timber sale demonstrates the same shameful lack of balance as the agency
leadership that oversees it. History will demonstrate the ultimate collapse of
environmental integrity on the Tongass National Forest was preceded by the
collapse of the moral integrity of those leaders who were trusted to "Care for
the Land and Serve the People".
If this agency were truly serious about Caring for the Land and serving
people, it would suspend all further incursions into roadless areas and create
jobs by addressing the enormous backlog of road maintenance and failed
Beebe culverts on the Tongass. It would aggressively institute fisheries and
0 wildlife habitat restoration and mitigation resulting from previous harvest
activities. It would begin an aggressive campaign to implement jobs by way of
badly needed commercial pre-thinning on other areas of the Tongass.
One cannot care for the land, with any sense of conscience and read of this
planning document and its agency doublespeak, and remain silent.
Dear Sir,
This agency document is appalling in regards to what is cavalierly deemed
acceptable silviculture practices with attendant environmental consequences.
It is hard to imagine any professional agency capable of attitudes and actions
that make a travesty of its stated credo: Caring for the Land Serving People.
Beebe
7
This document fails to address the impacts of native corporate logging on
adjacent forest landscapes that have resulted in significant loss of
subsistence opportunities to the residents of Kake. The impacts have already
begun to register.
Beebe
8
There is no scientific doubt that harvest activities increase landslide
hazards that ultimately adversely affect salmon habitat and survival. Any
silviculture practice that downplays foreseeable, preventable destruction of
the publics' forest resources indicates erosion of professional principles
_that is deeply troubling.
It has been shown that watersheds with as little as 12% clearing for roads can
have significant effects on the stability of slopes. These effects can take
decades to recover from.
Almost all sediment Risk ratings in Kuiu watersheds with 20% or greater
harvest levels resulted in significantly increased risks to salmon habitat. 23
different watersheds were rated with high or very high risks for sedimentation
of salmon habitat due to clearcutting and roading in the watersheds, yet
little has been done to assess water quality on Kuiu Island.
130 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #1 1 - David Beebe
Beebe
9
Beebe
10
Beebe
11
Beebe
12
Beebe
13
Beebe
14
f The following are the particularly egregious example of reckless disregard for
consequences of logging:
Unit 207 in alternatives (2, 3, and 4) which ranges from 60 to 75 acres. It
befuddles the mind that this agency would knowingly allow this unit in zones
of extreme soil hazard (MMI 4 ) involving 6 separate stream channels highly
susceptible to landslides. The unit was previously designed to be a wildlife
travel corridor, and harvest would eliminate high value deer and marten
habitat .
Units 103d (5 acres), 103c (20 mostly high Volstrata acres), and unit 101(98
mostly high Volstrata acres) occur in the hardest hit watershed which has
already had 5 landslides and lost 60% of its landscape to clearcuts. Unit 101
incurs into extreme hazard soils (MMI 4), quite likely to result in
landslides. And you people propose to heap yet more destruction on this
V^watershed and call this caring for the land?
USFS Hall of Shame:
This agency continues to highgrade volume class 6&7 disproportionate to its
occurrence on the Tongass resulting in significant habitat degradation and
carrying capacity.
The sediment risk index is either high or very high in five out of seven of
the watersheds in the project area. Increases in risk are directly
attributable to clearcut activities.
During the most recent inventory (12/'03), 57 landslides were recorded in the
project area, the largest being 88 acres in size. What does this agency
^^ropose to do about this?
813 acres of volume class 6&7 of high quality deer habitat would be lost to
the preferred alternative. This will result in inevitable reduction of
subsistence opportunities.
The preferred alternative would have the highest impact of all action
alternatives on roadless areas.
31% of low elevation deer habitat capability has already been eliminated from
the harvest area.
54% of the high volume class timber of the project area would be eliminated
from historic conditions if the preferred alternative were implemented.
52 acres of harvest would occur on extreme hazard soils in the preferred
alternative and 160 acres of detrimental soil disturbance.
The preferred alternative would create the greatest potential for landslides.
Watershed 109-45-10090
59% has been clearcut.
5 different landslides have occurred which likely resulted in stream channel
sediment loading resulting in width to depth ratios that result in poor salmon
habitat .
There is no equivocation in terms of what caused this degradation of
habitat : "extensive harvest, landslides and road building".
Dean Creek Watershed
It has a 30 acre landslide even though it has a very small percentage of its
landscape in the high or very high Mass Movement Hazard categories
▼ 33% of the watershed has been roaded and clearcut.
Kuiu Timber Sale FEIS
Appendix C • 131
Comment Letter #1 1 - David Beebe
Security Creek
12 separate landslides
16 miles of roads
26% of the watershed has been harvested
Kadake Creek Watershed (8,18^ MBF on 340 acres)
18 separate landslides
78 miles of roads
90% of the streams are either salmon spawning habitat or are streams flowing
into spawning habitat.
over
410 acres of riparian areas harvested
Some stream channel characteristics have been downgraded to "Poor", but it is
said that it is impossible to say if management activities were the cause
Saginaw Creek Watershed
19 landslides
29% of the watershed has been roaded and clearcut .
Sediment Risk Rating to salmon spawning habitat boosted to Very High
Further harvest and road building activities will require going into steeper
terrain with a greater risk of landslides
Coho are dying in a streambed that was destroyed by a logging road, then
haphazardly "mitigated" using inappropriate fill material that allows the
stream channel to disappear completely during dry periods.
A single storm event in 1988 produced most of the 19 landslides present in the
Sagniaw Watershed alone. Practically 3/4 of the streams in this watershed are j
either salmon spawning habitat or streams flowing into their spawning grounds.
Beebe
14 contd.
When compared with other watersheds of Kuiu Island, the Saginaw Creek
Watershed was rated average to below average for the proportion of slopes with
high or very high Mass Wasting Hazard. Yet the agency pressed on with marching
orders .
When the agency was finished caring for the land, their clearcuts catapulted
the Saginaw Watershed into the 90th percentile for landslide density compared
to the island's more fortunate watersheds.
Because the forest service exhausted the low elevation oldgrowth in valley
bottoms and toe slopes in the late 60 's and 70 's, it has been forced to
concentrate later harvest on mid-slopes and ridge tops. Alders now dominate
many harvest areas that once supported phenomenal densities of oldgrowth
spruce and hemlock.
The watershed integrity as a result, has been severely altered from a
pristine, world class example of coastal temperate rainforest into an
industrial landscape that puts salmon spawning and subsistence resources at
the bottom of the list of imperatives. There is no excuse why multiple use
objectives cannot be more balanced than this.
While the Saginaw watershed has over 20 miles of logging roads, practically
30% of its forests clearcut, a massive degree of landslides imposing high
sediment risk to its world class salmon streams, the agency is still equivocal
about why salmon stream attributes are now below average. On page 30 of
Appendix C in the Kuiu DEIS, it is explained this way: "It is not possible to
say whether below average (attributes of spawning habitat) in the East and
West Forks of Saginaw Creek are due to management activities or simply a
natural characteristic of these streams". What is the point of having
hydrologists and fishery biologists on the IDT if they can't put as much time
y^into causes as they do effects?
132 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #1 1 - David Beebe
Beebe
15
Beebe
16
Beebe
17
Beebe
18
Beebe
19
Chapter 3-135 has an incorrect total of harvest acres for Kadake Creek
Watershed. Unit cards total 340 acres. Table 3-55 has Kadake Creek total of
^83 acres.
On matters of subsistence deer issues, this DEIS uses hunter deer harvest
statistics as if they constituted absolute scientific fact without regarding
cases of poaching and the projected impacts by high density road conditions
which enhance that possibility. It disregards hunters who fail to make harvest
reports .
It fails to assess predation due to wolves and bear and the impacts that will
have on subsistence opportunities. It fails to account for extreme weather
mortality, and assumes average weather conditions will prevail for the course
of the planning period. When in reality, large portions of our planet and
North America in particular are experiencing extreme aberrations in weather
patterns that could have dire consequences to an already compromised
environment due to timber sales such as this one. NEPA requires that this
agency consider the environmental impacts of past, present and reasonably
foreseeable future scenarios .
Appendix C notably excludes all mention of watershed 109-44-10370. Locations
of existing landslides in the project area are also notably absent in the GIS
maps and are an important feature of the landscape of the project area
^ritical to the understanding of the consequences of harvest activities.
I recommend the no action alternative until you can demonstrate a higher
regard for your professional responsibilities to the public.
Sincerely,
David Beebe
P.O. Box 148
Petersburg
AK 99833
Kuiu Timber Sale FEIS
Appendix C • 133
Response to Beebe
Beebe - 1
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1 997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
The Tongass National Forest will continue to be managed in compliance with Section
lOl of the Tongass Timber Reform Act of 1 990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...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 (I) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
As described more fully in Appendix A of the FEIS, to provide a steady flow of timber
harvest volume, timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand.
Beebe - 2
Concern over the acres of clearcuts on Kuiu Island is noted. However the 27,856 acres
and 78 watersheds referred to are located on an island 482,101 acres in size with 163
major watersheds. Sixty four percent of the island is in non-development LUDs (Kuiu
Island Landscape Assessment). Less than six percent of the island has been harvested and
less than five percent of the major watersheds include any harvest.
As noted in the DEIS p.3-1 19 and the FEIS Chapter 3 Cumulative Effects to Watershed
section, approximately 59 percent of Watershed 109-45-10090 has been harvested, but
only 20 percent of the watershed has been harvested within the last 30 years. The high
amount of cumulative harvest in this watershed does not mean the watershed has lost its
integrity. Hydrologic recovery due to regrowth of vegetation in harvested in areas is
expected to require between 10 and 30 years (DEIS p. 3-124 and FEIS Chapter 3
Cumulative Effects on Watersheds, Cumulative Watershed Effects section). Watersheds
are altered by timber harvest and road building, not destroyed. The watersheds affected
by the proposed project continue to produce clean water and support anadromous and
resident fish populations. The watersheds are expected to continue to support these
beneficial uses into the future, regardless of which alternative is selected.
Beebe - 3
On p. 3-26 of the DEIS it states, “The Forest Plan contains a comprehensive conservation
strategy to assure viable and well-distributed wildlife populations (Forest Plan FEIS
Appendix, Volume 4, Appendix N, 1997).” The DEIS goes on to explain much of this
strategy. While there is expected to be some effects from the proposed actions of each
alternative, the cumulative effects listed on pp. 3-72 thru 3-74 do not identify any threats
to the viability to any species from the proposed timber harvest activities.
134 • Appendix C
Kuiu Timber Sale FEIS
Response to Beebe
The Conservation Strategy Review Workshop was conducted April 10-14, 2006 at the
Ted Ferry Civic Center in Ketchikan Alaska. Key Findings from the workshop are listed
below:
• The Conservation Strategy is still sound.
