Historic, Archive Document
Do not assume content reflects current
scientific knowledge, policies, or practices.
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United States
II Department of
Agriculture
Forest Service
Tongass
National
Forest
R10-MB-136
Shelter Cove
Final Environmental
Impact Statement
Alaska Region
Ketchikan Area
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Volume II: Maps, Comments on DEIS
Final Environmental Impact Statement
Shelter Cove
U.S.D.A. - Forest Service
Alaska Region
Alaska
Lead Agency:
U.S.D.A. Forest Service
Tongass National Forest
Ketchikan Area
Federal Building
Ketchikan, Alaska 99901
Responsible Official:
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
For Further Information
Contact:
Steven T. Segovia
Ketchikan District Ranger
3031 Tongass
Ketchikan, Alaska 99901
Contents
NOTE: This document is to be used in conjunction with Volume 1 as a reference aid for
referring to figures mentioned in the text.
Chapter 1 Maps Figures 1-1 to 1-2
Chapter 2 Maps Figures 2-1 to 2-5
Log Transfer
Facilities and Site
Location Maps
Figures 2-6 to 2-12
Monitoring Reports
Figures 2-13 to 2-14
Chapter 3 Maps Figures 3-1 to 3-11
Chapter 4 Maps Figures 4-1 to 4-25
Alternative Maps Figures A2 to A6
Comments on DEIS
Chapter 1 Maps
Figure 1-1
VICINITY MAP
Chapter 2 Maps
LEGEND
□ HARVEST UNITS
□ SALTWATER
FRESHWA TER
~ PROPOSED ROADS
“ PR I V A TE END
~ VCU END
SHELTER
NORTH
Figure 2-1
COVE
ALTERNATIVE 3
ALTERNATIVE 4
LEGEND
Q HARVEST UNITS
□ SALTWATER
FRESHWA TER
- PROPOSED ROADS
~ PRIVATE BND
- VCU BND
NORTH
SHELTER COVE
Figure 2-3
ALTERNATIVE
LEGEND
□ HARVEST UNITS
□ SALTWATER
FRESHWA TER
” PROPOSED ROADS
“ PRIVATE BND
~ yet/ MD
NORTH
SHELTER COVE
Figure 2-4
Figure 2L5
Log Transfer Facilities
and Site Location Maps
Log Transfer Sites Investigated
The first map indicates all new sites that were considered. Those that were eliminated did
not meet pertinent siting guidelines and are indicated on the maps as investigated sites.
The preferred sites were investigated and are proposed for use in the various alternatives
considered in this document.
The next two maps refer to the individual existing and proposed (non-existing) log transfer
sites that are planned for use in the alternatives in this document.
Figure 2-6
Figure 2-7
Osten
Island
HUME ISLAND
EXISTING L.T.F.
REVILLAGIGEDO
ISLAND
Existing
Private
Road o
500 1CCC
^Hume
j j Is land X
V v*
Ccc!e in Ycrds
-£ Log Transfer S te
//Vl Leg Raft Arec
REVILLAGIGEDO
\ „ ISLAND
ALTERNATIVE
2
3
4
5
6
Used
X
X
Reconstruction
SYSTEM TYPE
Double A-Frame
X
X
Slide
Float - Off
Figure 2-8
Preliminary Reconnaissance Reports
These site diagrams relate to the Area L.T.F. Sites Map.
Site 1 —
Shelter Cove
Development
• Rock borrow is adjacent to the site.
• Good beachhead adjacent to site for equipment mobilization.
• Site requires moderate fill and rock excavation.
Access
• Access road would be about Vi to V* mile long.
• Road will contain some minor segments with very steep grades.
• Site is adequate for a drive-through loop road.
• Approach to dump position is suitable.
• Access road will have a very heavy through-cut adjacent to the site. The cut will be
about 100' long and 20-30' deep. This can serve as a rock source if it proves
adequate.
Water Beach Conditions
• The site has adequate water depth.
• According to the navigational charts, Carroll Inlet has very good depth.
• Ample raft and booming area is available at the site.
Environmental
• The site appears to lie in a favorable area.
• Water depth indicates suitable flushing.
• Eagle Tree Atlas does not indicate the presence of any eagle trees.
• Site is protected from weather.
Recommendations
• The site appears to be adequate and should be considered further. Marine, archaeo-
logical, and economic impacts should be evaluated in more detail. Additionally, the
area should be surveyed for eagle trees.
Operations
• The site appears to have adequate upland area.
• Favorable for A-frame system.
• Dry sort and storage is not available at the site. Dry sort and storage may possibly
be located 14 to Vi mile from site.
Figure 2-9
Site 2
Site 2 contained a 70-80' high ridge within the site. Development would be very dif-
ficult and expensive. This site was not given further consideration.
Figure 2-10
Operations
• Site is of adequate size.
• Favorable for A-frame.
• Dry sort and storage would have to be accomplished within 14 mile of the site. If
done at the TTF, much rock excavation would be necessary to develop dry storage
and sort.
Development
• Rock source is adjacent to the site.
• Good beachhead near the site for equipment mobilization.
• Site requires moderate fill and much rock excavation.
Access
• Access road would be about 3/i to 1 mile long.
• Site access road would have moderate grades and alignment.
• Site is excellent for a loop drive-through system.
• Approach to dump position is excellent.
Water Beach Conditions
• Site has adequate water depths for A-frame operations.
• Ample water maneuvering room for raft and booming operations.
Environmental
• Site is 14 to Vi mile from tideflat areas and about Vi mile from any significant
streams.
• Site is protected from weather.
• Eagle tree atlas does not indicate any eagle trees present on site.
Recommendations
• From an operational and development standpoint, this site appears to be superior to
all other sites considered; however, access is extremely difficult for development. If
marine, archaeological, and economic impacts are favorable, this site should be con-
sidered further. The site should be investigated for eagle trees as the West Carroll
shoreline appears to contain a number of them.
Figure 2-11
Site 4 Operations
• Site is of adequate size.
• Dry sort and storage cannot be accommodated at the site. This would have to be
developed about !4 mile inland.
• A-frame or chain slide would be best suited to this site.
Development
• Site will require a fill 70-75 ' out from the vegetation line on the beach.
• Rock source is unknown. The fill adjacent to the site had no exposed rock to verify
a source.
• Site has good beachhead at north edge of site for equipment mobilization.
Access
• Site access would have moderate grades near the site.
, • Access road would be about 1 to 1 14 mile long.
• Large fill will accommodate drive-through loop. Excavated area can also provide
part of the loop. Chain slide system would require heavy excavation for ingress and
egress because the slide would not require a large fill, thus moving operations back
into the uplands.
Water Beach Conditions
• The site would require the TTF face to be 70-75 ' from the vegetative line to reach
sufficient water depth.
• Tidal action at the site appears to create a fast current. Log rafting would be
located directly south of the site at an area with 40' of water depth.
• Ample water area to handle logs for rafting and booming.
Environmental
• The site is about !4 mile from a tideflat area lying to the north. The navigational
charts show that the channel has a deep pocket between Osten Island and the site.
This may trap bark and prevent it from dispersing further out into Carroll Inlet.
Recommendations
• This site is an adequate site; however, the fill will be large. The site will require
review from marine, archaeological, and economic standpoints.
Figure 2-12
Operations
• The site is suitable for A-frame, chain slide, crane or derrick systems.
• Dry sort and storage area appears to be developable adjacent to the site.
Development
• Rock source availability is unknown.
• Site requires a large fill to reach water depth for all tidal operations.
Access
• Terrain appears to be flat to moderate, providing minimal roading problems.
• Good beachhead landing at the site for equipment mobilization.
• This site is on private land requiring rental, share cost, or other agreement.
