Historic, Archive Document
Do not assume content reflects current
scientific knowledge, policies, or practices.
United States
Department of
Agriculture
Forest Service
Alaska Region
Tongass
National Forest
R10-MB-311b
December 1 995
Central Prince of Wales
Supplement
to the Final Environmental
Impact Statement
Central Prince of Wales
Final Supplement to the
Final Environmental Impact Statement
Record of Decision
Ketchikan Area - Tongass National Forest
USDA Forest Service
Alaska Region
Lead Agency USDA Forest Service
Tongass National Forest
Ketchikan Area
Responsible Official Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
For Further Information Contact David Arrasmith, Planning Staff Officer
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Contents
Record of Decision 1
Background 1
Decision 2
Reasons for Decision 2
How Issues Are Addressed 4
Issue 1 : Falldown 4
Issue 2: Sustainability 4
Additional Issues Raised in Comments on the Draft Supplement 6
Public Involvement 7
Coordination with Other Agencies 8
Description of Options 8
Options Eliminated from Detailed Study 8
Options Considered for Detailed Study 8
Environmentally Preferred Option 8
Planning Record 8
Findings Required by Law 9
Federal and State Permits 9
Implementation Process 9
Process for Change During Implementation 9
Right to Appeal 10
Contact Person
11
Record of Decision
Background
The Record of Decision (ROD) for the CPOW FEIS was published on August 6, 1993.
The ROD documented the decision of the Ketchikan Area Forest Supervisor to implement
alternative F5 (as modified) as the selected alternative which would harvest 267 MMBF on
approximately 9,836 acres and would meet the purpose and need for the project.
The ROD was followed by a 45-day appeal filing period which ended on September 20,
1993. Five appeals of the CPOW ROD were received.
On November 23, 1993, the Regional Forester’s appeal decisions on the Central Prince of
Wales project affirmed the Ketchikan Area Forest Supervisor's decision. On
February 2, 1994, the Reviewing Officer for the Chief of the Forest Service affirmed the
Regional Forester's appeal decisions on all CPOW appeals and appeal points.
Five offerings or releases of timber from the CPOW project were made to Ketchikan
Pulp Company (KPC) between February and December 1994. These releases totaled
approximately 78 million board feet (MMBF).
On June 1, 1994, Sierra Club Legal Defense Fund, Inc., filed a complaint for declaratory
judgement and injunctive relief on behalf of its clients (SEACC, et al.) in the United
States District Court, District of Alaska. The complaint named the Ketchikan Area
Forest Supervisor and the Forest Service as defendants and challenged the CPOW timber
project: The complaint alleged violations of the National Environmental Policy Act
(NEPA), the Administrative Procedures Act (APA), and the Tongass Timber Reform Act
(TTRA). The NEPA and APA allegations focused on the volume of timber available in
the project area and the sustainability of future timber supply. The TTRA allegation
challenged the method used for determining proportionality in the CPOW project under
Section 301(c)(2) of the TTRA.
On December 20, 1994, the Forest Supervisor partially suspended implementation of the
CPOW ROD pending completion of a Supplement to the CPOW FEIS. The Forest
Supervisor did not suspend implementation on the 78 MMBF previously released in the
project, nor an additional 20 MMBF in two offering areas being contemplated for release
to KPC prior to April 1996. These two offerings were made to KPC in 1995 and totaled
approximately 18 MMBF
A Notice of Intent to prepare a Supplement to the CPOW FEIS was published in the
Federal Register on April 5, 1995. The Draft Supplement to the CPOW FEIS was
published in July 1995.
FINAL SUPPLEMENT TO THE CPOW FEIS
Record of Decision-1
RECORD OF DECISION
Decision
It is my decision to continue implementing the CPOW project. My rationale for this
decision is shown below.
Reasons for Decision
• Continuing the project as planned should result in the harvest of approximately
214 MMBF of the 267 MMBF cleared in the original CPOW ROD, taking into
account 20 percent project level falldown. Halting the project now would result
in harvest of only 96 MMBF previously released. Continuing the project as
planned will more closely approach meeting the stated purpose and need of 290
MMBF for the CPOW project than would halting the project now.