• There is a low risk of species viability problems related to Forest Plan
implementation.
• Endemic species continue to be a high priority information need.
• There is good opportunity to manage habitats to emphasize production of prey
species of other foods.
• Management of young-growth forests for wildlife habitat is promising,
especially for species like black-tailed deer.
• There is a need to better understand the role and management of the Matrix
part of the Strategy, including the role of non-National Forest System lands.
• The wildlife monitoring program needs to be updated.
Beebe - 4
The large and medium old-growth reserves, of which there is approximately 25,171 acres
on Kuiu Island (DEIS p. 3-26, Kuiu Island Landscape Assessment p. 4) are non-
development LUDs established in the Eorest Plan and are not diminished in size for
development activities including timber projection. Furthermore, there is a forest-wide
system of protection provided by other non-development LUDs (307,729 acres on Kuiu
Island (Kuiu Island Landscape Assessment p. 4)) that maintain the integrity of the forest-
wide ecosystem and provide future option for maintaining naturally occurring
ecosystems.
Beebe - 5
The DEIS (p. 3-4) defines what irreversible and irretrievable commitments are and
further clarifies that there would be no irreversible commitment of resources from the
proposed project and the expansion of rock pits would lead to an irretrievable
commitment of resources within this project. The Transportation section of the DEIS (p.
3-21 1) addresses the need for a rock source to maintain and construct roads and while
there will be no need to develop new rock quarries, existing quarries would be used and
expanded.
Removing trees from the landscape does not destroy it. The landscape remains and the
trees will grow back. A responsibility of the Eorest Service is to identify and present all
of the effects from the proposed project including irreversible commitments of resources
to the public and Responsible Official.
Beebe - 6
The Forest Service receives annual road maintenance monies to be used for maintenance
of the road systems for the present and perceived problem areas of the road system.
Petersburg Ranger District is composed of several island road systems and the annual
maintenance monies are generally divided between these island systems.
Kuiu Timber Sale FEIS
Appendix C • 135
Response to Beebe
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 NEPA 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.
Fisheries and wildlife habitat restoration projects are ongoing within the Forest. In the
planning area, the Kadake Creek tributary restoration project is ongoing and two red
culverts (those that don’t pass fish at all flows) will be replaced with all action
alternatives. The remaining red culverts are being evaluated on a forest-wide basis for
prioritization for repair or replacement.
As stated in the DEIS p. 1-6 and 3-167, of the total acres harvested in the project
(approximately 10,393 acres) 4,766 have been pre-commercially thinned. The remaining
5,627 acres are not ready for pre-commercial thinning. Decisions on thinning other areas
of the Tongass does not fall within the realm of this project analysis.
Beebe - 7
There is no corporate land adjacent to the Project Area. There are 356 acres of non-
National Forest System lands within the Project Area: two acres of private land, seven
acres of Bureau of Land Management land, and 347 acres of State of Alaska land. The
concern over logging on native corporate land on Kupreanof Island in relation to
significant loss of subsistence opportunities for residents of Kake has been addressed in
the FEIS Chapter 3 - Issue 2 Deer Habitat and Subsistence Use section. The historic and
current use of Kuiu Island for subsistence deer hunting has been updated in the FEIS (see
Response to OVK 4).
The scoping for this project found that there is concern that timber harvest on private
lands on both Kuiu and Kupreanof Islands has had, or may have, harmful effects to deer
populations on Kuiu Island. There are very few acres of State or private lands on Kuiu
Island. State lands include the State Marine Park in Security Bay and two town sites in
Rowan Bay and No Name Bay. There may be clearing of the Rowan Bay site in the
future if the State sells lands for a town site. The No Name Bay site is part of the over-
selection and is low on the priority list of lands the State will select. Harvest will most
likely not occur on the remaining State lands because of the nature of the lands
withdrawn.
The Sealaska Corporation owns lands on the northern portion of Kuiu in VCU 398. At
this time, no harvest has occurred on these lands. These are small acreages and are not
expected to have much impact to wildlife.
The harvest of private lands on Kupreanof Island around the village of Kake is extensive.
The Native Corporation completing this harvest has followed the State Forestry Practices
Act and has cut what is available. This large harvest area has had major impacts to deer
on Kupreanof Island but probably has had little effect to Kuiu populations.
136 • Appendix C
Kuiu Timber Sale FEIS
Response to Beebe
Beebe - 8
The effects of harvest activities on rate of landslides are discussed in the DEIS p. 3-192 -
3-197 and 3-201 and in the FEIS Chapter 3-Soils and Geology section. A soil stability
analysis was completed by a Soils Scientist for all MMI-4 soils within planned road
locations and timber harvest units. All unstable slopes were avoided. However, due to
the numerous concerns received, those units with MMI-4 soils were reanalyzed. Units
207, 303, and 305 (See unit cards in FEIS Appendix B) will be modified to exclude the
MMI-4 soils. For Unit 101, the MMI-4 soils in the southeast corner of the unit will be
removed and the area along the western edge of the unit will remain. There are no
streams in this area and the risk of sedimentation delivery to a stream is very small.
Beebe - 9
Soil stability analysis was completed by a Soils Scientist (and is available in the planning
record) for all MMI-4 soils within planned road locations and timber harvest units, and
all unstable slopes were avoided. However, due to the numerous concerns received about
including these MMI-4 soils within the units, the unit boundaries have been modified (see
Beebe -8 response). The potential for landslides were discussed on pages 3-199 to 3-201
of the DEIS and are discussed in the FEIS Chapter 3 - Soils and Geology section.
See Beebe-2 for the response to the concern of harvest within Watershed 109-45-10090.
Beebe - 10
The DEIS analyzes the cumulative effects of harvest and road building on both deer and
marten carrying capacities at the project level and the Wildlife Analysis Area (WAA)
level. There was no significant habitat degradation or change to the carrying capacity of
either species.
The analysis of the proportion of volume class 6 and 7 harvested and proposed for
harvest has been expanded in the FEIS and the Wildlife Report. The harvest on Kuiu
Island is not disproportionate to its occurrence. Currently, approximately 25 percent of
the POG is coarse canopy, and all of the alternatives would retain this proportion (DEIS
pg 3-158 and 3-159 and FEIS Chapter 3 - Wildlife Habitat and Timber and Vegetation
section). The action alternatives would harvest between 1 and 4 percent of the coarse
canopy, which would not be a significant degradation to the habitat or its carrying
capacity.
Beebe - 11
As the Watershed Analysis explains, there were no historical records on these streams to
compare to, therefore it cannot be determined if the present conditions of these streams is
due to common events, harvest or a combination thereof. As stated on p. C-19 of the
DEIS: “Water quality parameters are not routinely monitored on Kuiu Island. The
primary water quality parameters that can be affected by timber harvest activities are
suspended sediment loads, turbidity, and stream temperature. Fuel storage on Kuiu
Island also presents a potential water quality concern. All of these water quality concerns
are addressed through the application of Best Management Practices (BMPs).
Kuiu Timber Sale FEIS
Appendix C • 137
Response to Beebe
A Memorandum of Agreement between Alaska Department of Environmental
Conservation and USDA Forest Service documents the Forest Service’s role in the
Alaska Nonpoint Source Pollution Control Strategy. State Approved BMPs are the
mechanism through which the Forest Service protects water quality from nonpoint source
pollution. The Forest Service’s implementation and monitoring of BMPs satisfies the
requirements of the Alaska Nonpoint Source Pollution Control Strategy and is approved
by the US EPA, thereby ensuring that USFS activities are consistent with the Clean
Water Act.
Beebe - 12
The landslides within the Project Area have reseeded naturally and there are no plans to
do anything about them at this time. Table 3-73 in the DEIS p. 3- 1 97 displays the number
of landslides in unharvested and harvested acres. Although landslides are more likely to
occur in harvested acres than unharvested acres, the planning area consists of 10,393
harvested acres and 35,709 unharvested acres. Approximately 77 percent of the planning
area is unharvested area. Thirty-nine of the 57 landslides within the planning area have
occurred within these unharvested areas as compared with 18 in the harvested areas. As
discussed in the DEIS (p. 3-191) Swanston and Marion 1991 noted that “as a general
rule, landslides in harvest areas are significantly smaller, occur at lower elevations,
develop on gentler gradients and tend to travel shorter distances [than naturally induced
landslides].’’
Beebe - 13
As indicated in the DEIS (p. 3-50) the restriction to subsistence is the low deer
populations due to severe winter die-offs and the slow recovery due to high predation
(see CCWF-4). Additional information added to the FEIS Chapter 3- Subsistence section
states that Kake residents have pointed out that their recent (since 1975) reliance on
Admiralty Island for deer hunting is not their preference, and that as the Kuiu herds
increase, more of their hunting will shift back to Kuiu Island. Kake residents on average
(1993 to 1995) take about 250 deer annually (TEMP Revision FEIS, Appendix H, p. H-
76, based on 75% of their harvest being 185 deer). If all of these deer were harvested
from Kuiu the minimum deer needed to support that demand would be 2,500 deer. Table
3-29 in the DEIS p. 3-83 shows that WAA 5012 would be able to meet this demand in all
alternatives.
Beebe - 14
Of the five slides that occurred within Watershed 109-45-10090, three did not reach a
stream. The width-to-depth ratio for the stream draining this watershed does rate as poor
when compared to the Tongass Fish Habitat Objectives; however, other indicators are
rated as fair, good, and excellent (DEIS P. 3-120). Salmon habitat is not poor overall.
Furthermore, width-to-depth ratios vary in nature and there is no pre-logging data
available for the stream channel condition, therefore, it is not possible to determine what
the width-to-depth ratio was before logging.
138 • Appendix C
Kuiu Timber Sale FEIS
Response to Beebe
Dean Creek Watershed does have one slide. This slide however is not in a managed
stand.
In Security Creek five of the 12 slides did not occur in harvest units. Two of the five not
in harvest units were near streams.
One hundred percent of the streams in this watershed flow into salmon spawning habitat.
The stream channel condition was rated as poor for pools per kilometer, however, it is not
correct to say that the condition has been downgraded to poor. No pre-logging data set
exists for comparison. Note that the rating for percent of channel in pool area was rated
as excellent. It could be that Kadake Creek naturally has few pools, but the pools are
very large. The majority of the managed stands in the watershed are outside of the
project boundary. Of the entire watershed (32,270 acres) 1.1% (352 acres) had slides. Of
the 18 slides within the watershed, 8 were not in harvest units.
There is no streambed in this watershed that has been destroyed by a road then
haphazardly mitigated with inappropriate fill material. One hundred percent of streams
in this watershed drain into salmon spawning habitat. The map on p. 3-141 shows
landslide initiation points. Within the Saginaw Creek Watershed most of the landslides
occurred outside of timber harvest units and away from roads, reflecting the fact that
landslides are naturally occurring events in this watershed.