Water Beach Conditions
• Full depth water is about 70-80 ' seaward from the vegetation line.
• Ample maneuvering room for rafting and booming.
• Area is protected from weather.
Environmental
• According to the Forest Service Eagle Atlas, two or three eagle trees are present at
or adjacent to the site.
• The site is within !4 mile of shallow tideflat beaches to the north and west of the
site.
Recommendations
• An economic analysis should be conducted to determine share cost, lease, rental
haul, and construction costs that would be applied to government use of the site.
Additionally, the site should be investigated for archaeological and marine impact.
Impacts must be evaluated to determine if it will be necessary to conduct any
special operations to accommodate eagle activity. Eagle trees are protected under
Federal law.
Site 5 —
Salmonberry Site
Cape Fox, Inc.
Figure 2-13— Unit Monitoring Report
Unit Monitoring Report
Date
Unit
vcu#
Camp
Road No.
Photo #
Quad Map
T.
R.
Unit litvonf Date
Unit Harvest Date
Sale Admin. Rv:
Monitored Bv:
Stream Name
ADF&G ft
Stream Class - I. Anadromous
II. Resident
III. Water Quality
Channel Tvpe
Channel Width
Length of Affected Area
Temp. Sensitive?
□ Yes □ No
Riparian Harvest
R. Bank
L. Bank
Both Banks
Standards & Guidelines Implemented (%) Effectiveness (%) Comments
Directional Felling
Split Yarding
Full Suspension
No Cut Zones
Selective Harvest Zone
Alluvial Fan S&G
Off Channel/Unmapped
Temperature Sen. S&G
Sideslope Stability
Windfirmness
Other
Discussion:
Figure 2-14— Road Monitoring Report
Road Monitoring Report
Date Unit
Camp Road No.
Quad Map T.
Road No.
Road Layout Date
COR
vcu# _
Photo #
R. _
Structure Type/Size
Road Construction Date
Monitored By:
Stream ADF&G ft
Stream Class - I. Anadromous II. Resident III. Water Quality
Fish Species Present
Channel Type Channel Width Substrate
Gradient at Crossing: Up Down Velocity (CFS)
Habitat Upstream
Habitat Downstream
Standards & Guidelines Implemented (%) Effectiveness (%) Comments
Fish Passage Provided
Construction Timing
Equip Stream Crossing
Sediment Control
Culvert Placement
Culverts Installed
Concurrent with Rocking
Flow Constriction
Seeding of Banks
Other
Discussion:
Chapter 3 Maps
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Figure 3-1
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MAXI MUM MODIFICATION
INVENTORIED
VISUAL QUALITY OBJECTIVES
INCLUDING POTENTIAL VIEWSHEDS
Figure 3-2
Relationship Between Visual Quality Objectives and Visual Condition
VOO Preservation
VC I Natural Condition
Predominately ecological changes.
VOO Retention
VC II Natural Appearing
Changes are not evident.
VOO Partial Retention
VC II Slightly Altered
Changes are noticed, but do not
attract attention.
NATURAL CHARACTER DOMINATES
VQO Modification
VC IV Moderately Altered
Changes are easily noticed and
attract attention.
VOO Maximum Modification
VC V. Heavily Altered
Changes are very strong and
attract attention.
VOO Unacceptable Modification
VC VI Drastically Altered
Changes are in glaring contrast
and disharmony with natural
patterns.
ALTERED CHARACTER DOMINATES
Figure 3-3
1
Figure 3-4
-
.
EXISTING VISUAL CONDITION
Figure 3-4
Figure 1-5
ADED MODIFIED
ADED NATURAL
Figure 3-6
ROADED MODIFIED
ROADED NATURAL
SEMI -PRIMI T I VE MOTORIZED
SEMI-PRIMITIVE NON-MOTOR I ZE D
PRIMITIVE 1 OR 2
SCALE IN MILES
Figure 3-6
Figure
Figure 3-7
Re villagigedo Island Project Area
LEGEND
EXISTING ROAD
PROJECT BOUNDARY
Figure 3-8
Revillagigedo Island Project Area
LTF LEGEND
K) EXISTING SITE
Figure 3-9
NORTH
SHELTER COVE
LEGEND
~ WATERSHED
END
~ AMO-CLASS
/
“ jiMZ-CIylSS
2
~ AHMU-CLASS
2
Figure 3-10
MAJUK CHANNEL, TYPES
■
Chapter 4 Maps
ALT
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2mm LE.NS
NORTH SRDDLE LAKES -LARGE LAKE LOOKING SOUTH
FIELD-OF-VIE-4 JSi
ALT
OUTLET Or SALT LRGOON LOOKING NE
Unit 41
ALT
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ERST OF SHELTER COVE- LOOKING NW
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riELD-OF-VIEW- 35.
OUTLET OF SflLT LRGOON LOOKING NC
V
OUTLET OF SALT LAGOON LOOKING NE
or ISLAND PT. LOOKING sw.
oTLET SFLT LFGrGN LOCKING Nr
NAHA- HECKMAN LAKE-LOOKING TO HEAD OE LAKE
riELD-Or-VIEW • J5mm CAMERA with 38. Gram LENS
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Unit 47
vie* distance:
PROPOSED
OLD GROWTH AREAS
Fig. 4-20
ALTERNATIVE 2
WILDLIFE OLD GROWTH
Fig. 4-21
ALTERNATIVE 3
WILDLIFE OLD GROWTH
^EFFECTIVE OLD CROWTU DLOCkS
□ SALT WATER
Fig. 4-22
ALTERNATIVE 4
WILDLIFE OLD GROWTH
Fig. 4-23
ALTERNATIVE 5
WILDLIFE OLD GROWTH
^EFFECTIVE OLD t ROWTB BLOCKS
□ SALT tATER
Fig. 4-24
ALTERNATIVE 6
WILDLIFE OLD GROWTH
Fig. 4-25
Alternative Maps
S33
LTERNATIVE 2
LECEND
M HARVEST UNITS
B OLD-GROWTH PRESCRIPTION
AFRESH WATER
SALT WATER
“ PROPOSED ROADS
~ PRIVATE BND
- VCU BND
SCALE / . 86,740
SHELTER COVE
Figure A2
LE CEftD
Figure A4
L TERN A T I VE
LEGEND
H HARVEST UNITS
MOLD-GROWTH PRESCRIPTION
□ FRESH WATER
SALT WATER
~ PROPOSED ROADS
~ PRIVATE END
~ VCU BND
J
Figure A5
L TERN A T I VE 5
LECEND
H HARVEST UNITS
MOLD-GROWTH PRESCRIPTION
B FRESH WATER
SALT WATER
~ PROPOSED ROADS
~ PRIVATE BND
~ VCU BND
LEGEND
Figure A6
Comments on the
Draft Environmental
Impact Statement
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KETCHIKAN GATEWAY BOROUGH
^ Planning Department
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344 Front Street
Ketchikan, Alaska 99901
228-6610
January 9, 1991
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JAN 10 1990
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Steven T. Segovia
Ketchikan District Ranger
3031 Tongass
Ketchikan, Alaska 99901
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Re: Shelter Cove DEIS, preliminary CZMP review.
State ID Number: AK901218-05J
Project Description
A draft Environmental Impact Statement has been prepared by the
U.S. Forest Service to describe alternatives for the harvest of
timber in and around Shelter Cove and George Inlet of the Tongass
National Forest. The Forest Service proposes to harvest between
61.8 and 95.6 million board feet of timber during the next five
years. The applicant is the U.S. Forest Service.
Findings
The Ketchikan District has reviewed the above referenced
application, and finds that the proposed project is consistent with
the Ketchikan District Coastal Management Program provided the
following conditions are met:
A. The applicant shall meet all applicable federal laws and
regulations .