• Sustainability is a standard required by the National Forest Management Act
and regulations stated in 36 CFR 219 to be applied at a National Forest level.
While not a legal requirement for a project area, current and projected timber
harvest levels help provide a measure by which decisions affecting community
stability can be made.
• In Chapter 4 of the Final Supplement, one estimate of suitable timber remaining
for harvest in the project area is that represented by the combined CPOW MELP
and the updated LSTA from the Control Lake Cumulative Effect Analysis. The
combination of the MELP and LSTA offsets some of the weaknesses identified
for each study as documented in Chapter 3 of the Supplement. Each analysis
identifies harvestable timber in areas the other study did not consider.
The Final Supplement indicated that a modified version of this combination
provided the best assessment of harvestable timber in the project area. That
modification recognized moderate to high risk factors including encumbered
lands, steep slopes, and high vulnerability karst. Based on these risk factors, the
Final Supplement proposed that 84,345 acres of suitable timber was the best
assessment of remaining timber available in the project area.
I disagree with this rationale. The only factor that should be considered in
modifying the combined results of the MELP and the updated LSTA is
conveyed lands. Of the 4,539 acres of suitable timber located on encumbered
lands in the updated LSTA, 3,218 acres have been conveyed to the State of
Alaska or Sealaska Corporation. Of the remaining 1,321 acres, 504 acres have
been selected by the State of Alaska as low priority, 798 acres have been
selected by Sealaska Corporation but appear unlikely to be conveyed, and 19
acres were incorrectly identified as encumbered. Removing only those
conveyed acres from the acres of suitable timber identified in the combined
CPOW MELP and the updated LSTA would result in a total of 91,025 acres of
potentially harvestable timber.
Other high risk factors recognized in the updated LSTA should not be dropped
from harvest consideration until further field reconnaissance (recon) occurs. If
potential harvest acres are found to be unharvestable, they are accounted for as
part of the anticipated recon and implementation falldown of 23 percent
discussed in the Supplement.
2-Record of Decision
FINAL SUPPLEMENT TO THE CPOW FEIS
RECORD OF DECISION
• Projected harvest on the CPOW project area over the current ten-year sale plan
through year 2004, including the remainder of the CPOW project, will average
17 MMBF per year. If the project were to be halted, average annual harvest on
the project area would drop to 10 MMBF.
• The combined MELP and updated LSTA (modified by the deduction of
conveyed lands) suitable timber estimate would yield an average annual harvest
of 3 1 MMBF beyond the year 2004, after the completion of the CPOW project
and additional planned timber projects in the area. If the project were halted,
the potential average annual harvest could be as much as 35 MMBF. While
both figures are lower than historic harvest of 52 MMBF annually, both are
higher than harvest currently planned for the period of 1995 through 2004.
• Community stability is affected by timber harvest over a larger area than that
defmed by the CPOW project. In this case, harvest on Prince of Wales Island as
a whole was also considered. Over the next ten year period (through 2004)
average annual harvest on Prince of Wales is projected to be 69 MMBF,
including the completion of the CPOW project. If the project were to be
deferred until after the year 2004, the average annual harvest would be
61 MMBF on the island.
• TLMP (1979a) scheduled commercial forest land (CFL) on the CPOW project
area is 71,666 acres. The suitable acres identified by the combined MELP and
LSTA (excluding conveyed lands) amounts to 91,025 acres, or 127 percent of
TLMP scheduled CFL. Extrapolating that proportion to TLMP (1979a)
scheduled CFL for Prince of Wales Island as a whole (333,159 acres), the
resulting suitable timber estimate is 423,1 12 acres. This would yield a potential
average annual harvest of 167 MMBF beyond the year 2004, assuming the
CPOW project is completed. If the project is halted and remaining volume
rescheduled, the potential average annual harvest on Prince of Wales would be
168 MMBF. Both figures are greater than the historic average annual harvest of
122 MMBF on Prince of Wales.
• The ten-year sale schedule(Appendix G) reflects a lower planned harvest than
can reasonably be expected in the future, even considering a 23 percent
falldown factor.
• If falldown approaches 30 percent (combined hard falldown of 23 percent and 7
percent soft falldown at moderate to high risk of not being scheduled for
harvest), future harvest potential on both the project area and Prince of Wales
Island could exceed harvest planned over the next ten year period.