The Forest Plan addresses multiple-use goals and objectives through the allocation of
lands to the set of Land Use Designations (Forest Plan, p. 2-2). Thus, multiple-use goals
are addressed at the Forest-wide level, not at the level of individual watersheds. Within
this watershed there have been 19 slides for a total of 1.5 percent of the watershed. Of the
19 slides, 1 1 occurred outside of harvest units and only one slide in Saginaw Creek
Watershed was directly related to the 1988 storm event.
Assessments of stream channel conditions for each watershed in Appendix C in the DEIS
are made without the benefit of pre-logging data. No pre-logging data on stream channel
conditions are available.
Within the watershed, increased sediment may affect individual fish by reducing oxygen
levels to developing eggs in spawning gravel and/or trapping of emerging fry in the
gravel, however, the effect is expected to be short term (48 hours or less) and the
placement of timing restrictions will minimize impacts to fish (see the road cards in
Appendix B). The State of Alaska’s Water Quality Standards state that the quality of a
water to support propagation of fish, shellfish, and wildlife and recreation in and on the
water must be protected and maintained. BMP implementation will achieve state water
quality standards (FEIS Chapter3 - Fisheries, Environmental Consequences section).
Beebe - 15
The table in the FEIS in Issue 4, Chapter 3 reports the correct number of acres of harvest
proposed in the Kadake Creek Watershed in Alternative 4.
Kuiu Timber Sale FEIS
Appendix C • 139
Response to Beebe
Beebe - 16
The FEIS and Wildlife Specialist Report describes the interaction between predators and
prey and analyzes it by applying the figures used by Person ( 1 997, 200 1 ). There is
sufficient habitat to maintain 34 deer per square miles island-wide and 29 deer per square
mile WAA-wide, which is above the predicted numbers Person used in his analysis. See
Response to OVK-4 and SEACC 3c
Beebe - 17
The DEIS p. 3-83 Table 3-29 footnote b, shows a 36 percent reduction in the habitat
capability for WAA to account for wolf predation. The Forest Service does not have
reduction factor for black bear predation on deer. It is not possible to guess what the
weather will be, therefore averages are used. All past, present, and reasonably foreseeable
impacts were analyzed for the cumulative effects shown in Chapter 3 of the FEIS.
Beebe - 18
Watershed 109-44-10370 is not analyzed in detail in Appendix C because it has had a
low level of cumulative harvest. The watershed is described on p. 3-123 of the DEIS.
The locations of landslides within the Project Area are depicted on map 3-8 on p. 3-141
of the DEIS. Figure 3-8 in the DEIS has been updated to make the landslides more
visible.
Beebe - 19
Preference for the No- Action Alternative is noted.
140 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #12 - Edna L. Jackson
EJ - 1
Edna JL Jackson
512 Keku Road
P.O. Box 163
Kalce, Alaska 993S0
March 19, 2006
Kiis Rutledge, Team Leader
USDA Forest Service
P.O, Box 1328
Petersburg, Alaska 99833
RE: Kuiu Timber Sale
Dear Ms. Rutledge:
I have lived in Kake nearly my whole life. My family on my father’s side is fiom Saginaw
Bay. Although my mother is not originally from Kake, ^e was adopted by a family that is
also fnom Saginaw Bay, so I have cultural roots to North Kuiu Island that go way back on
my tribal Emily’s side and my father’s family’s side. When I was a small girl, my Mier
used to take our family out to North Kuiu for fishing and gathering, the same as his father
before him, and 1 am sure the same for many generations before that As 1 grew into
adulthood, my husband and I did the same with our own &mily. Our grandson’s name is
tied directly to a clifif in Saginaw Bay.
North Kuiu Island has been an important customary and traditional use area for myself and
my femily. We fish for halibut and sm^per, we gather black and red ribbon seaweed, we
dig for clams, we gather gumboots. We pick tea and berries, gather devil’s club bark for
medicine. My husband and his brothers make a special trip for the last dog salmon of the
year fi:om Security Bay. We get not only physical sustenance from file area but spiritual
sustenance as well because that area is where, according to our oral history. Raven created a
small Nass River when he became homesick, fiiat is where Raven tracks arc locked in stone,
and where Raven’s beads are scattered. The US Forest Service looks at the same area and
sees so many mbf per acre, or suitable forest land or unsuitable forest land. And it’s business
as usual, as the Forest Service continues to propose timber sales that completely &il to
accommodate Kake residents’ concerns. Or sales that are even economical... how many
timber sal^ are sitting on the shelf with no bidders because of the present timber market.
In NRDC V. USFS, the 9^ Circuit Court of Ai^reals found fundam^tal defects in the 1997
Tongass Forest Plan based on the substantial error made by the For^ Service in estimating
the market demand for Tongass Timber. As the court explained, this error “&tally infected
[file agency’s] balance of the economic and environmental considerations...” NRDC v.
USFS, 421 F.3d797, 816 (9’*' Cir, 2005). The court directed the Forest Service to revise the
Tongass Forest Plan. Until that court-scnand^ed revision is complete, 1 would reconunend
the Forest Service stop all planning activities related to file Kuiu Timber Sale project.
Edm L Jackson Letter (0 us Finest Sovico
RE; Kuiu toland Timber Sale
b I
Kuiu Timber Sale FEIS
Appendix C • 141
EJ - 3
EJ-4
Comment Letter #12 - Edna L. Jackson
Industrial scale logging on my ancestral land has been going on since the early 1960’s with
Pendlla Loggmg, Soderbuig Logging, and prior to that, high-grade spruce logging during
WWn. Give North Kuiu Island some time to recover.
^VK hunteis’ customary and traditional activities are significantly restricted when our
nephews have to travel further from home to hunt deer at a time of year with dangerous and
life-threatening weather conditions. I don’t need to resound you that two years ago, our little
community lost three hunters attempting to make the 24 mile run across Frederick Sound to
Admiralty Island for deer. One young man was my neighbor, the other two were a father
and son who lived just two houses away from me. Perhaps they would still be with us today
had they not needed to travel so far for their de^ hunting.
j[ would like to point out that the US Forest Service is using an outdated community profile
in the DEIS. In 2003, the reported population for Kake was 682 residents O^EIS, 3-76).
The current population of Kake is Table 3-92, identifying Kake’s population at 663 in 2004.
In the last two years, however, Kake's population has dropped over 12 percent to S98.
The description of Kake’s employment and income is also inaccurate and outdated. The
DEIS states that seafood processing at Kake Foods “contribute[s] considerably to the
economy.” Unfortunately, the Kake Foods has not operated at all in fre past two years; tribal
members are forced to seek seasonal employment in Petersburg and Sitka, returning home
when these seasonal jobs are over.
Hie DEIS also references employmrat of residents logging on village and regional
corporation lands. Two summ^ ago, Kake Tribal sold all its logging equipment, so
logging jobs are miniinal at best Logging by the regional corporation employed less tban a
dozen local men last year for a very short season. Some of our local men worked at these
jobs but eventually left Kake to work in Kensington Mme because of the few hours they
were even called to work. I suspect there will be even fewer log^ng jobs by our regional
CoiporatioD^ as their subcontractcH- brou^t in ten migrant woikera last month.
Anyway, 1 am pointing this out to you to show that we are real people here that your
decisions affect; have the courtesy to use current infomiation, please. For the U.S. Forest
S^ce to use outdated and incomplete information makes its attempt to evaluate the human
health arul environmental effects of the proposed action aibitraiy. While the DEIS attempts
to evaluate the social and economic effects of the proposed Kuiu timber sale on Kake, it
completely fails to consider how past ami future significant iinpacts to customary and
traditional activities in the project are impacting the cultural arid social lives of OVK
members.
The environmental justice analysis contained in the DEIS £uls to disclose cuirent
unemployment statistics for Kake, compare the median incomes of Kake housdiolds wifo
the regional medium, evaluate the access of residents to potendai jobs. Kake is classified as
a "distressed” community due to the dire economic situation. There is no reflection of this in
your DEIS.
Edna L JBckun Letter to U$ Fonest Service
RE; Kuiu blind Titritcr Sole
Ti- t
142 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #12 - Edna L. Jackson
EJ - 5
Duiing times of axinoinic down&ll, tribal memboship depend even more so on gathoing
of customaiy and traditional foods, and there is no reflection of this in your DEIS.
I am opposed to further logging on north Kuiu Island. There has been more than enough
indusliia] scale logging on North Kuiu Island. Let the fish ami wildlife habitat and
watersheds have some rime to recover. This directly impacts our customaiy and traditional
gathering. I prefer the No-Action Alternative, Alternative A
Thank you for your attention.
Kuiu Timber Sale FEIS
Appendix C • 143
Response to Edna L. Jackson
EJ -1
The Forest Service acknowledges that these are customary and traditional use areas.
EJ -2
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
The Tongass National Forest will continue to be managed in compliance with Section
101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which ( 1 ) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
As described more fully in Appendix A of the DEIS, to provide a steady flow of timber
harvest volume timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand.
EJ -3
The Forest Service acknowledges the grief regarding the loss of three hunters from Kake
and recognizes that the deer population on Kuiu Island has not returned to historic levels
since the sever winter die-off in the late 60’s and early 70’s, which forces Kake hunters to
travel farther than they might otherwise.
EJ -4
The FEIS has been updated to include current population estimates and the following
income and employment information.
U.S. Census data for Year 2000 shows the median household income was
$39,643, per capita income was $17,41 1, and 14.61 percent of residents were
living below the poverty level.
A letter dated February 2006 from the Denali Commission confirmed Kake’s
classification as a distressed community. Based on 2003 data, the Denali
Commission estimates Kake average market income as below the $14, 872
threshold level and that more than 70% of residents age 16 and over earned less
than the threshold.
The FEIS has been updated as much as possible; the following sites were used as sources:
6. Alaska Department of Commerce, Community and Economic Development
community database (www.dced.state.ak.us).
144 • Appendix C
Kuiu Timber Sale FEIS
Response to Edna L. Jackson
7. the Denali Commission website (www.denali.gov),
8. the Kake Community Economic Development Strategy (2004) (the page
provided),
9. the U.S. Census Bureau, Census 2000
(http://censtats.census.gov/pub/Profiles.shtml) and
10. Personal communication with Kake Schools, OVK, the City of Kake and Jeannie
Monk (Denali Commission).
The Forest Service has noted that Kake Foods has not operated in the past two years and
that Kake Tribal recently sold all its logging equipment. The Forest Service also
acknowledges that as income has dropped, reliance on subsistence has increased. The
FEIS Environmental Justice section has been expanded to recognize the above-mentioned
condition in Kake and acknowledge that, during times of economie hardship, tribal
membership depends even more on gathering of customary and traditional foods. It was
also noted that the project is not expected to make conditions worse and there may be
some opportunities for employment as a result of the project.