B. The applicant shall meet all applicable state laws and
regulations .
Supporting Data
The project is located in the Future Development Zone and is a
permitted principal use in that zone.
This project is supported by the Ketchikan Gateway Borough
Comprehensive Plan.
Steven T. Segovia
Page 2
January 9, 1991
Zoning Permit
The applicant is required to obtain a zoning permit from the
Borough Planning Department prior to the construction of all
structures .
Stephen G. Hanis
Assistant Planning Director
SGH/bjs
cc : Lorraine Marshall, Department of Governmental Coordination
Letter from Stephen G. Hanis, Assistant Planning Director
Ketchikan Gateway Borough
Response:
Thank you.
o
HISTORIC
KETCHIKAN
ALASKA
J34 FRONT STREET
KETCHIKAN ALASKA «*WOI
907-225-3111
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
^ ^ C E i y E 5
MAYOR TED FERRY
ITY OF KETCHIKAN
i-U
January 30, 1991
S r
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Subject: 1950 - Shelter Cove Draft Environmental Impact Statement, Alaska Region,
Ketchikan Area
Dear Sirs:
In reference to the Shelter Cove EIS you are currently reviewing, I would like to go on
record in support of the position taken by the Ketchikan Gateway Borough as outlined in
their letter to you dated January 14, 1991. I fully concur with the Gateway Borough’s
selection of Alternative Number Three (3) (the Recreation/Visual Resource Emphasis
Alternative) as being in the best interests of our area. I concur with the Borough that
Alternative Number Three (3) will assist local officials with trying to meet the increased
community demand for economic stability, public access, and recreational needs.
The Ketchikan area serves as a hub for all of Southeast Alaska and has a responsibility
to foster recreation, economic development and public access for its citizens and the
large number of visitors to our area. Ketchikan Public Utilities is in the process of
developing an intertie which will traverse the Borough to the north of the Island and will
need a right-of-way to accomplish this very important project for Southeast Alaska.
Because Ketchikan Public Utilities and the community wish to proceed with development
of this transportation/utility corridor in an ecologically feasible manner, it is lending its
support to the development of a right-of-way that will encompass as much as is possible,
a designated corridor for a joint right-of-way for both of those projects.
I would ask that the Shelter Cove EIS acknowledge the potential crossing of such an 7 |
intertie right-of-way and make provision for this potentiality. I have provided testimony on J
the Shelter Cove EIS, the Leask Lakes and White River area land exchange and in
support of the Alaska Energy Authority /Ketchikan Public Utilities intertie transportation/
utility corridor project from Swan Lake to Lake Tyee.
007-Y7.1
Forest Supervisor
January 30, 1991
Page 2
As a life long resident of the Ketchikan community, I send this letter to you with the
breadth of feeling and concern that has lead me to be so active in the community over
these many years, and I truly believe that the pulse of this community lies in support of
Alternative 3, and in the development of the transportation/utility corridor from Lake Tyee
and the Ketchikan area.
Sincerely,
CITY OF KETCHIKAN d/b/a
KETCHIKAN PUBLIC UTILITIES
Ouy ui r\eiui ut\cti i
TWSiLLH
cc: Ralph Bartholomew, Ketchikan Gateway Borough Mayor
007-Y 72.
Letter From Ted Ferry, Mayor of the City of Ketchikan
Comment 1 : (paraphrased)
I ask that the EIS acknowledge the potential crossing of a public utilities intertie and the potential need
of a right-of-way and to make provision for this potentiality.
Response 1:
Roads planned in the Shelter Cove DEIS indicate several potential crossings of the Ketchikan Public
Utility power transmission lines. Such crossings will be coordinated with Ketchikan Public Utilities during
the design and construction phases.
In reviewing your concerns relating to power transmission corridors, I am assuming you are referring
to areas outside the Shelter Cove project area. The transmission corridor is already in place and requires
no additional right-of-way. From your statements, I believe you are relating to the Tyee intertie which runs
from Swan Lake northward. This is not in the project area.
.
.
if m
January 14, 1991
Stephen Ambrose
Acting Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
RE: 1950 - Shelter Cove Draft Environmental Impact
Statement, Alaska Region, Ketchikan Area
Dear Mr. Ambrose:
At the request of the Ketchikan Gateway Borough Assembly, I am
forwarding this letter in response to the U.S. Forest Service
request for comments and recommendations on the Shelter Cove Draft
Environmental Impact Statement.
We would like to state what our principal community objectives are
regarding this sale, and thereby explain our basis for supporting
Alternative 3. In no priority order these objectives are:
* The retention and continued viability of a principal
economic base — the timber industry. Alternatives that
provide jobs and community income were judged as more
valuable than those not providing a reasonable level of
timber harvest.
* Access to and recreation within significant recreation
areas . The Community Attitude Survey ( for outdoor
recreation) found a very great need for additional roaded
recreation opportunities . Alternatives providing more
recreational opportunities and that protect such
resources through 'retainance areas' were judged more
valuable than those not providing such areas and
opportunity.
Stephen Ambrose
Page 2
January 14, 1991
* The ability to create a road system that can eventually
be upgraded to an acceptable public access standard for
an inter/intra island road. Alternatives that provided
more such access and that could be integrated with an
eventual inter-island road were judged more valuable than
other alternatives .
* The minimization of impact upon habitat resources, but
within the context of meeting the previously stated
objectives .
Based on these objectives, the Borough Assembly finds that
Alternative 3, the Recreation/ Visual Resource Emphasis alternative,
as presented, to be adequate and supportable by the Ketchikan
Gateway Borough as we attempt to meet community economic, access,
and recreational needs .
Of primary concern to the Borough within this environmental impact
statement is that the economic base provided by the timber industry
to the community remain at a constant level . The timber industry
continues to be a major source of employment within the Borough,
employing roughly twenty percent (20%) of the total labor force
with both direct and indirect employment. Any major shift towards
less employment within the industry, or any reduction in available
timber, will have a profound effect upon the local economy. The
Ketchikan Gateway Borough Assembly supports the timber industry as
a major source of community employment, and therefore recommends to
the U.S. Forest Service that they continue to make available a
reasonable level of timber harvest to this industry.
The Ketchikan Gateway Borough is located in the extreme southeast
portion of the state, and maintains land holdings on three major
islands. The Borough residents do not have a direct link to a road
system for access off Revillagegido Island. Instead, the only
direct linkages off the islands remain wholly with the air
transport industry and the Alaska Marine Highway system. The
Ketchikan Gateway Borough is specifically interested in the
development of an inter-island and intra-island road system. The
following access considerations are recommended:
A. Mainline roads, for whichever alternative is developed, be
developed in such a manner that they could be utilized as part
of an intra- and/or inter-island road tie.
B. That all mainline sections of new logging roads be designed to
provide horizontal control sufficient to meet USFS standards
for a public access road with a minimum of a sixteen (16) foot
width and a design speed of at least thirty (30J miles per
hour and, preferably, 40-50 miles per hour.
Stephen Ambrose
Page 3
January 14, 1991
G.
That the design of all mainline sections of road strive for ( 3
vertical control at no more than eight ( 8 ) percent . ^
During the construction of mainline road sections, it is
desirable that an effective waste management system be
implemented to effectively remove waste material from the
site, or to bury waste material on site, in order to maintain
a high visual quality along the principal road corridor.
That logging operations not clear cut up to the mainline
roads , and that some vegetation remain to provide a visual
barrier between the road and adjacent clear cut areas.
Provide access to important lakes and waterways that are
accessible via the mainline roads to recreation sites, as
depicted in the road/recreation configuration of Alternative
3.