• The next ten-year period from 1995 through 2004 is expected to experience
lower timber harvest volumes on the CPOW project area and on Prince of Wales
Island than that experienced in the past. Potential future timber harvest levels
are projected to be greater than those that will occur over the next ten years.
• I believe that deferring the remainder of the CPOW project during a period of
exceptionally low timber harvest is not justified by the long-term benefits of a
1-3 MMBF increased average annual harvest expected in the future. This
long-term benefit does not outweigh the immediate disruption of community
stability if the CPOW timber project is brought to a halt.
FINAL SUPPLEMENT TO THE CPOW FEIS
Record of Decision-3
RECORD OF DECISION
• Reallocation of timber harvest based on speculative changes to the allowable
sale quantity (ASQ) is best addressed through the Tongass Land Management
Plan revision process, not in a project level decision document such as this
Supplement.
How Issues Are Addressed
ISSUG 1 1 The issue of falldown was not fully addressed in either the CPOW DEIS or the CPOW
Falldown FEIS. The Supplement reviewed The Irland Group Report, the Forest Service
Evaluation of The Irland Group Report, and data gathered during the field
reconnaissance of the CPOW, Lab Bay, Control Lake, and Polk Inlet projects. In
addition, data gathered during the implementation of 121 CPOW harvest units
(approximately half of the total planned units) provided a site-specific and accurate
measure of falldown that can be expected during project implementation.
The relative strengths and weaknesses of applying falldown projections from each of
these sources to the CPOW project were discussed. Based on the information and
analysis displayed in the Supplement and the planning record, the falldown percentages
of 8 percent during field reconnaissance and 15 percent during project implementation
are the best available information regarding hard falldown. Soft falldown factors
encountered during field reconnaissance (10 percent) and project implementation
(5 percent) were also identified. While some soft falldown is simply the rescheduling of
proposed harvest until the next project, some falldown is implemented for resource
protection measures until standards and guidelines are formulated and implemented
through revision or amendment of the Forest Plan. The potential for 7 percent soft
falldown (moderate to high risk of not being harvested) is addressed in the Supplement.
If this soft falldown factor of 7 percent is applied to potential harvest volumes, one could
expect an average annual harvest of 29 MMBF from 2005 through 2054 on the CPOW
project area if the project continues as planned. If halted now, average annual harvest
from 2005 through 2054 may be 32 MMBF. If the 7 percent factor is applied to harvest
on Prince of Wales Island, the average annual harvest from 2005 through 2054 would be
slightly under 153 MMBF if the CPOW project continues as planned. If the project is
halted, average annual harvest on Prince of Wales would yield slightly more than 153
MMBF. Even with this additional 7 percent soft falldown, potential harvest on the
project area and on Prince of Wales Island beyond year 2005 is greater than planned
harvest over the next ten years, whether or not the CPOW project continues as planned.
Estimated falldown discussed in The Irland Group Report and the Forest Service
Evaluation of The Irland Group Report are not inconsistent with the site-specific data
generated on the Prince of Wales projects. These reports were intended to be forest-wide
(Tongass NF) projections bearing on the ASQ proposed by the alternatives in the
Supplement to the Draft Environmental Impact Statement, Tongass Land Management
Plan Revision published in 1991. Their findings are not as accurate as the data collected
on the project area over the past several years.
Issue 2: The issue of sustainable timber harvest was addressed in both the CPOW DEIS and the
Sustainability CPOW FEIS. The Supplement provides additional analysis and data on this issue.
The CPOW DEIS used results of the CPOW MELP (identified as 52,727 acres in the
DEIS) to project potential future harvest levels on the project area. The CPOW FEIS
used TLMP Draft Revision Alternative P projections of suitable timber (1 14,016 acres)
to predict potential future harvest levels.
4-Record of Decision
FINAL SUPPLEMENT TO THE CPOW FEIS
RECORD OF DECISION
The Supplement uses site-specific data from the CPOW MELP (50,288 acres in the
CPOW FEIS) and the updated logging system transportation analysis (LSTA) from the
Control Lake Cumulative Effects Analysis (75,205 acres) as starting points for the
analysis of potential timber harvest levels from the CPOW project area. The updated
LSTA for the project area is the result of updating resource databases on the Ketchikan
Area in project areas identified in the ten-year sale plan. These estimates of suitable
timber are compared with TLMP (1979a) planned harvest represented by scheduled CFL
for the project area.