EJ -5
Preference for the No- Action Alternative (Alternative A) is noted.
Kuiu Timber Sale FEIS
Appendix C • 145
Comment Letter # 13 - Katie Fearer
KF-
KF-2
KF- 3
kfearer@myuw.net
03/20/2006 10:42 AM
To :Comments-alaska-tongass-petersburg@fs.fed.us
cc:
Subject: Kuiu Timber Sale
I am commenting on the proposed Kuiu Timber Sale, which includes parts
of Kadake Creek and other areas in the Kadake Bay watershed.
I urge the Forest Service to select the "no action" alternative to the
sale .
f 1 have traveled to Kadake Bay and have enjoyed fishing, wildlife
watching, and hiking along Kadake Creek. I am drawn to the area
because it is relatively undisturbed and supports a high-density
population of black bears, along with wolves, moose, Sitka black-tailed
deer, and
course, salmon.
It is my understanding that the Tongass Fish and Wildlife Resource
Assessment (ADF&G, 1998) identified Kadake Creek as a primary sportfish
producer and one of 19 "high value" watersheds in Southeast Alaska. It
is also my understanding that in 1997 the Forest Service recommended
23 miles of Kadake Creek as a recreational river under the Wild and
Scenic River Act because of its high historic, recreation, and
^fisheries values.
^I do not believe that the demand that exists for Tongass timber
justifies logging this pristine area. According to a ruling by the
9th Circuit in 2005, the Tongass Forest Plan's estimates of the demand
for Tongass timber are misleading, because they erroneously doubled the
market demand for the timber. It is also my understanding that the
Forest Service's logging program in Southeast Alaska loses millions of
dollars every year.
Considering the adverse environmental and economic impacts of the
proposed sale, I oppose it.
Thank you for considering my comments.
Katie Fearer
2425 SW Webster St., Apt. E-4
Seattle, WA 98106
146 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #13 - Katie Fearer
KF-1
Preference for Alternative 1 , the No- Action Alternative, has been noted.
KF -2
Most cultural, historical, recreational, fish and wildlife values of the Kadake watershed
are concentrated at the mouth of Kadake Creek and within the riparian buffer of the creek
itself (TLMP FEIS, Appendix, Vol. 2, pp E-25 1-254). None of the proposed harvest
units or roads would be within these areas. The Kadake Creek Recreational River LUD
contains 6,585 acres. Suitable forested land is available for harvest within the
Recreational River LUD if the adjacent Land Use Designation allows timber harvest
(Forest Plan p. 3-118) as is the case in the Kuiu Project Area (see Unit Cards Appendix B
pp. B-83 and B-85). Alternatives 1, 3, and 5 do not propose any harvest within the
Recreational River LUD. Alternative 2 proposes 1 8 acres of partial timber harvest within
the Vi mile wide river corridor and Alternative 4 proposes 49 acres of partial harvest. See
also Greenpeace Response #41.
KF-3
There are several interpretations of pristine, however, this area already has a road
structure and has been logged in the past and is therefore not pristine. It is because of the
existing roads and infrastructure that this area is a good place for harvesting, as the
existing infrastructure helps keep the high cost of road construction to a minimum.
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands.
The Tongass National Forest will continue to be managed in compliance with Section
101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which (1) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
As described more fully in Appendix A of the FEIS, to provide a steady flow of timber
harvest volume, timber sale projects need to be completed through the NLP A process
each year to meet current and future market demand.
The Forest Service does not lose millions of dollars yearly with the logging program;
however, the Forest Service is not mandated to make money by offering timber for sale,
either. This point is further emphasized in the Forest Supervisor’s declaration, where it
states:
There is no legal mandate for the Forest Service to generate a profit. The Timber
program is not unusual in costing more to operate than the government receives in
revenues for the program. Many programs on the Tongass National Forest
generate no revenue, including the subsistence, heritage, inventory, and
Kuiu Timber Sale FEIS
Appendix C • 147
Response to Fearer
monitoring, land management planning, geology, fish and wildlife management,
trail improvements, and fire protection programs. The Tongass National Forest
produces the majority of wildlife and fish for commercial, sport, and subsistence
users in Southeast Alaska, yet receives no returns on its investments (Cole, 2006)
148 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #14 - Glen Ith
Attn: Kris Rutledge
Team Leader
Box 1328
Petersburg, AK 99833
Kuiu Draft EIS Comments and Concerns
1. Harvest Unit Volume Estimates
Timber harvest economics is a significant issue identified in this DEIS (pages S-1 1, 1-19,
3-97 to 3-1 1 1). The NEPA Economic Analysis Tool (NEAT) is used to present the
economic evaluation of harvesting specific units. Outputs from the NEAT include the
expected bid, and the number of potential jobs created, to name a few. Since some
^utputs are based on the unit volume per acre and expressed in monetary terms it is
reasonable to use the volumes and tree species composition actually measured within the
existing harvest units. This is the best estimate of the actual volumes believed to exist in
the project area.
Ith - 1
The NEAT model typically uses a weighted average of volume per acre that is unlikely to
represent the true volumes contained within the specific harvest units comprising a
portion of the total volume estimate. Therefore all of the outputs created from the model
can be deceiving if weighted averages are used in the NEAT. This is especially true
when there are harvest units identified in volume classes 6 and 7, since these stands can
possibly contain substantially more or less volume per acre than shown on the unit card
estimates in the DEIS.
Timber harvest economics is an important issue; the best science used to determine the
economic benefits derived from this harvest proposal are obtained from specific
measurements taken within these specific harvest units, not by using a weighted average
taken from all or a portion of those units. Please use the actual volumes measured in this
\analysis.
2. Important Deer Winter Range
On page 3-53 of the DEIS it states that important deer winter range is determined and
described as part of an agreement between the State of Alaska and the Forest Service.
This document is a Memorandum of Understanding (MOU) between the two agencies.
Attachment 1 of this MOU refers to information needed by the State to review timber
sale proposals. This MOU does not describe, evaluate, or mention important deer winter
range. The information requested is a map displaying all deer winter range in the project
area distinguished by quartile. This is contrary to the wording on page 3-53 of the DEIS.
Impacts to Sitka black-tailed deer habitat is a common concern in most timber harvest
projects, especially those projects located on the southern half of the Forest. It is critical
Kuiu Timber Sale FEIS
Appendix C • 149
Comment Letter #14 - Glen Ith
lth-2b
Ith - 2c
that a consistent method is developed to determine important deer winter range.
/Important deer winter range is not specifically defined or clarified in the Forest Plan,
which may be the source of this concern; leading to many methods to identify and
evaluated impacts to important deer winter range. This project is no exception; it uses the
historic conditions (acres) existing within the WAA to determine this habitat. The Scott
Peak FEIS used the historic conditions within the ecological subsection for identification
of this habitat type. The Overlook EA uses the current conditions in the WAA. These
three examples illustrate current inconsistencies in methods used to determine important
,deer winter range.
r
The terminology used to identify important deer winter range is also inconsistent
throughout this DEIS. The term “High value winter range” is used on page 1-18, “high
value deer habitat” is used on page 1-9, “critical winter range” is used on page 3-23,
and finally “important deer winter range” is used on page 3-28. Apparently all four of
these terms are supposed to represent the same habitat type, yet this is left for the reader
to assume. These differences in terminology may at first seem trivial but they make the
document confusing to the readers that may possess a general understanding of deer
habitat relationships. These differences in terminology become infuriating to a reader
^possessing a rich understanding of these important relationships.
The four terms highlighted above vary substantially in their meaning. “High value deer
habitat” could represent summer range; especially areas located in sub-alpine regions of
the project area where high concentrations of preferred deer browse species occur. These
areas may be important for preparing and storing energy for deer to survive extreme,
prolonged winter conditions, but these high elevation areas are not typically utilized
during the winter months due to snow conditions in typical winters. The high value deer
habitat utilized in summer in both sub-alpine and young growth stands may not be
directly related to “important deer winter range”.
Changes in deer winter habitat capability numbers are the recognized means used on the
Tongass National Forest to determine impacts to deer habitat. Deer and marten are used
as MIS in this proposal and habitat capability is used to express the value and impacts to
habitat. Habitat capability for deer and marten is expressed as the potential number of
animals that can be supported within an area of evaluation. Habitat capability is also
indirectly related to subsistence use, since the Forest Plan FEIS assumes that reductions
of 10 to 20 percent habitat capability within WAAs may potentially result in reduced deer
population viability, possibly leading to subsistence restrictions in some areas.
It is reasonable that important deer winter range be based on quartiles broken down by
habitat capability. This would be meaningful since the upper quartile would represent
25% of the entire habitat capability in the preharvest condition in the WAA, regardless of
how many acres make up this quartile. This method would also clearly display that
further reductions in this specific habitat type would have disproportional impacts to total
habitat capability. In this DEIS thousands of additional acres are shown as important
deer winter range and impacts to these areas are washed out by the sheer amount of
habitat.
150 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #14 - Glen Ith
Please use the final output from the deer winter habitat capability model to determine
important deer winter range in the project area. This forth quartile would represent 25%
of the total habitat capability that once existed in the pre-harvest condition in the
associated WAA. This method would also present an important threshold, since large
reductions from past harvest activities in this habitat type would raise a red flag for
expressing potential limited deer subsistence resource in the project area.
3. Impacts to Marten Winter Habitat Capability Due to Road Density
^The impacts to marten winter habitat capability due to open road density are not shown in
this DEIS. Marten are a species at risk for local population reductions as a result of past
road building and timber harvest activities. Open road density is a component of the
marten winter habitat capability model as discussed on pages 3-44 and 3-45. This
component of the 1991 model was not revised in the most recent revision of the Forest
Plan.
A large reduction in marten habitat capability is not displayed or disclosed between the
historical and existing conditions within the project area caused by open high open road
densities. This component of the model is quite similar to the reduction in deer winter
habitat capability due to wolf predation (a 36% reduction). The difference is that road
density in the marten winter habitat capability model reflects improved accessibility to
marten trappers, a known source of high marten mortality. Please include this important
^^^component of the model in the Final EIS.
Thank you for the opportunity to comment on this proposal.
Petersburg, AK 99833
March 19, 2006
Kuiu Timber Sale FEIS
Appendix C • 151
Response to Ith
Ith - 1
The inventory done on this FEIS for the economic analysis is designed to be used as a
Project Area average and not on an individual unit basis.
Timber cruise plot surveys conducted within the planning area were used to derive the
average volumes and tree species composition used in NEAT and NEAT_R. It is neither
required nor practical to cruise all the units at this point in the sale program as all units
are not included in all alternatives and may not be selected for harvest.