Defer logging specifications for sites immediately adjacent to^)
the Leask Lakes area until a Master Development Plan for the (
proposed land trade is completed by the Borough, this would \
allow for the coordination of harvest patterns within the two
areas .
4
s'
7
H. Defer harvesting and road construction of the west end of the
study area (sites 49-51, VCU 748, alternative 3) until such
time as the Alaska Department of Transportation and Public
Facilities completes a corridor study for the construction of
an inter-island road system.
I . As a matter of public policy, the Borough supports a road
corridor through the LUD II (Naha) area as a possible linkage
for the inter-island road network.
Under all alternatives it is recommended that all "retention areas"
related to recreation purposes be maintained in their natural
state . It is further recommended that if more timber harvesting is
determined to be necessary than provided for under Alternative 3,
that it be harvested from areas that will not have a direct affect
on the lands retained for recreational purposes. Additionally, it
is recommended that all logging operations be conducted in such a
manner as to minimize the impact to significant habitat, while
realizing the aforementioned timber, access, and recreational
objectives .
In addition, the Ketchikan Gateway Borough believes that adequate
provisions should be made for sufficient right-of-way for electric
transmission and major road corridors in the development of the
Shelter Cove timber sale program. Major road corridors are any
roads that will allow for 40-55 mile per hour traffic flow. This
right-of-way should not be less than 200 feet and a joint use
corridor (electric transmission and road) be established.
1 0
Stephen Ambrose
Page 4
January 14, 1991
The Ketchikan Gateway Borough Assembly and I would like to thank
you for this opportunity to comment on the Shelter Cove Draft
Environmental Impact Statement. We will continue to follow the
progress of this proposed sale, and in particular our requested
revisions, with great interest. If we can provide any further
comment, or clarify our present comments, please feel free to
contact me at the above address.
Ralph Bartholomew, Mayor
Ketchikan Gateway Borough
RB/SGH/bjs
Letter From Ralph Bartholomew, Mayor Ketchikan Gateway Borough
Comment 1: (paraphrased)
It is recommended that mainline roads, be developed so they could be used as part of an intra- and/or
inter-island road tie.
Response 1 :
The Shelter Cove DEIS addresses a timber sale project. A road tie to Ketchikan will require a separate
environmental document addressing the inter-island tie. However, the road pattern proposed in the
Shelter Cove project will accommodate a possible inter-island road tie. The main road from Shelter Cove
to the west will be developed along a corridor that could later be upgraded into a main road tie.
Comment 2: (paraphrased)
It is recommended that mainline roads be designed for public access with a minimum of sixteen foot
width and design speed of at least thirty miles per hour and, preferably, 40-50 miles per hour.
Response 2:
Initial construction of the main line road will be for timber harvest purposes. Thus, a single lane road
would be built to accommodate such traffic. The mainline road from Shelter Cove to Salt Lagoon is
planned to be built as a 1 6’ wide, single lane road. This road will be built along a corridor that will facilitate
upgrading to highway standards.
Comment 3: (paraphrased)
It is recommended that mainline roads strive for vertical control at no more than eight percent.
Response 3:
See response to Comment 2.
Comment 4: (paraphrased)
It is recommended that during construction of mainline roads that it is desirable to effectively remove
waste material from the site to maintain a high visual quality along the principal road corridor.
Response 4:
Waste material will be disposed of according to the Visual Mitigation Measures contained in Appendix
B.
Comment 5: (paraphrased)
It is recommended that clearcut logging not occur up to the mainline roads and that a visual barrier
remain.
Response 5:
This practive is displayed for the majority of harvest units in Alternative 3. Where potential windthrow
areas exist harvest was limited to one side of the road. Alternative 3 is the recreation alternative and
potential recreation values are retained.
Comment 6: (paraphrased)
It is recommended that access be provided to important lakes, waterways and mainline roads access
recreation sites.
Response 6:
The mainline road passes adjacent to North Saddle Lakes which provides access to the lakes. Addition-
ally, a boat ramp in Shelter Cove accessing Carroll Inlet is planned. Walk-in access would be available
to other lakes in the area.
Comment 7: (paraphrased)
It is recommended that logging be deferred immediately adjacent to Leask Lakes.
Response 7:
Alternatives 2, 4 and 5 respond to this issue.
Comment 8: (paraphrased)
It is recommended to defer harvesting and road construction of the west end of the study area (sites
49-51, VCU 748, Alternative 3).
Response 8:
Alternatives 2, 4 and 5 respond to this issue.
Comment 9: (paraphrased)
It is recommended that if more timber harvesting is necessary than provided for under Alternative 3, that
it be harvested from areas that will not have a direct affect on the lands be retained for recreational
purposes.
Response 9:
Additional harvest, as displayed in the Record of Decision, was obtained outside of areas withdrawn for
recreation and wildlife.
Comment 10: (paraphrased)
It is recommended that adequate provisions be made for sufficient right-of-way for electric transmission
and major road corridors. This right-of-way should not be less than 200 feet.
Response 10:
The power transmission corridor through the project area is in place. Thus, additional corridors are
unnecessary. The Tyee inter tie runs from Swan Lake northward, and does not appear to be in the
project area
Klukiuan Forest Products , Inc.
P.O.Box 34659 • Juneau. Alaska 99803-4659
(907) 789-7104 Fax.(907) 789-0675
January 25, 1991
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Mr. Ambrose:
On behalf of Klukvan Forest Products, Inc., its Board of
Directors, its over 400 employees, its over 250 shareholders and
all of their families, I would like to recommend Alternative 4
for the Preferred Alternative for the Shelter Cove DEIS. This
alternative best protects other resources, such as
Visual/Recreation, Fish/Water, and Soils/Water, while providing a
supply of timber to the industry. Providing this supply is
necessary to comply with the new Tongass Reform Act of 1991.
In this Act significant areas of forest land have been set aside
and designated for single uses, such as wilderness, which of
course does not allow any timber harvest whatsoever. This is in
addition to those lands similarly designated in ANILCA.
Section of
105 (f) of
part . . .
Alternative 4 is also necessary
the Tongass Timber Reform Act.
to comply with Sect
That Section reads
"in order to assure the continuation of the Small
Business Administration timber sale program, the
Secretary shall seek to provide a supply of timber from
the Tongass National Forest which meets the demand of
those purchasers qualifying as 'small business
concerns' under the Small Business Act as amended
(15U.S.C. 631 et seq. ) . "
Klukwan Forest Products as a qualified small business concern
must have a supply of timber in conformance with Section 105 (f).
Other benefits to the Ketchikan Area, as well as indirect
benefits to all of Southeast Alaska, include the road corridor
potential link up of Ketchikan to the outside. This unique
opportunity must be preserved because federally designated
wilderness lands preclude this opportunity in so many other
locations throughout Southeast Alaska. Alternative 4 also
creates opportunity for road dependant rural recreation.
Therefore, while this is perhaps beyond the immediate planning
Forest Supervisor
January 25, 1991
Page 2
scope, no road should be permanently blocked to retain this as a <
future option.
Alternatives 3 or 6 create some acceptable opportunities yet they
simply fall short in meeting independent and small business
timber demand as required by the new law. Both do, however,
create the opportunity to interconnect the proposed Forest
Service road system with the main road.
Alternative 5 is totally unacceptable and runs contrary to public
response to the Community Survey results regarding fish and
wildlife due to lack of road access. It would also block access
to other tracts of timber for future entries into the area.
Implementation of this would be downright deceitful and
underhanded.
Klukwan Forest Products supports an active timber industry, the
management and development of natural resources, increased
recreation and cultural opportunities, and growth of the
community of Ketchikan.