The combination of these two studies offsets some of the weaknesses of each discussed
in Chapter 3 of the Supplement. The MELP was not an attempt to identify all
harvestable suitable timber within the project area, and the updated LSTA did not
identify harvestable timber beyond the suitable timber identified by using updated
resource data and TLMP Draft Revision Alternative P standards and guidelines. The
combination provides the most accurate estimate of timber harvest opportunities in the
project area from which future projects will be identified. The total suitable acreage
identified by the two studies is 94,243 acres. There is a 31,250 acre overlap between the
two.
Analysis of the data provided with the updated LSTA revealed a potential risk to harvest
for 9,898 acres. These risks involved steep slopes, high vulnerability karst, excessive
numbers of streams, V-notches, and encumbered lands. Of this total, 4,539 acres fall on
lands selected by the State of Alaska or the Sealaska Corporation.
Of the 4,539 acres of suitable timber on encumbered lands, 3,218 acres have been
recently conveyed to either the State of Alaska or Sealaska Corporation. Of the
remaining 1,321 encumbered acres, 1,302 have been selected but are of lower priority.
These acres will probably remain in the National Forest System. There are 19 acres that
were mistakenly identified as encumbered but are not.
Excluding only those conveyed lands from the total harvest potential provides a more
accurate forecast of potential timber harvest levels on the project area. The result of
excluding conveyed lands from the combined MELP and the updated LSTA total is
91,205 acres of potentially harvestable timber. This total exceeds TLMP (1979a)
scheduled CFL (71,666 acres) for the project area, though it does not equal the suitable
timber identified by the Draft Revision Alternative P (1991) of 1 14,260 acres.
The combination of the MELP and the updated LSTA (excluding conveyed lands) would
allow an average annual harvest of 3 1 MMBF from 2005 through 2054. This exceeds
the ten-year sale plan average of 17 MMBF for the project area.
Updated LSTAs for the remainder of the project areas identified in the ten-year sale plan
were not yet available at the time the Supplement was completed. In order to provide an
estimate of suitable timber available over the remainder of Prince of Wales Island, the
proportion of the five suitable timber estimates to TLMP (1979a) scheduled CFL for the
CPOW project area were applied to the scheduled CFL for Prince of Wales.
The proportional amount of suitable timber that may be available on Prince of Wales as a
whole (based on the combined LSTA and MELP excluding conveyed lands) would yield
an average annual harvest of 167 MMBF from 2005 through 2054 given an average
falldown of 23 percent and completion of the CPOW project as planned. It should be
noted that only the most conservative estimate (the overlap between the LSTA and
the MELP) would have resulted in a future average annual harvest less than that expected
over the 1995 through 2004 period.
FINAL SUPPLEMENT TO THE CPOW FEIS
Record of Decision-5
RECORD OF DECISION
Additional Issues Raised in Comments on
the Draft Supplement
Some comments indicated that timber harvest under the Long-term Contract with
Ketchikan Pulp Company is unsustainable.
The contention that logging under the KPC contract is unsustainable is a conclusion
that cannot be reached based on the analysis of timber supply on one project area.
Sustainability is a legal requirement that applies to a National Forest rather than a
project area. Whether or not Long-term Contract commitments can be met on the
Tongass National Forest and how much suitable timber will remain for harvest on the
Tongass and the Ketchikan Area beyond the end of the contract in the year 2004 is
beyond the scope of this Supplement.
There is no assurance of an even flow of timber from any given project area for each
year or each decade. Initial entries into areas have traditionally harvested
proportionally more timber and more easily accessible timber than later entries. This is
done to offset high initial roading and logging camp costs (Alaska Regional Guide, p. 2-
48). Future entries would have proportionately lower harvest volumes. There are
project areas on the Ketchikan Area, such as the Cleveland Peninsula, that have
experienced little to no harvest to this point. Substantially less than 50 percent of the
suitable timber has been harvested in the first 50 years of the timber rotation.