Ith - 2a
The DEIS p. 3-53 states that the “results were generated using the quartile model
developed by the Eorest Service and the State of Alaska as means of describing important
deer winter range.” The methods to develop the quartiles mentioned above are what was
being referred to on page 3-53. The MOU (Agreement No. OOMOU-1 1 1001-026
Attachment 1 p. 1 states “All deer winter range in Project Area (that scores above 0 in
most recent interagency approved version of deer HSI model) distinguished by quartile
(i.e. by 25% of acres).” This has been clarified in the FEIS.
Ith - 2b
Analysis within the FEIS Chapter 3 Wildlife Habitat and Subsistence Uses section
includes comparisons between past, present and reasonably foreseeable future important
deer winter range by alternative. Important deer winter range was derived from the
historic condition of WAA 5012 and quartiles were developed based on total acres of
Habitat Suitability Indices (HSI) >0 within this area of analysis, as directed in the May
25, 2005 Forest Supervisor’s letter (Cole 2005). The appropriate scale of analysis to
develop HSI values for this project was the Wildlife Analysis Area (WAA) level in order
to compare the quartile analysis with the Forest Plan analysis.
Ith - 2c
Although the meanings of the different terminology used to refer to deer winter range
were the same, it is understandable how this could be confusing. The terminology in the
FEIS has been changed to be more consistent.
Ith - 2d
The methods used to determine the quartiles for the important deer winter range are
addressed in the Forrest Cole letter of May 25, 2005, in the wildlife section of the Annual
Monitoring & Evaluation Report for FY 2000, and the MOU Agreement No. OOMOU-
1 11001-026 Attachment 1 p. 1 as mentioned above.
Ith -3
The discussion of road density has been expanded to include both open and closed road
densities and the accessibility of closed roads for OHV use in conjunction to marten
trapping. The road density factor (90% reduction) was discussed in an earlier model
(Suring et al. 1992) but was not added then or in the current marten model (Version 7.0).
A discussion is available in the Wildlife Specialists Report.
152 • Appendix C
Kuiu Timber Sale FEIS
Response to Ith
As discussed in the DEIS and the FEIS, the road accessibility would be short-term, which
is defined as over the life of the timber sale, and the overall cumulative effects of the
action alternatives is a decrease in open road densities within the planning area.
Kuiu Timber Sale FEIS
Appendix C • 153
Comment Letter #15- John Kober
Kober - '
Kober - 2
Kober - 3
Kober - 4
Kober - 5
John Kober
<johnkober@mac .com>
03/20/2006 08:41 AM ’
To: Comments-alaska-tongass-petersburg@fs.fed. us
cc:
Subject: Kuiu Timber Sale
I am writing to comment on the proposed timber sale on Kuiu Island.
Given the economic value of Kadake Creek as one of SE Alaska's most
prolific salmon and steelhead streams I do not support any
clearcutting or road building, including temporary roads, in the
Kadake Creek watershed. The Forest Service itself has acknowledged
the significance of Kadake Creek when it recommended that 23 miles be
designated under the Wild and Scenic River Act because of it's
/recreation and fisheries value.
I have fished Kadake Creek several times and have flown over Kuiu
Island and have seen that the Island has already been heavily logged
and clearcut. More logging or road building will only serve to
threaten the recreation and fisheries value of the Kadake Creek
drainage and I would urge you to adopt Alternative 1, the No Action
alternative .
On my visits to Kuiu Island I have had the great opportunity and
fortune to stay at the Forest Service cabin on Kadake Bay. This site
offers huge recreation, fishing and hunting opportunity while still
providing solitude. I am very glad to hear the Forest Service plans
to upgrade this cabin. However, I am disturbed to learn that the
Service plans to eliminate needed maintenance and/or close some
public use cabins due to a $300,000 budget shortfall. How can the
Forest Service ignore the large public benefits these cabins provide
while still proposing timber sales that have been proven to loose money?
The economic costs of continuing to loose money on remote timer sales
that require additional road building is not a good use of the public
resource. The Forest Service would better serve the public taxpayers
if it would concentrate timber sales in less remote places that do
not need further road building and do not loose money. It should not
'^lose public use cabins that provide some of the highest public
Benefits. Rather the Service could reduce the number of timber sales
that loose money and apply these savings to support great programs
like the public use cabin system.
I do not want to see any cabin closures and do not support the
proposed timber sale on Kuiu Island.
'^ank you,
John Kober
John Kober
6037 44th Ave SW
Seattle, WA 98136
(206) 778-0883
j ohnkoberOmac . com
154 • Appendix C
Kuiu Timber Sale FEIS
Response to Kober
Kober - 1
The Forest Service acknowledges the importance of Kadake Creek and Bay. There are no
proposed activities within Kadake Bay and the activities planned within Kadake Creek
Watershed are consistent with the expectations for the Timber Land Use Designation
(LUD) and the Kadake Creek Recreational River LUD (Forest Plan p. 3-118).
Kober - 2
Most recreational and fish values of the Kadake watershed are concentrated at the mouth
of Kadake Creek and within the riparian buffer of the creek itself (Forest Plan, Vol.2, pp
E-25 1-254). None of the proposed harvest units or roads would be within these areas. The
fisheries values of Kadake Creek are not expected to change with the proposed project
activities (DEIS p. 3-182).
Kober - 3
Preference for Alternative 1 - the No Action Alternative is noted.
Kober - 4
While the comment regarding the Kadake Creek Cabin and other cabins on the Tongass
is outside the scope of the Kuiu Timber Sale, it will be shared with the staff in charge of
cabins. The funds for the Forest Service are allocated by Congress and the amount of
money allocated to each resource cannot simply be transferred back and forth. The
Forest Service is undergoing a 5 year evaluation process with its public use cabins and is
decommissioning those that cannot be maintained to standard. One cabin in the
Petersburg Ranger District is being decommissioned this year due to lack of use and the
inability to maintain to standard, and it is a cabin that has been unavailable to the public
for over 10 years.
The Forest Service is not mandated to make money by offering timber for sale. This point
is further emphasized in the Forest Supervisor’s 2006 declaration, where it states:
There is no legal mandate for the Forest Service to generate a profit. The Timber
program is not unusual in costing more to operate than the government receives in
revenues for the program. Many programs on the Tongass National Forest
generate no revenue, including the subsistence, heritage, inventory and
monitoring, land management planning, geology, fish and wildlife management,
trail improvements, and fire protection programs. The Tongass National Forest
produces the majority of wildlife and fish for commercial, sport, and subsistence
users in Southeast Alaska, yet receives no returns on its investments. The Tongass
provides cabins for recreational purposes in semi-remote and remote locations of
the Forest. The returns on these investments do not cover annual maintenance
costs of the facilities (Cole, 2006).
Kuiu Timber Sale FEIS
Appendix C • 155
Response to Kober
Kober - 5
The Forest Service is directed to sell commercial timber sales at not less than appraised
rates. Some of the road building for this project is for temporary road construction, which
is a part of the bidder’s costs and is not paid for by the Forest Service.
The aversion to timber sales located in remote areas has been noted. However, this area
has an existing infrastructure of roads and log transfer facilities and is not considered
remote.
Appendix A of the Kuiu Timber Sale Area DEIS states that the Forest Service should
“...concentrate timber sales in less remote places that do not need further road building
and do not lose money.” Subject to appropriations and applicable law, including the
National Forest Management Act, section 101 of the TTRA directs the Secretary of
Agriculture, to the extent consistent with providing for multiple use and sustained yield
of all renewable resources, to “seek to provide a supply of timber from the Tongass
National Forest which (1) meets the annual market demand for timber from such forest
and (2) meets the market demand from such forest for each planning cycle.”
The location of timber sale projects is based first on the land allocation decisions in the
Forest Plan. Under the 1997 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 Land Use Designations. The second
consideration is the suitability of the land for timber production. Keeping in mind all of
the competing management issues across the forest, the decision to propose a timber sale
in the Kuiu area is based on; the consideration of cumulative effects on other resources
from past harvest activities, the location of timber sales under contract, and the eventual
use of all suitable and scheduled lands for timber sale projects.
156 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #16 - Mike A. Jackson
MAJ
1
Mike A. Jackson
PO Box 163, 512 Keku Road
Kake, Alaska 99830
Phone; (907) 785-4177
March 19, 2006
Kris Rutledge, Team Leader
USDA Forest Service
PO Box 1328
Petersburg, Alaska 99833
Re: Kuiu Timber Sale Draft EIS
Dear Ms. Rutledge,
I was bom here in Kake and have lived here in Kake all of my life, except for going out
to Oregon to get my Forest Management Degree. I got manied here, raised my daughter
here and now she has two children that she is raising here in Kake. My father was bom
here and his mother was bom in Saginaw Bay, Kuiu Island in the 1 800's, just like my
great-grandparents and theirs before them. My &mily has camped and will continue to
camp in various bays and watersheds on Kuiu Island, just like my ancestors. I am
opposed to any further logging on Kuiu Island.
When I was a child my femily, along with most of the village would move out to
Cornwallis Point fish camp, and spend most of the spring and part of the summer there.
Other Kake residents went to Kadkke’s Bay, Security Bay, Rowan Bay, Washington Bay,
Bay of Pillars, Tebenkof Bay, Port Camden Bay, High Island, Kushneahin Creek, Three
Mile Arm, Boulder Point, and many other bays and creeks to help supplement their
income earned from working at seasonal canneries and various fisheries. During the
winter I remember my grandfethers, my fether, his brothers and other men from Kake
going out to these same bays and watersheds to trap all of November and part of
December, come home for Christmas and leave for three more months, coming home just
to visit and restock supplies and leave again. I helped my father and seven bo&eis
prepare the 700 mink and martin traps, 100 otter traps and 50 wolf traps.
i raised my daughter, whose original clan village was located in Saginaw, to respect the
place that she lives and comes from, but it is difhcult to see the continued industrial
logging on private and US Forest Service land, the land that we come from. The cunent
village of Kake was originally located on Northern Kuiu Island, we only moved here for
safety reasons, in the past 200 years. The old Kuiu village site went through two floods,
and original village site is under water, and the original creek that sustained the
village is now a small stream, it's watershed was dtanged during the last great flood. The
present village of Kake always was a village site for all the clans that lived around the
Kake area, it was the place for gathering to make peace, hold sacred ceremonies, and plan
events that would involve the whole Tribe.