Sincerely,
QmaldL £ LUoJi/U^
Ronald R. Wolfe^^
Chief Forester
RRW : mm
Letter From Ronald R. Wolfe, Chief Forester,
Klukwan Forest Products, Inc.
Comment 1: (paraphrased)
Selection of Alternative 4 is necessary to comply with Section 1 05(f) of the Tongass Timber Reform Act.
Response 1:
Section 105(f) of the Tongass Timber Reform Act requires only that the Forest Service seek to provide
a supply of timber from the Tongass National Forest to small business concerns. This project addresses
this concern. Section 105(f) does not require the Forest Service to select the ‘Maximum Timber Harvest
Alternative’ but that timber harvest be consistent in providing a sustained supply of renewable re-
sources.
Comment 2: (paraphrased)
Other benefits to the Ketchikan Area, as well as indirect benefits to all of southeast Alaska, include the
road corridor potential link up of Ketchikan to the outside. Therefore, while this is perhaps beyond the
immediate planning scope, no road should be permanently blocked to retain this as a future option.
Response 2:
Roads addressed in the Shelter Cove plan would not preclude eventual link up or potential use in an
intra-island road tie. The mainline road from Shelter Cove to the Salt Lagoon area will be located along
a corridor that will accommodate eventual upgrading and linkage to an intra-island system.
Comment 3: (paraphrased)
Alternatives 3 or 6 create some acceptable opportunities yet they simply fall short in meeting indepen-
dent and small business timber demand as required by the new law.
Response 3:
See response number 1.
Comment 4: (paraphrased)
Alternative 5 is totally unacceptable and runs contrary to public response to the community survey
results regarding fish and wildlife due to lack of road access. It would also block access to other tracts
of timber for future entries into the area.
Response 4:
Of the nine recreational values prioritized by the community, the first through third priorities dealt with
fish and wildlife habitat protection. Roaded access to recreation was listed as a fourth priority. Alternative
5 protects the highest value fish and wildlife habitat, while proposing harvest of 67.1 million board feet
of timber.
■
y j!
January 2 4 ,
1991
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Sir:
In reviewing the Shelter Cove Draft Environmental Impact Statement
I can see that your agencv has put many man hours into different
philosophies of resource management. I believe from reading it
that many people employed ' by the U S F S should be c o m men d e d .
1 understand tnat there are six alternatives to cnoose rrom. Tnere J
should be a choice of an alternative 7 termed "HARVEST EVERYTHING /
MERCHANTABLE". I believe this to be as valid an alternative as x
alternative 1 'which is termed NO ACTION as the Shelter Cove area ]
is to be managed under multiple-use. This is not to state that I J
am in favor of harvesting everything merchantable, though is to
state that I believe that your agencies alternative 1 is such an
extreme that in order to obtain a middle ground tne totally
opposite alternative should else be proposed. In future Draft
Environmental Impact Statements i believe tnat a harvest everything
alternative should be listed so that both extremities could be
eliminated and the middle around concentrated on.
I believe that the Shelter Cove Area with its close proximity to
Ketchikan is highly regarded by the citizens of Ketchikan. The
Shelter Cove area is meant to be managed under the multiple-use
principle and as such is intended to have harvesting of timber
allowed. Nov; how much and rrom where is tne question posed by your
agency.
I strongly believe that the MAJORITY of citizens in Ketchikan favor
roaded recreation "immediately" and this has been shown by a survey
conducted by the Ketchikan Gateway Borough. In order to have this )
roaded recreation it is imperative that VCU 748 have roads (
established to the presently owned state land commonly referred to j
as Leask Lakes. These roads would allow multiple-use of a
multiple-use area by a multiple variety of people. These roads are
imperative for the use of this area by elderly, very young and
handicapped citizens of Ketchikan..
i/j.v/9/
As you are already aware the economy of Ketchikan is strongly based
on the timber allowed for harvest by your agency. Some city
operations would include LP ' s Ketchikan Pulp Company and Seley's.
The economy or Ketchikan is also oased on the fishing inciuscry.
VJith operations such as Silver Lining.
So how do you get what seems to be two competing natural resource
users to agree on how to manage the natural resources of the
Shelter Cove area for their benefit? A most perplexing problem
indeed or is it?
I believe that both the common timber cutter and the common
risnerman who work outdoors want and NEED to use the resources for
their livelihood. Though, these working people also wish to ertect
the resources as little as possible. In order that their children
will also have the ability to use the resources.
I don't truly believe there is a wide gap of thought between the
common fisherman and logger in natural resource issues. Though
there is a wide gap of thought by lobbying interest who more often
then not scream the loudest at and to your agency. Please keep in
mind that tne small nsherman ana logger are the ones who are going
to d e a f r e c t e d by your decision on a day to da y basis .
I have given the alternatives that are proposed by your agency
careful and meticulous review. Although I don't believe any of
them are perfect. I do believe that alternative 6 comes closest to
what the common majority of people would like done in managing the
resources of the Shelter Cove Area.
Why do I believe tnat the majority of citizens favor alternative
6 over the others? There are many reasons though 1 nave only-
outlined a few that I feel are imperative for your upcoming
decision .
1. I believe that the roads once accessed by the citizens of
Ketchikan will provide for a "quality outdoor experience" by
the majority of people. An expanded road system will allow
people tne freedom of being able to hunt and fish away from
other people mucn more easily then wnat currently is
allowed. As I stated previously I am writing about tne common
citizens, of which I'm one, the citizens who want to spend the
day fishing not walking to go fishing. Nor am I writing about
the citizens who own airplanes and large boats. '
As wildlife is a major concern to people including myself I
support alternative 6 over alternative 5 tor it provides
increased hamtat acreage for black bears, bald eagles, river
otters, and Vancouver Canadian Geese. Alternative 6 has an
increase of 21 habitat effect on pine martin, black tail deer,
and hairy woodpeckers. I am questioning the affect on
black tail deer as current literature is indicating that these
animals store up body fat for the winter months and harvesting
timber will bring food down to a level in which they can
easily achieve it. As evidenced oy Prince of Wales Island.
Fish management ennancements or improvements are much more
easily accomplished under alternative 6 then under alternative
5. These fish enhancements or improvements are undoubtedl1/
beneficial to the commercial fisheries of Alaska in the
ability to increase fish numbers and consequently harvest
rates. Which in turn increases revenue to the Ketchikan Area.
Alternative b
pro v i d e
s for
70 timber related jobs .
This
equates to _ 0 k
more pe
ople e
mployed m Ketcnikan then
under
alternative 2 ,
2 , c< 5
In
money this amounts to at
leas t
S 6 0 0 . O 0 0 . 0 0 a r
id would
me r e
ese from there as these
o e 0 r 1 e
w 0 u Id need to
purchase
g 0 0 d s
from town fie food, gas.
etc.
5. I believe that the added road access would increase the amount
of time that the independent traveler would spend in the
Ketchikan Area. This would also be beneficial to the
merchants of tne city as this traveler would be more likely to
purchase goods.
o. alternative o builds less roads on highly ercdible soils then
alternative 5. As sediment can be a factor on aquatic
populations alternative 6 would be better for fish and
consequently people dependent on fish such as fishermen.
7. Alternative 5 harvest less acreage in very hign MM I areas then
alternative 5.
8. Alternative 6 does not make any larger entries then 135 acres
which is the same as alternative 5.
9. If the road is tied to Ketchikan. Citizens of Ketchikan will
be allowed to gather firewood for their personal use.
10. Alternative 6 harvest less wetland associated timber then
alternative 5. This is an important point as timber takes
longer to establish itself in wetland areas. So evidently
alternative 5 impacts the natural resources for a longer
period of time then does alternative 6.