Potential harvest of timber in the CPOW project area may be lower than has occurred
historically. This has been documented and discussed in the Supplement. This is not
relevant to the decision to be made. The issue addressed by this Supplement is how
much suitable timber remains for harvest on the project area and the allocation of
harvest over the next decade compared with potential harvest in future decades. The
decision to be made is how much of the CPOW project should be re-allocated to harvest
in future decades based on what is planned for harvest in the next ten years as compared
with potential harvest in the decades beyond.
Several comments received stated that the Forest Plan ASQ should be changed to reflect
the effects of falldown.
The Forest Plan ASQ is established through amendment or revision of the Forest Plan.
This is beyond the scope of the Supplement. Analysis regarding falldown was forwarded
to the TLMP Revision Team for use in the current revision effort. Updated resource
databases provided by the contractor performing the Control Lake Cumulative Effects
Analysis were also forwarded to the TLMP Revision Team. Falldown is the subject of
one of the sixteen science assessments and resource analyses being prepared by the
Revision Team.
Comments were also received that express concern that there is less suitable timber on
the CPOW project area than projected by Alternative P of the Proposed Revised Forest
Plan (1991) raising the question of an ASQ of 418 MMBF as opposed to TLMP (1979a)
ASQ of 450 MMBF.
The results of intensive efforts to identify suitable timber on one project area best apply
to that project area. While it would appear that 20 percent less suitable timber may be
found on the CPOW project area than projected by Alternative P (proposed ASQ of 418
MMBF), that may not hold true for other project areas.
6-Record of Decision
FINAL SUPPLEMENT TO THE CPOW FEIS
RECORD OF DECISION
Some comments requested that the scope of the Supplement be broadened into
discussions of viable wildlife populations including Alexander Archipelago wolf and
Queen Charlotte goshawk. Other comments suggested that we delay the Final
Supplement until new habitat capability models can be developed.
The scope of the Supplement was clearly defined by the memo directing the Supplement
IDT to prepare a supplement regarding f alldown and its effects on timber harvest.
Wildlife population viability, more accurate habitat capability models, and the status of
the wolf and goshawk were addressed in the CPOW FE1S including the Biological
Assessment. These issues are currently being dealt with in the revision of the TLMP, the
draft of which is due for publication by the end of the calendar year. These issues are
clearly beyond the scope of the decision to be made for this one project.
Comments expressed concern that the current Forest Plan ASQ of 450 MMBF cannot be
sustained from now through the end of the rotation without disastrous effects on the local
and regional economy as well as subsistence lifestyles.
The point must be made that ASQ is a ceiling on decadal amounts of timber harvest that
may be accommodated on a National Forest level. From 1954 through 1990, average
annual harvest has averaged 364 MMBF, well less than the ASQ of 450 MMBF. This
allows some flexibility and room for decision-making that will accompany the Forest
Plan Revision. While the concerns raised are not groundless, they are not grounds for
immediate cessation of timber projects pending the revision of the Forest Plan.
Public Involvement
A Notice of Intent to prepare a Supplement to the CPOW FEIS was published in the
Federal Register on April 5, 1995. A letter explaining the supplement process and
describing the focus of the analysis was mailed on April 10, 1995 to over 700 individuals
and organizations on the original CPOW mailing list. Those interested in
remaining on the Supplement mailing list were asked to complete and return an attached
form. Eight-five respondents indicated their interest in the project by returning
completed forms.
The CPOW Supplement was also placed on the NEPA Schedule of Proposed Actions for
the Ketchikan Area. This schedule is updated quarterly and mailed directly to 67
individuals and organizations. The quarterly schedule gives a brief description of the
project and a contact person for more information.
The Draft Supplement to the CPOW FEIS was published in late July and mailed to all
interested parties in the first week of August. A notice of Availability was published in
the Federal Register on August 1 1 with a comment period ending September 25, 1995.
A total of seven comment letters were received.
A press release regarding the Draft Supplement was issued on August 23, 1995. The
press release briefly summarized the issues of falldown and the implications for
sustainable timber harvest and provided information for those persons wishing to
comment.