Kuiu Timber Sale FEIS
Appendix C • 157
Comment Letter #16 - Mike A. Jackson
MAJ
2
MAJ
3
MAJ
4
MAJ
5
MAJ
6 ^
Mike A. Jackson Letter on Kuiu Timber Sale
Draft EIS
Page 2 of 3
r
I grew up following in my Jfalher’s footsteps using Kuiu Islands for customary &
traditiojoal gathering (subsistence). My &mily still gathers from the same sites that our
ancestors have and we still acknowledge the sacred sites and practice our Indigenous
Religion in areas that we have been taught to. It is hard to share our sacred sites with the
US Forest Service because they may be shared with the public for educational and
scientific purposes. We continue to gather and camp on Kuiu Island, its shoreline and
/Water that surrounds the island. I am concerned about the continued sedimentation
caused by building roads, logging and log transfer sites. Hie Kuiu Island Draft EIS
(DEIS) states that the logging plan will contribute more sedimentation to the already
disturbed watersheds, affecting the fisheries that we depend on. We use some of the
following bays for subsistence gathering: Port Camden, Security Bay, Kadake Bay, and
other bays and watersheds to fish for Coho and Dog Salmon. The EIS also states that
logging is necessary even though the EIS also sites that the subsistence gathering of the
Kake people will be significantly impacted by the logging, primary the impact on deer
populations.
V
The US Forest Service (USFS) uses their notices of open house for proposed timber sales
and subsistence meetings as the only notification to I<^e that they are going into log a
certain area. I took part of a USFS meeting when 1 was in high sdiool, here in Kake,
when the USFS told the community it was going to log our watershed with a balloon
^ystem, a system they help subsidize. With Kake Tribal, Sealaska and the USFS logging
our watershed we are IucIq' to still have potable water. 1 would like the USFS to do
mearimgful consultation with the Organized Village of Kake, on a govemment-to-
govemment level, to plan for a sustainable, small, local logging for the small local
savimulls along the existing road system on Kuiu/Kupreanof Island, and help subsidize
them as much as they subsidize the large logging and mill companies. In fret, I
recommend the USFS to give all the money used to subsidize frdtering large logging
and mill companies to all the rural communities in S£ Alaska and watch the communities
build a local sustainable program that would employ more forest workers than the few
that the large companies employ. I would like to see all the USFS employees continue to
help this new sustainable rural forest companies/co-ops, in fact I would wager that the
USFS on the Tongass would be the most popular lan^ord in the natioir. Granted some
communities will not want to develop or continue the logging around their villages.
In the recent NRDC v. USFS, the 9* Circuit Court of Appeals found fundamental defects
in the 1997 Tongass Forest Plan based on the substantial error made by the USFS in
estimating the market demand for Tongass Timber. The Court directed the USFS to
revise the Tongass Forest Plan, with that; 1 suggest that the USFS not advertise any more
timber sales until a new Forest Plan is done.
Three subsistence hunters from Kake died on January 1, 2004 trying to cross Fredrick
Sound from Admiralty Island. Kake subsistence hunters have been displ^ed from
hunting in the safe inter-islands of Kupreanof and Kuiu Islands by the cumulative effects
~of logging by the USFS. Today hunters still have to cross Fredrick Sound to subsistence
-hunt. The Denali Commission of Alaska wrote to Kenneth Brewer, PresidsutiCEO of the
158 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #16 - Mike A. Jackson
MAJ
6 contd.
Mike A. Jackson Lett^ on Kuiu Timber Sale
Draft EIS
Page 3 of 3
SEARHC Hospitals in Sitka and Juneau, dated Febniaiy 13, 2006 is attached, stating that
Kake is a ‘^duitr^ed’’ community under the Denali Commissiim’s Code. Your
Kuiu Island Draft £1S contains old employment statistics; I demand that the USFS
update its section on employment that is over two years old!
As stated at the beginning I am opposed to any further industrial size logging on Kuiu
Island, that would make me j&vor your Alternative A in the Kuiu Timber Sale Draft EIS.
Kuiu Timber Sale FEIS
Appendix C • 159
Response to Mike A. Jackson
MAJ - 1
Opposition to any further logging on Kuiu Island is noted.
MAJ - 2
The Forest Service acknowledges that much of Kuiu Island is a customary and traditional
use area for people from Kake. During the Alaska Wilderness, Recreation and Tourism
(AWRTR V. Monison Settlement Agreement) Workshops held at Kake, many areas
formerly open to commercial timber harvest received special protection in the Forest
Plan. Examples of these areas include: Rocky Pass, Pillar Bay, Kadake Creek, Fall Dog
Creek, the Red Cedar Area. All beach and estuary areas are protected with the 1000 foot
beach/estuary buffer.
MAJ -3
The Kuiu Timber Sale DEIS (p.3-182) states that there will be temporary increases in
sediment delivery to streams, primarily due to road construction activities. The EEIS has
been updated to clarify the ‘temporary increases’ as sediment levels are expected to
return to normal within 48 hours of the completion of construction work. These
temporary increases in sediment are not expected to significantly degrade water quality or
fish habitat. The streams are expected to continue to support the fisheries on which
subsistence users depend. Port Camden, Security Bay, and Kadake Bay are not expected
to be affected by this project. Current conditions of Rowan Bay and Saginaw Bay are
described in the DEIS (p. 3-180 and 3-181). The project will use either the existing
Rowan Bay or Saginaw Bay LTFs. Logs will likely be barged from the sites, although
there is a possibility logs will be placed into the water and rafted for towing from the
bays. Barging logs will not increase bark accumulation at either site. Log rafting will
cause newly dislodged bark to accumulate at the sites. Annual monitoring will determine
the amount of accumulation, if any, and trigger cleanup if accumulation exceeds
Environmental Protection Agency’s National Pollutant Discharge Elimination System
(NPDES) permit requirements.
The DEIS (p. 3-95 and 3-269) states that the potential foreseeable effects from the action
alternatives in the Kuiu Timber Sale Area are not expected to result in a significant
restriction of subsistence uses of Sitka black-tailed deer, black bear, moose, furbearers,
marine mammals, upland birds, water fowl, salmon, other finfish, shellfish, or other
foods.
MAJ -4
The Eorest Service attempted to involve as many people as possible in the planning
efforts. As early as Eebruary of 2004, scoping letters were sent to City and Tribal
governments and interested citizens of Kake. That letter signified the beginning of the
planning process and desire for input. Open houses were held in July and November of
2004 in which additional input to the proposals was solicited. A subsistence hearing was
held in March of 2006. Information about the open houses and subsistence hearings was
sent out on the scanner, by newspapers and posted on bulletin boards in town.
160 • Appendix C
Kuiu Timber Sale FEIS
Response to Mike A. Jackson
On November 22, 2004, several members of the Kuiu Timber Sale planning team
accompanied Patricia Grantham, Petersburg District Ranger, to Kake. The Forest Service
group met with Henrich Kadake, Sr., OVK President, and other OVK members, where
the Kuiu Timber sale was discussed including a presentation of the SHPO report.
The Forest Service is currently planning a timber sale on Kupreanof Island that will
consider timber sale opportunities for small-scale operators. Due to the expense of
mobilization to and from Kuiu Island, lack of any local processing facilities, and the
distance to established processing facilities it is unlikely that an operator will be
interested in purchasing timber sale offerings with volumes less than 1,000 MBF from
this Project Area (DEIS Chapter 3 p. 3-105 and the FEIS Chapter 3-Timber Sale
Economics section). It is not the policy of the Tongass National Forest to subsidize
sawmills large or small.
MAJ -5
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands.
The Tongass National Forest will continue to be managed in compliance with Section
101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which (1) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
As described more fully in Appendix A of the FEIS, to provide a steady flow of timber
harvest volume, timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand.
MAJ -6
The Eorest Service acknowledges the loss of three hunters from Kake and recognizes that
deer populations on Kuiu Island have not returned to historic levels since the die off in
the late 60 ’s and early 70 ’s, which forces hunters to travel farther than they might
otherwise.
The PEIS has been updated to include current population estimates and used the
following income and employment information.
U.S. Census data for Year 2000 shows the median household income was
$39,643, per capita income was $17,41 1, and that 14.61 percent of residents were
living below the poverty level.
A letter dated Pebruary 2006 from the Denali Commission confirmed Kake’s
classification as a distressed community. Based on 2003 data, the Denali
Kuiu Timber Sale FEIS
Appendix C • 161
Response to Mike A. Jackson
Commission estimates Kake average market income as below the $14, 872
threshold level and that more than 70% of residents age 1 6 and over earned less
than the threshold.
The FEIS has been updated as much as possible with the following sites used as sources:
1 1. Alaska Department of Commerce, Community and Economic Development
community database (www.dced.state.ak.us),
12. Denali Commission website (www.denali.gov),
13. Kake Community Economic Development Strategy (2004) (the page
provided)
14. U.S. Census Bureau, Census 2000 (http://censtats.census.gov/pub/Profiles.shtml)
15. personal communication with Kake Schools, OVK, the City and Jeannie Monk
(Denali Commission).
The Forest Service notes that Kake Foods has not operated in the past two years and that
Kake Tribal has recently sold all of its logging equipment. The Forest Service also
acknowledges that as income has dropped, reliance on subsistence has increased. The
FEIS Environmental Justice section has been expanded to recognize the above-mentioned
condition in Kake and acknowledge that during times of economic hardship tribal
members depend even more on the gathering of customary and traditional foods. This
project is not expected to make conditions worse, and there may be some opportunities
for employment as a result of the project.
162 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #17 - Steve Mashuda
Mashuda
1
Steve Mashuda
1000 25'" Ave. E
Seattle, WA98112
grizmer@aol.co
(206) 322-7932
March 20, 2006
Via electronic mail
Kris Rutledge, Team Leader Attn: Kuiu
Timber Sale USDA Forest Service
P.O. Box 1328 Petersburg, AK 99833
RE: Kuiu Timber Sale DEIS
Dear Kris:
Thank you for the opportunity to comment on the Draft Environmental Impact
Statement (“DEIS”) for the Forest Service’s proposed Kuiu timber sale. The action
alternatives propose logging between 14.6 million board feet of timber from 491 acres to
42.65 MMBF from 1,425 acres from the Kuiu Timber Sale Area on north Kuiu Island.
Each of the action alternatives includes a significant amount of clearcutting in several
watersheds, including Kadake Creek, Saginaw Bay, Rowan Bay, and Security Bay. I
write to urge the Forest Service to adopt Alternative 1, the “No Action” alternative. I
^write with special emphasis on the place I know best, the Kadake Creek watershed.
Over the past five years, I have come to treasure Kuiu Island, making the trek
from Seattle via Petersburg a number of times to fish for steelhead and coho salmon,
dolly varden, sea-run cutthroat, and Dungeness crab in Kadake creek and Kadake bay.
I’ve hiked (and sometimes struggled) through much of the low-elevation old growth in
the Kadake watershed. I’ve had the privilege of watching and photographing the island’s
black bears, wolves, bald eagles, waterfowl, river otters, and deer. Several good friends
and I fly into the Forest Service cabin in Kadake Bay at least once a year to fish, hunt
waterfowl, and hike. On these trips, 1 spend over $800.00 on lodging in Petersburg - on
chartered float plane flights, fishing licenses, groceries, camping and fishing supplies,
and entertainment - all in just two days on either side of our flights to the Kuiu.