11. Alternative 6 will provide for a sustained yield of timber as
the entry harvest only 10% of the totally available commercial
timber within the Shelter Cove management area.
I believe with my "middle of the road" approach to management. The
Shelter Cove area alternative 6 provides for the best interest of
the MAJORITY of Ketchikan citizens.
Sincerely,
cc: Dave Fletcher
Letter From Al Peterson
Comment 1: (paraphrased)
It is recommended that there should be a choice of an Alternative 7 termed 'HARVEST EVERYTHING
MERCHANTABLE'. I believe this to be as valid an alternative as Alternative 1 which is termed NO ACTION
as the Shelter Cove Area is to be managed under multiple-use.
Response 1 :
The Tongass Land Management Plan (TLMP), limits the amount of harvest in the first entry. To do
otherwise would go contrary to this direction.
Comment 2: (paraphrased)
In order to have roaded recreation it is imperative that VCU 748 have roads established to the presently
owned State land commonly referred to as Leask Lakes.
Response 2:
Alternatives 2, 3 and 6 propose roads to the state land boundary in the Leask Lakes area. The fact that
the other alternatives do not propose roads to the state land boundary near Leask Lakes offers a
resaonable range of alternatives to the public.
Comment 3: (paraphrased)
I am questioning the affect on black-tail deer as current literature is indicating that these animals store
up body fat for the winter months and harvesting timber will bring food down to a level in which they
can easily achieve it. As evidenced by Prince of Wales Island.
Response 3:
As stated in the EIS, timber harvest converts old growth into early successional shrub and forb stages.
Clearcuts 0-1 5 years old provide abundant forage and improve the opportunity for more deer to enter
the winter in good condition, but the lack of canopy cover, in clearcuts to intercept snow, results in
making herbaceous forage unavailable during intermediate or deep snow winters. We who stated these
facts, studied the deer on Prince of Wales Island.
Comment 4: (paraphrased)
It is recommended that added road access would increase the amount of time that the independent
traveler would spend in the Ketchikan Area.
Response 4:
We agree. Given more miles of road to drive and more developed recreation opportunities it seems likely
that the independent traveler would be likely to stay in the area longer.
Comment 5: (paraphrased)
It is recommended that alternative 6 builds less roads on highly erodible soils then Alternative 5. As
sediment can be a factor on aquatic populations, Alternative 6 would be better for fish and consequently
people dependent on fish such as fishermen.
Response 5:
We agree that Alternative 6 does build slightly less roads on soils with very high mass movement index;
0.4 miles compared to 1.2 miles (DEIS 4-3). But the total road miles on areas of high mass movement
index is higher for Alternative 6 (15.2 miles) compared to Alternative 5 (14.2 miles). We disagree that
Alternative 6 is better for fish habitat productivity.
As stated in the DEIS, Chapter 2, page 20; the greatest potential for adverse impacts to fish habitat
results from potential mass movement and road erosion within the Salt Creek drainage. Alternative 5
has not units located within these sensitive areas, compared to five units with soil hazard areas above
the productive salmon habitat in upper Salt Creek.
STEVE COWPER, GOVERNOR
DEPT. OF ENVIRONMENTAL CONSERVATION
Division of Environmental Quality
Southeast Regional Office
P.O. Box 32420
Juneau, Alaska 99803 Phone: (907) 789-3151
January 15, 1991
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
F f;
; •n.ci ,
p'"
t. !
v t U
5 t
i A *,i
In 111
1390.
RE: Shelter Cove Draft Environmental Impact Statement
The Shelter Cove independent sale plan will harvest between 26.3 to 95.6 million board
feet of timber on the Ketchikan Ranger District. The 60,383-acre project is located on
Revillagigedo Island, around the Shelter Cove and George Inlet area and is 18 air miles
northeast of Ketchikan.
The Department has reviewed this document under the National Environmental Policy Act
(NEPA), the Alaska Coastal Management Program (ACMP), review authorities and
standards of the Alaska Forest Practices Act (FPA). Our comments relating to the
project’s consistency with ACMP are separated from our NEPA comments.
NEPA COMMENTS
Alternative 5 appears to be the most preferable in terms of maintaining water quality and
preserving wildlife habitat in the area. In addition, Alternative 5 proposes no road building
in VCU 742, which is designated as LUD II. One concern with this alternative, as well as
with alternatives 4 and 6, is whether the LTF at Hume Island will be usable as is assumed
in each case. The EIS lists two factors that could preclude the use of this LTF. The first
is the possible presence of several eagle nesting sites in the vicinity. The second factor
is the question of obtaining permission from the owners to use the site. Neither issue was
resolved in the draft EIS. Finally, the Forest Service should seriously consider excluding ^
road building and timber harvesting activities from areas identified as having very high / ^
MMI soils. For example, Alternative 5 proposes the building of 1.2 miles of road, and the \
harvesting of 33 acres of timber in areas with very high MMI soils. These areas should be J
excluded from proposed road building and timber harvesting activities, as the potential for J
landslides in such areas is high.
Stream buffer requirements presented in Appendix B (the proposal for placing buffers
around certain streams in each alternative) do not meet the requirements of the Tongass
Timber Reform Act. Obviously, the draft EIS was produced before the legislation was
passed. However, the final EIS should incorporate the new requirements.
4
A list of major watersheds is presented in Chapter 3, page 20. Watershed D83A was ]
excluded from this list, despite the fact that it is anadromous fish habitat, and has timber )
harvesting activities scheduled in its vicinity in several of the alternatives. This watershed V
should be included in the final EIS. In addition, the fish production potential of watershed j
D83A should be included in the final EIS, if it was excluded from the draft EIS.
The monitoring plan identifies the most important subjects for research and monitoring on
lands affected by timber harvest activities, but has two main deficiencies: ■
Feathering of boundaries (including stream buffers) should be a common practice in wind-
prone areas, not just (apparently) a research item as proposed in the draft EIS. Feathering
is an effective method for preventing blowdown at the boundaries of cutover areas.
Under "Fish Habitat," a proposal is made to sample 5-15% of the harvested units annually.
A unit of measurement of "percent effective" is proposed. Two questions need to be
answered. The first is: what is meant by "effective"? For example, "effective" could mean
meeting state water quality standards and maintaining fish populations with no significant
losses. It would be helpful to know, even in a general way, what and how specific
parameters will be measured (e.g. quantity of sediments up and down stream from a
harvest unit, and/or before and after harvesting at one point) in order to judge whether
stream protection efforts are effective. The monitoring effort should also address the
question of impacts of sediment loading in Class III streams that are upstream from fish
habitat, and in Class II streams that are not tributary to Class I streams, and which are not
buffered. The second question is temporal: for how long will the monitoring be done?
Cumulative effects analysis needs to be done in order to ensure that fish habitat is not
significantly impacted over the long term.
ACMP
The Department reviewed this document under the Alaska Statutes governing Forest
Practices on State and Private Lands (Title 41) for the protection of water quality. Under
section 41.17.098 the Department of Environmental Conservation is given due deference
for water quality.
Loo Transfer Sites
Volume II of the DEIS for Shelter Cove discusses the evaluation of LTF sites. The final J £
selection of LTF sites should meet the criteria described within the document "Log Transfer S
Facility Siting, Construction, Operation and Monitoring/Reporting Guidelines" dated j
September 1985. Guidelines in this document serve as the basis on which agencies judge
the ability of sites to meet water quality and habitat concerns. Since the issuance of this
document, State and Federal agencies have refined LTF performance standards. The 'N
Environmental Protection Agency (EPA) has determined that LTFs should meet log entry / -j
velocities of 3 feet per second. This entry speed is achievable with the best available ?
technology; LTFs should be designed to meet this standard. The Department of j
Environmental Conservation has also required that LTFs have a surface runoff plan, J
defined boundaries for the sort yard and LTF, and requires the disposal of woodwastes
consistent with solid waste regulations under 18 AAC 60.