FINAL SUPPLEMENT TO THE CPOW FEIS
Record of Decision-7
RECORD OF DECISION
Options
Eliminated from
Detailed Study
Options
Considered for
Detailed Study
Environmentally
Preferred Option
8-Record of Decision
Coordination with Other Agencies
Appendix C lists all individuals and organizations to whom copies of the Final
Supplement to the CPOW FEIS were provided. The Alaska Department of Fish and
Game and the United States Department of Interior provided comments on the Draft
Supplement. Their comment letters and Forest Service responses are included in
Appendix F.
Description of Options
The original alternatives examined in detail in the CPOW FEIS were not considered
in detail in the Supplement. The estimated harvest volumes ranged from 261 MMBF
to 268 MMBF for the action alternatives and no harvest for the no action alternative.
The original alternatives were not examined in detail as they do not take into account that
the selected alternative (F5) has been partially implemented and the no action alternative
would now have to account for the harvest of 98 MMBF. Additional information is
provided in the Preface of the Supplement.
Two options were considered for this Supplement. The first option was to halt the
CPOW project after an estimated 98 MMBF had been released. The second option was
to continue the CPOW project as planned. The effects of these two options on future
harvest volumes in the project area and over Prince of Wales Island as a whole were
displayed.
A wide range of options was not considered as the purpose and need for the project
remains valid. The option of continuing the project as planned meets the purpose and
need for the project. Halting the project now would not meet the purpose and need.
Of the two options analyzed, the option to halt implementation of the CPOW project now
would result in less timber harvest over the next ten years. That deferred volume would
then be rescheduled for harvest between 2005 and 2054. This option has fewer
short-term effects on the environment, but there would be little to no difference over the
course of the rotation through 2054. Based on this analysis, the option to halt
implementation of the CPOW project would be the environmentally preferred option.
This option was not selected as it does not meet the purpose and need for the CPOW
project.
Planning Record
The planning record for the Supplement to the CPOW FEIS is available for review, by
appointment, at the Forest Supervisor's Office in Ketchikan, Alaska. The planning record
also includes the certified administrative record for the CPOW project, TLMP (1979a),
TLMP Draft Revision (1991), and the Regional Guide.
FINAL SUPPLEMENT TO THE CPOW FEIS
RECORD OF DECISION
Findings Required by Law
The original CPOW Record of Decision (July 93) documented how the CPOW project
and the decision to implement the project complied with the following laws:
National Forest Management Act
Tongass Timber Reform Act
Endangered Species Act
Bald Eagle Protection Act
Clean Water Act
National Historic Preservation Act
ANILCA Section 810
Executive Orders 1J988 and 1 1990 (floodplains and wetlands)
Coastal Zone Management Act
Compliance with these laws and executive orders has not changed with the decision I
have made as documented in this Record of Decision.
Federal and State Permits
This decision does not obligate the Forest Service to obtain any permits in addition to
those already described in Chapter 1 of the CPOW FEIS.
Implementation Process
Implementation of this decision may occur no sooner than 30 days after the date of
publication of the notice of decision and availability of the Final Supplement in the
Federal Register, or 50 days following publication of the legal notice of the decision in
the Ketchikan Daily News, published in Ketchikan, Alaska, whichever is later.
Process for Change During Implementation
Proposed changes to the authorized project actions will be subject to the requirements of
the National Environmental Policy Act (NEPA), the National Forest Management Act of
1976 (NFMA), Section 810 of the Alaska National Interest Lands Conservation Act
(ANILCA), the Tongass Timber Reform Act (TTRA), the Coastal Zone Management Act
(CZMA), and other laws concerning such changes.
In determining whether and what kind of NEPA action is required, the Forest Supervisor
will consider the criteria for whether to supplement an existing EIS in 40 CFR 1502.9(c)
and FSH 1909.15, sec. 18, and in particular, whether the proposed change is a substantial
change to the selected alternative as planned and already approved (CPOW FEIS and
ROD, July 1993), and whether the change is relevant to environmental concerns.
Connected or interrelated proposed changes regarding particular areas or specific
activities will be considered together in making this determination. The cumulative
impacts of these changes will also be considered.
FINAL SUPPLEMENT TO THE CPOW FEIS
Record of Decision-9
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