I’ve seen first hand the devastation caused by intensive logging outside the
Roadless Areas on the north end of the island. Attached to these comments is a Google
Earth satellite photograph of the proposed Project Area that shows the pattern of past
harvest units pock-marking the northern part of Kuiu. That image, which I witnessed
from the air flying into Kadake Bay on a clear day, speaks volumes about the wisdom
of additional large-scale logging on the island. Others, including the Tlingit natives of
the Village of Kake, can attest more accurately to the value of this area for native
Alaskans and the impacts that this legacy of past logging on the island have had on their
Kuiu Timber Sale FEIS
Appendix C • 163
Comment Letter #17 - Steve Mashuda
use of the area.
Mashuda
2
Despite these impacts, parts of North Kuiu still retain their wild character. Both
the Forest Service and the Alaska Department of Fish and Game (ADF&G), have made
official what the people of Kake and anyone who’s ever hooked a steelhead in Kadake
Creek, struggled to find a stream crossing amongst throngs of spawning pink salmon, or
feasted on Dungeness crab from Kadake Bay in September, already know - the Kadake
watershed is a special place. The Tongass Fish and Wildlife Resource Assessment
identified the stream systems for the Saginaw, Security, Rowan, and Kadake watersheds
(all affected by the action alternatives) as primary salmon producers. ADF&G
designated Kadake Creek in particular as a primary sportfish producer and one of 19
“high value” watersheds in Southeast Alaska. In 1997, the Forest Service recommended
23 miles of Kadake Creek as a recreational river under the Wild and Scenic River Act
because of its high historic, recreation, and fisheries values.
Mashuda
3a
Mashuda
3b
Mashuda
3c
Mashuda
3d
The DEIS does not adequately discuss the potential for significant effects to any
of these watersheds and their fisheries from siltation, including the potential for increased
sedimentation to destroy productive salmon spawning habitat. Further [logging or road-
building, including construction of so-called “temporary” roads, is inconsistent with
protecting the recognized cultural, fish and wildlife, and recreational values of these
watersheds, especially Kadake Creek.] I urge the Forest Service to [consider an
alternative that would exclude this watershed and other sensitive areas from any timber
^ale units.] While such an alternative could take many forms, [the agency should
examine an alternative that includes selective logging from existing road systems by
smaller-scale operators.] I understand that this program has been used successfully
blsewhere in the Tongass to meet legitimate demand for timber while protecting vital
natural resources.
Mashuda
4
Mashuda
5
^ Though the DEIS does not disclose or otherwise analyze this issue, the Ninth
Circuit Court of Appeals last year invalidated the Tongass National Forest Plan
because, among other things, it contained a fatally flawed economic analysis that
“inflated the economic benefits and discounted the environmental impacts of the Plan.”
See Natural Resources Defense Council v. U.S. Forest Service, 421 F.3d 797, 81 1 (9
Cir. 2005). But this proposed sale appears to be based on that same flawed plan. It is an
unfortunate, but now well-documented fact, that the Forest Service loses millions of
dollars annually on its timber sale program both in Southeast Alaska and on the
national level. This sale, with its construction of 19 miles of new roads, is no
exception.
r At the same time, the Forest Service has proposed to close, sell, or eliminate
needed repairs to several recreational cabins in the Tongass because of a budget shortfall
of approximately $300,000.00 in its recreation program. The agency’s multiple-use
mandate requires the Service to treat recreation and timber production at least on an equal
basis. It simply does not make any sense to be proposing to close cabins that provide
access and recreational opportunities to the public because of budget shortfalls while
simultaneously proposing another timber sale that will lose more money. The Forest
Service needs to take a step back and take a comprehensive look at the Tongass Forest
rlan with these kinds of discrepancies in mind and fix the Plan before moving ahead with
164 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #17 - Steve Mashuda
this sale.
Mashuda
6
On a related, but contrasting note, it is heartening to see that the Tongass National
Forest has proposed, through its recreation master plan, to up.rade the cabin at Kadake
Bay. As mentioned earlier, this cabin provides access to some of the best fishing,
hunting, and recreational opportunities in Southeast Alaska. These are the kinds of
decisions that make sense and ensure long-term economic productivity from the Forest.
Mashuda
7
V.
r Thank you for the opportunity to comment on this proposed sale. For all of the
reasons discussed above, the Forest Service should drop its proposal for this sale. North
Kuiu Island is the . Short of that, the EIS process should be suspended at least until the
Tongass National Forest Plan is amended or rewritten to comply with the Ninth
Circuit’s NRDC decision. Only after that can the Forest Service have a chance to
produce a Final Environmental Impact Statement that considers the full economic and
environmental costs and benefits of this sale along with a broader range of action
Alternatives and other uses of the forest that protect the unique resources on Kuiu Island.
Sincerely,
/s/
Steve Mashuda
Kuiu Timber Sale FEIS
Appendix C • 165
Response to Mashuda
Mashuda - 1
Preference for Alternative I, the No- Action Alternative, has been noted.
Mashuda - 2
As noted, parts of North Kuiu Island still retain their wild character and it is the intention
of the Kuiu Plan that the area will still retain wild characteristics after implementation of
the proposed project.
Most recreational and fish values of the Kadake watershed are concentrated at the mouth
of Kadake Creek and within the riparian buffer of the creek itself (TLMP, Vol.2, pp E-
251-254). None of the proposed harvest units or temporary roads would be within these
areas. The fisheries values of Kadake Creek are not expected to change with the proposed
project activities (DEIS p. 3-182).
The activities planned within the Kadake Creek Recreational River Land Use
Designation (LUD) are consistent with the expectations for that LUD. Suitable forested
land is available for harvest within the Recreational River LUD if the adjacent Land Use
Designation allows timber harvest (Forest Plan p. 3-118) as is the case in The Kuiu
Timber Sale Area (see Unit Cards Appendix B p. B-83 and B-85). Alternatives 1, 3, and
5 do not propose any harvest within the Recreational River LUD. Alternative 2 proposes
1 8 acres of partial timber harvest within the Vi mile wide river corridor and Alternative 4
proposes 49 acres of partial harvest. See also Greenpeace Response #4 1 .
Mashuda - 3a
The expected effects of the proposed project include temporary increases in sediment
delivery to streams, primarily during road construction (DEIS p. 3-182). However,
sediment delivery to streams associated with this project is not expected to significantly
degrade fish habitat. The strategy for avoiding significant effects to streams within the
Project Area includes the implementation of Forest-wide Standards and Guidelines and
Best Management Practices (BMPs) (pp. B-6 - B- 10 of the DEIS). Site specific design
and mitigation measures for protecting streams are listed on the unit card narratives
(DEIS B-16 to B-95) and are incorporated into road construction plans. Action
alternatives proposed in this project would increase the amount of open road temporarily,
but would ultimately reduce the amount of open road within the Project Area (DEIS
Table 3-50, p. 3-129).
The DEIS (p.3-182) acknowledges that there will be an increase in sedimentation from
temporary road construction and reconditioning; however, this effect is expected to be
short term (clarified in the FEIS as 48 hours after construction). The placement of stream
buffers and the implementation of BMPs (DEIS Appendix B pp. B-7 - B -9) is expected
to minimize the amount of sediment entering streams. The following statement has been
added to the DEIS; Because sedimentation may reduce oxygen levels to developing eggs
in spawning gravel and/or trap emerging fry in the gravel construction, timing windows
for stream crossings on roads proposed for reconditioning or storage will be implemented
(DEIS p. 3-175).
166 • Appendix C
Kuiu Timber Sale FEIS
Response to Mashuda
Mashuda - 3b
See Mashuda #2 and Greenpeace Response #41.
Mashuda - 3c
Alternative 1 , the No- Action alternative, does not propose any timber harvest or road
building within the Kadake watershed. While Alternatives 2-5 do propose timber harvest
within the Kadake watershed. Alternatives 3 and 5 do not propose harvest within the '/2-
mile wide river corridor that is recommended as a Recreational River in the Wild and
Scenic River System. The harvest proposed by Alternatives 2 and 4 within the corridor is
limited to 18-acres partial harvest in unit 415 and an additional 31 acres partial harvest in
Unit 41 in Alternative 4. See also Greenpeace #41.
Mashuda - 3d
The alternatives were developed in response to issues raised during public scooping, and
timber sale economics was one of the issues identified. Supplying timber for a small
sales program, as exists on other areas of the Tongass National Forest, is a program set up
exclusively for the small mills and individuals from the numerous communities located
around that area. Kuiu Island does not have the same level of community development as
Prince of Wales Island, where the small sale program is located. Without this community
structure, it is unlikely minor amounts of down or dead trees from the existing road
system would provide economic timber.
The Forest Service is currently planning a timber sale on Kupreanof Island that will
consider timber sale opportunities for small-scale operators.
Mashuda - 4
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is currently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
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, trail improvements, and fire protection
programs.
Mashuda - 5
Kuiu Timber Sale FEIS
Appendix C • 167
Response to Mashuda
The Multiple-Use Sustained Yield Act of 1960 directs the Forest Service to consider and
manage all the resources on the national forests. It also recognizes that some land will be
used for less than all of the resources. The Act does not mandate equal spending for each
resource on the national forest. The Forest Service is allocated a certain amount of
funding for recreation, timber and other resources with specific direction on how to use
that money. The amount of money allocated to each resource is beyond the scope of this
project.
The Forest Service is undergoing a 5-year evaluation process with its public use cabins,
and is decommissioning those that cannot be maintained to standard. One cabin in the
Petersburg Ranger District is being decommissioned this year due to lack of funding and
lack of demand, and it is a cabin that has been unavailable to the public for over 10 years
due to its poor condition.
The Forest Service is directed to sell commercial timber sales at no less than appraised
rates. The Kuiu Timber Sale is not a deficit sale.
Mashuda - 6
The Forest Service is glad to have agreement with some of the management decisions.
Mashuda - 7
For the rest of the comments see the response to Mashuda - 4.
168 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #18 - Chris Zimmer
Zimmer
1
Zimmer
2
Zimmer
3
Zimmer
4
Zimmer
5
"chris Zimmer"
<zimmer@alaska .net>
03/20/2006 07:29 PM
To; <Comments-alaska-tongass-petersburg@fs.fed.us>
cc:
Subject; Kuiu Timber Sale
Kris Rutledge, Team Leader
Attn: Kuiu Timber Sale
USDA Forest Service
P.O. Box 1328
Petersburg, AK 99833
Thank you for considering these comments on the proposed Kuiu Timber Sale. The four action
alternatives propose logging between 14.6 million board feet (MMBF) of timber from 491 acres
and 42.65 MMBF from 1,425 acres from the Kuiu Timber Sale Area on north Kuiu Island.