2
Water Quality Monitoring
The DEIS soil and water monitoring plan is inadequate, does not describe methods to'A
determine water quality before, during, and after timber harvest and does not describe a )
process to allow modifications of harvest prescriptions in response to water quality ( &
conditions. The Alaska Forest Practices Act specifically states in AS 41.17.060 (b)(5) \
"significant adverse effects of soil erosion and mass wasting on water quality and fish J
habitat shall be prevented or minimized". To met this performance standard, the Forest
Service must demonstrate that its forest practice Best Management Practices (BMPs) and
Aquatic Habitat Management Units (AHMU) maintain State Water Quality Standards.
To assess whether AHMU and BMPs meet State Water Quality Standards, a method of
monitoring BMP effectiveness must be part of the FEIS. The DEIS is deficient on this
issue. The measurement of water quality in the DEIS is based on adherence to BMPs and
AHMU practices. There is no existing research demonstrating that BMPs utilization in
Southeast Alaska meets State Water Quality standards. To the contrary, Thorne Bay
Ranger district issued a report (Prince of Wales Culvert Repair, State I.D. No. AK901003-
04) on the review of 45 culverts for fish passage. A disturbingly high percentage of
culverts failed to allowed fish passage due to improper culvert installation or maintenance.
This report is an example of where BMPs failed to achieve the goal of water quality
protection and fish passage. It is impossible using this or the proposed type of monitoring
to predict and determine if Aquatic Habitat Management Unit (AHMU) prescriptions and
Best Management Practices (BMP) meet State Water Quality Standards during and after
timber harvest. The application of prescriptive practices should be validated with solid
monitoring information.
The Forest Service has argued that monitoring is part of the forest wide plan (Tongass
Land Management Plan) and is therefore not an issue for discussion within the DEIS
document. The Forest Service is playing a shell game in defining where water quality will
be monitored. In TLMP, monitoring plans call for analyzing data collected in conjunction
with projects (see Appendix Vol. Ill, pg. H-17 #3). It does not give specific plans nor
projects. We agree that monitoring should be part of Forest Service projects. We also
believe that Shelter Cove more than qualifies as a project.
The Department of Environmental Conservation finds the DEIS consistent with ACMP if
the following stipulations are followed. These stipulations are necessary for the protection
of Water Quality (AS 41.17.060 (b)(5)).
SHELTER COVE WATERSHED MONITORING STIPULATIONS
1 .) BMPs for road building and installation of culverts and bridges shall be monitored
for effectiveness at meeting State Water Quality Standards. Turbidity and
sedimentation must be measured using established sampling techniques.
Monitoring should include both long and short term sampling.
/
3
2. ) BMPs for timber harvest shall be measured for effectiveness at meeting State
Water Quality Standards. Parameters to be considered are turbidity,
sedimentation, and temperature. Monitoring should include both long and short
term sampling.
3. ) AHMUs for timber harvest shall be measured for effectiveness at meeting State
Water Quality Standards. Parameters to be considered are turbidity,
sedimentation, and temperature. Monitoring should include both long and short
term sampling.
Thank you for allowing comment on this document.
cc: Lorraine Marshall (DGC)
Walter Dortch (USFS)
Daryl McRoberts (ADNR)
Jack Gustafson (ADF&G)
Rick Reed (ADF&G)
Tamra Faris (NMFS)
Susan Cantor (USEPA)
Sincerely,
Jim Ferguson
Environmental Specialist
Letter From Jim Ferguson, Environmental Specialist, State of Alaska
Comment 1: (paraphrased)
I am concerned with Alternative 5, as well as Alternatives 4 and 6, whether the LTF at Hume Island will
be usable as is assumed in each case.
Response 1:
Use of the Hume Island LTF is dependent upon developing an equitable agreement with Cape Fox
Corporation. If the site is not usable, or such an agreement could not be reached, all resource access
would be accomplished via the Shelter Cove LTF. This is provided for in discussion in Chapter 4, pp.3
of the DEIS.
Comment 2: (paraphrased)
It is recommended that the Forest Service should seriously consider excluding road building and timber
harvesting activities from areas identified as having very high MMI soils.
Response 2:
The Forest Service (FS) does what it can to avoid road building and timber harvesting activities in areas
identified as having very high MMI soils.
It is noted in footnote 1 of Table 4-3 and on page 7 of Appendix B of the Draft Environmental Impact
Statement (DEIS) that soils information used to compute this document is not 100% accurate for
conditions on the ground. Mapping of soils is generally accurate for a given area, but not for every
location in that area. Soils and slopes are not 100% homogeneous within a soil map unit. Assigning a
very high mass movement designation to a map unit is often a worse case scenario that can protect
some of the soil resource. The major areas of very steep slopes are noted, while the smaller areas of
less steep slopes may not be identified. The inventory system is not able to identify the smaller areas
of less steep slopes and benches within a map unit where the roads may be laid out or some of the
timber may be harvested. This is not ingnoring that activities will be done on very high MMI soils. The
land in southeast Alaska occurs in such a pattern that it is difficult to avoid areas of very high MMI soils.
The information provided by the inventory system on high MMI soils is a red flag to alert us to potential
problems. These areas are investigated by soil scientists with the FS prior to construction of roads or
harvest of timber. Alternate areas are suggested if they are available. It is noted in the Soils/Water section
for each of the action alternatives in Chapter 2 of the DEIS, that 'High and very high mass movement
index soils will be avoided, to the extent possible.1 Mitigation measures are applied if activities must be
done on areas with very high MMI soils. These mitigation measures are applied to minimize possible
adverse effects to timber harvest and road construction on soil productivity and water quality. Table 2-28
(pages 27 to 30) of the DEIS list mitigation measures. Item 3 discusses mitigation measures for activities
for road construction on very high MMI soils. Item 4 discussed mitigation measures for activities for
timber harvest on very high MMI soils.
Comment 3: (paraphrased)
I am concerned that stream buffer requirements presented in Appendix B do not meet the requirements
of the Tongass Timber Reform Act.
/
Response 3:
The Aquatic Habitat Management Unit Harvest Standards and Guidelines for the Final EIS will be
amended to be consistent with requirements in the Tongass Timber Reform Act.
Comment 4: (paraphrased)
I am concerned that Watershed D83A was excluded from a list of major watersheds presented in
Chapter 3, page 20. This watershed should be included in the final EIS.
Response 4:
The table in Chapter 3, page 20 is in error. Salt Lagoon Creek, ADF&G #101 -45-1 0400, was erroneously
labeled as watershed D81C. It is actual watershed number D84A. Salt Lagoon Creek #2, ADF&G
#101-45-10420 was erroneously labeled D84A, when in fact it is D83A.
Comment 5: (paraphrased)
Two questions need to be answered about a unit of measurement of ‘percent effective" is proposed.
The first is: what is meant by ‘effective'? The second question is temporal: For how long will the
monitoring be done?
Response 5:
The % effective can be answered by reviewing the revised Fish Habitat Monitoring Plan. The how
measured column defines the effectiveness question. The when measured answers how long the
monitoring will be done.
Comment 6: (paraphrased)
It is recommended that the final selection of LTF sites should meet the criteria described with the
document ‘Log Transfer Facility Siting, Construction, Operation and Monitoring/Reporting Guidelines'
dated September 1985.