Significant clearcutting will be involved. This sale area includes parts of Rowan Bay (VCU 402)
and Kadake Creek (VCU 421), most of the land in Saginaw Bay (VCU 399) and the eastern half
of Security Bay (VCU 400). All involve logging in the Kadake Bay watershed.
The Tongass Fish and Wildlife Resource Assessment (ADF&G, 1998) identified the stream
systems for the Saginaw, Security, Rowan, and Kadake VCUs as primary salmon producers.
ADF&G also identified Kadake Creek as a primary sportfish producer and one of 19 “high
value” watersheds in Southeast Alaska. Despite this ranking, and the Forest Service’s decision
to recommend 23 miles of Kadake Creek as a recreational river imder the Wild and Scenic River
Act because of its high historic, recreation, and fisheries values in 1997, the action alternatives
"^propose logging in the watershed. There should be no logging or road-building, including
temporary roads, in the Kadake watershed.
Kadake is a valuable recreational, cultural and environmental resource. The island has already
^een heavily logged and clearcut. Additional logging and roading pose unacceptable risks to the
watershed and to the people who use and rely on it. I urge you to adopt Alternative 1 , the No
Action Alternative.
There does not appear to be a pressing economic need for the sale. Last summer’s ruling by the
9th Circuit showed that the Tongass Forest Plan significantly inflated estimates of the demand
for Tongass timber in order to justify the economics of logging. One reasonable alternative to
the four action alternatives described in the DEIS is a timber sale program similar to that
developed on Prince of Wales Island. Under that “microsale” program, the Forest Service makes
available timber from the existing road system to supply wood specific to small purchaser’s
^operations. The court termed the forest plan “fatally infected” and required a revised plan for the
Tongass. Despite the court order, the Forest Service continues to use the discredited plan as the
basis for opening up more wild forest land to logging. This flawed plan should be fixed before
^any more sales are offered.
I applaud the Forest Service’s plans to upgrade the public use cabin in Kadake Bay. I have
visited the cabin several times. This area offers excellent hunting and fishing and excellent
opportunities for solitude and wilderness experiences. However, I am disturbed by plans to close
Kuiu Timber Sale FEIS
Appendix C • 169
Comment Letter #1 8 - Chris Zimmer
some cabins in the Tongass or to eliminate needed maintenance due to a $300,000 budget
Zimmer shortfall. There is documented evidence that the Forest Service’s logging program in Southeast
5 contd. Alaska loses millions of dollars every year. The Forest Service should curtail the money-losing
timber sales and apply savings to the recreation program. The Forest Service should not be
closing cabins when it continues to offer money-losing timber sales.
Sincerely,
Chris Zimmer
5957 Thane Road
Juneau, AK 99801
170 • Appendix C
Kuiu Timber Sale FEIS
Response to Zimmer
Zimmer - 1
Most cultural, historical, recreational, fish and wildlife values of the Kadake watershed
are concentrated at the mouth of Kadake Creek and within the riparian buffer of the creek
itself (TLMP FEIS, Appendix, Vol. 2, pp E-25 1-254). None of the proposed harvest
units or roads would be within these areas. See also Mashuda #2 and GSS #41.
Zimmer - 2
Preference for Alternative 1 - The No Action Alternative, is noted.
Zimmer - 3
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongass Forest Plan adopted in 1997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. The court did not
find a willful inflation of market demand to justify logging. In response to the Court
ruling, the Forest Plan is currently being amended through an environmental impact
statement. The DEIS for the amendment was released for public comment in January
2007.
FAA is currently analyzing market demand. Appendix A has been updated with the
information from Brackley et al.
The microsale program on Prince of Wales Island referenced in the comments is a timber
sale consisting of dead or down timber, which has been proposed by a prospective
purchaser, that the District Ranger agrees to offer for bidding using an informal
advertisement and short Bid Form. The maximum size of a microsale is 50 MBF and
$10,000 advertised value. District Rangers review each proposed microsale that is greater
than 25 MBF for its potential as a regular small sale.
Kuiu Island does not have the same level of community development as Prince of Wales
Island. Without this community structure, it is unlikely the same demand will exist for
minor amounts of down or dead trees from the existing road system.
Zimmer - 4
The court listed its findings in Natural Resources Defense Council v. U.S. Forest Service
but did not require the Forest to revise the plan. In response to the court’s decision the
Tongass chose to amend the Forest Plan. Until the revision is completed, projects will
move forward, with the Forest Plan continuing to be the guiding document and contract
with the public.
The Tongass National Forest will continue to be managed in compliance with Section
101 of the Tongass Timber Reform Act of 1990 (TTRA), which modified the Alaska
National Interest Lands Conservation Act (ANILCA). This states that the Secretary of
Agriculture “...shall, to the extent consistent with providing for the multiple use and
sustained yield of all renewable forest resources, seek to provide a supply of timber from
the Tongass National Forest which (1) meets the annual market demand for timber from
such forest and (2) meets the market demand from such forest for each planning cycle.”
Kuiu Timber Sale FEIS
Appendix C • 171
Response to Zimmer
As described more lully in Appendix A of the FEIS, to provide a steady flow of timber
harvest volume, timber sale projects need to be completed through the NEPA process
each year to meet current and future market demand.
Zimmer - 5
The Forest Service is undergoing a 5-year evaluation process with its public use cabins,
and is decommissioning those that cannot be maintained to standard. One cabin in the
Petersburg Ranger District is being decommissioned this year due to lack of funding and
lack of demand, and it is a cabin that has been unavailable to the public for over 10 years
due to its condition
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, trail improvements, and fire protection
programs.
172 • Appendix C
Kuiu Timber Sale FEIS
I
1
i
I
NRDC- 1
I
I
1
NRDC -2
NRDC -3
Comment Letter #19 - NRDC form letter
February 20*March 20, 2006
Kris Rutledge, Team Leader
Attn: Kuiu Timber Sale
USDA Forest Service
P.O. Box 1328
Petersburg, AK 99833
Subject: Kuiu timber sale
Dear Team Leader Rutledge,
I oppose any new roads or logging in the Security or North Kuiu roadless
areas of the Tongass National Forest, and I urge the Forest Service to
^ withdraw its proposal for the Kuiu timber sale. The surrounding region has
^ already been logged extensively, and more clearcuts would rentove the
best of the remaining forest and could forever change the habitat of what
may be the highest densities of black bears anywhere in North America.
This incredible wild area is virtually the last unlogged and road-free fish
and wildlife habitat in this portion of Kuiu Island, supporting Sitka black-
^ tailed deer, moose, marten, wolves and salmon.
^ In addition to permanently obliterating wild roadless areas, any logging
project would likely increase taxpayer subsidies, threaten important native
ancestral grounds and endanger local industries such as commercial
fishing, tourism and hunting. Again, I urge you to withdraw your proposal
to log roadless areas in the Kuiu timber sale.
Sincerely,
Kuiu Timber Sale FEIS
Appendix C • 173
Response to NRDC form letter
NRDC - 1
Opposition to new road building and logging on Kuiu Island has been noted.
NRDC -2
Concern over the acres of clearcuts on Kuiu Island in noted. The 27,856 acres of harvest
referred to are located on an island that is 482,101 acres, 64 percent of which is in non-
management LUDS (Kuiu Island Landscape Assessment). Less than six percent of the
island has been harvested and less than five percent of the major watersheds have any
harvest in them. In addition there is a forest-wide system of protection provided by other
non-development LUDs (282,558 acres on Kuiu Island) that maintain the integrity of the
forest-wide ecosystem and provide future options for maintaining naturally occurring
ecosystems.
The Project Area is mostly roaded. The use of the existing road system was one of the
reasons this area was chosen.
NRDC -3
See response GSS-12
174 • Appendix C
Kuiu Timber Sale FEIS
Comment Letter #20 - WS form letter
March 2 -March 15, 2006
Kris Rutledge, Team Leader
Attn: Kuiu Timber Sale, USDA Forest Service
P.O. Box 1328
Petersburg, AK 99833
Subject: Kuiu timber sale
Dear Team Leader Rutledge,
^ I urge you to cancel the proposed Kuiu Timber Sale immediately.
Please halt all sale preparations and cease any further plans to log or build
roads on North Kuiu Island.
North Kuiu Island is already heavily logged and roaded. Clearcutting and
building more roads within remnant wildlife habitat will bring further, and
irreparable, harm to the cultural traditions of the local TIingit people. It is
not in the best interests of our nation.
You are logging America’s rainforest under a deeply flawed forest plan that
^ is costing taxpayers millions of dollars. Please end those losses now.
Sincerely,
Form Letter
Kuiu Timber Sale FEIS
Appendix C • 175
Response to WS form letter
WS-1
The request to cancel the proposed Kuiu timber sale has been noted.
In August 2005, the Ninth Circuit held that the environmental impact statement and
record of decision for the Tongas's Forest Plan adopted in 1 997 had errors relating to the
use of projected market demand for timber, the range of alternatives considered, and the
cumulative effects of activities on non-National Forest System lands. In response to the
Court ruling, the Forest Plan is cun'ently being amended through an environmental
impact statement. The DEIS for the amendment was released for public comment in
January 2007.
The past harvest and road construction referred to is located on an island 482,101 acres in
size of which 64 percent is in non-management LUDs (Kuiu Island Landscape
Assessment). Less than six percent of the island has been harvested and less than five
percent of the major watersheds include any harvest.
On p. 3-26 of the DEIS it states, “The Eorest Plan contains a comprehensive conservation
strategy to assure viable and well-distributed wildlife populations (Forest Plan FEIS
Appendix, Volume 4, Appendix N, 1997).” The DEIS goes on to explain much of this
strategy. While there is expected to be some effects from the proposed actions of each
alternative, the cumulative effects listed on pp. 3-72 thru 3-74 do not identify any threats
to the viability to any species from the proposed timber harvest activities.
The Conservation Strategy Review Workshop was conducted April 10-14, 2006 at the
Ted Eerry Civic Center in Ketchikan Alaska. Key Findings from the workshop are listed
below:
• The Conservation Strategy is still sound.
• There is a low risk of species viability problems related to Forest Plan
implementation.
• Endemic species continue to be a high priority information need.
• There is good opportunity to manage habitats to emphasize production of prey
species of other foods.
• Management of young-growth forests for wildlife habitat is promising,
especially for species like black-tailed deer.
• There is a need to better understand the role and management of the Matrix
part of the Strategy, including the role of non-National Forest System lands.
• The wildlife monitoring program needs to be updated.
The historic and current use of Kuiu Island for subsistence deer hunting has been updated
in the FEIS (see Response to OVK 2a). Analyses for heritage resources, subsistence, and
socioeconomics can be found in Chapter 3.
176 • Appendix C
Kuiu Timber Sale FEIS
GX> U.S. GOVERNMENT PRINnNG OFFICE: 2007 — 676-080 / 03115 Region No. 10
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.
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