Response 6:
Shelter Cove was selected and evaluated in accordance with the Log Transfer Facility Siting, Guidelines,
dated 1 985. The facility will be constructed and operated within the Operation and Monitoring/Reporting
Guidelines. The Shelter Cove LTF evaluation is included in Appendix C of the DEIS.
Comment 7: (paraphrased)
The Environmental Protection Agency (EPA) has determined that LTFs should meet log entry velocities
of 3 feet per second. This entry speed is achievable with the best available technology. It is recommend-
ed that LTFs should be designed to meet this standard and have a surface runoff plan.
Response 7:
The Shelter Cove site is designed for A-frame lift off or crane operations. These systems will provide the
3 foot per second log entry speed which exceeds the above mentioned siting guideline requirements.
Surface run-off and other design features will be accomplished during the permitting process.
It was unknown to us that the Hume Island LTF was a short-term use facility. If we cannot gain access
via Hume Island LTF for any reason, all Forest Service timber resources tributary to Hume Island LTF
will be transported to the Shelter cove LTF.
Comment 8: (paraphrased)
If am concerned that the DEIS soil and water monitoring plan is inadequate, does not describe methods
to determine water quality before, during, and after timber harvest and does not describe a process to
allow modifications of harvest prescriptions in response to water quality conditions.
Response 8:
Tables 2-28 (pages 27 through 30) and 2-36 (pages 45 and 46) of the Draft EIS have been revised in
the FEIS to include information to correct these deficiencies.
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WALTER J. HICK EL, GOVERNOR
DEPARTMENT OF FISH AND GA ME
DIVISION OF FISHERIES REHABILITATION
ENHANCEMENT AND DEVELOPMENT (FRED)
2030 SEA LEVEL DRIVE, SUITE #205
KETCHIKAN, AK _ 99901
:t9.ar)r~-2?5~$677~
JAN .18 1991.
January 16, 1991
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Forest Supervisor:
I have reviewed the Shelter Cove DEIS. Since I am personally not
familiar with most of the area involved, I have relied on your
information regarding the amount and quality of fish habitat and
the expected impacts to the habitat from the various alternatives.
It is clear to me that Alternative 5 is the most reasonable, in
that it will result in the least amount of degradation of natural
habitat important to fish and wildlife, while allowing for timber
harvest. Although you have planned for buffer zones adjacent to
streams in harvest units - and a lot of thought has gone into
planning for effective buffer zones - there is no way to insure
against unexpected blowdown and the consequences to fish habitat.
Therefore, protecting the Salt Creek watershed by leaving old
growth intact is important to the coho salmon resource.
Your references to "good fish enhancement access" for alternatives \
2, 3, 4, and 6 should not be a consideration on which to base a / /
choice of alternative, and therefore should not appear on Table 2- \
27. Decisions to implement enhancement projects should be based on J
habitat and biological parameters, not human convenience and low
cost. Fish pass construction, as you know, is entirely feasible in
non-roaded areas (Old Franks, Margaret, etc.). Likewise, stating .
that Alternative 5 results in "limited fish enhancement" implies (
that this alternative does not score as high in this category, when
in fact it would be best for the resource since it' leaves more
natural habitat and requires the least amount of mitigation.
When your harvest plans are finalized I will be glad to discuss a
co-operative enhancement program with you, for colonization of
native coho above any new fishpass. FRED Division's Beaver Falls
Central Incubation Facility would be the logical place to incubate
eggs for enhancement projects, and any political support you can
lend in the coming months to help keep the facility operating will
be appreciated.
Sincerely,
Carol Denton
Area Biologist
FRED Division
Letter From Carol Denton, Area Biologist, State of Alaska
Comment 1: (paraphrased)
It is recommended that references to 'good fish enhancement access’ for Alternatives 2, 3, 4, and 6
should not be a consideration on which to base a choice of alternative, and therefore should not appear
on Table 2-27.
Response 1:
Table 2-27 is a comparison of alternatives. By having a road adjacent to the potential project site, costs
for construction are considerably cheaper. Also, the Area has found that good road access facilitates
the ability to find volunteers to help construct fishways.
Comment 2: (paraphrased)
I am concerned that stating that Alternative 5 results in ’limited fish enhancement’ implies that this
alternative does not score as high in this category.
Response 2:
The table does over simplify the fish enhancement opportunities. The discussion of the effects of timber
harvest on fish gives a more complete analysis. Alternative 5 would not include the Salt Creek falls in
a Knutson-Vandenberg collection boundary. This source of monies have been used to fund construc-
tion of several fish passage facilities that the State has worked as partners with us. These are Dog
Salmon, Rio Roberts, Margaret, and Big Lake. So the elimination of the Salt Creek falls from the collection
boundary would limit enhancement opportunities compared to Alternatives 2, 3, 4, and 6.
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WALTER J. HICKEL, GOVERNOR
DEPARTMENT OF NATURAL RESOURCES
January 16, 1991
Steve Ambrose
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Mr. Ambrose:
DIVISION OF FORESTRY
SOUTHEAST REGION OFFICE
400 WILLOUGHBY AVE., 5th FLOOR
JUNEAU, ALASKA 99801
The Division of Forestry recommends that you consider Alternative 6 as the
preferred alternative for the Shelter Cove area. We feel Alternative 6 which
emphasizes recreation and timber is appropriate for this area due to its close
proximity to Ketchikan. This is especially true with the possible future link
to the existing road system in Ketchikan.
Alternative 6 provides 82.1 million board feet of timber to the local economy.
The 71 miles of road to be built will provide considerable recreational
opportunities to the residents of Ketchikan when this system is linked to
town. Currently the opportunity for vehicle recreation is severely limited in
the Ketchikan area.
Under Alternative 6, the state will benefit from the roads developed around
its property at Salt Lake and Leask Lake. The lower road around Salt Lake
would make access to the state's property there easier. If the state decided
on a land distribution, or other development, these roads would provide needed
access. The road ending near the state's property boundary at Leask Lake
would also provide access to that area in the future. This roaded access to
the state's land would be especially important if this road system was linked
to Ketchikan.
We urge you to consider Alternative 6 as the preferred alternative in the /
final EIS. If another alternative is chosen, we urge you to incorporate the\
lower road system around Salt Lake up to the state's boundary at Leask Lake \
into the preferred alternative. '
Enclosed is a draft copy of the Division's interpretation of the revised
Forest Practices Act's relationship to the Alaska Coastal Zone Management
Program. In order to be consistent, the buffers that are being left along
anadromous or high value resident fish water bodies must be at least 100 feet
wide .
Sincerely
Daryl McRoberts
Asst. S.E. Regional Forester
enclosure
cc: Division of Governmental Coordination, Juneau
Chris Westwood, Ketchikan Area Forester
ZLlj D'inted on recycled cacer c y C. D-
FEDERAL CONSISTENCY TO THE ACMP
OF TIMBER HARVEST ACTIVITIES
Alaska's revised Forest Practice Act speaks specifically to
the issue of Federal consistency of timber harvest activities.
The following sections are identified as pertaining to Federal
consistency .
AS 41.17.900
(b) For Federal land,
(1) the degree of resource protection may not be
less than that established by this chapter for state land
except that AS 41.17.119 establishes the minimum riparian
standard;
(2) a timber harvest activity subject to this
chapter shall satisfy the requirement to be consistent to
the maximum extent practicable with the Alaska coastal zone
management program if the federal land management plans,
guidelines, and standards applicable to that timber harvest
activity provide no less resource protection than the
standards that are established in this chapter provide for
state land except that
(A) AS 41.17.119 establishes the minimum
riparian standards; and
(B) this paragraph does not apply to a timber
harvest activity that requires a state or federal
authorization under a provision of law other than this
chapter .
AS 41.17.060 REGULATORY AND ADMINISTRATIVE STANDARDS.
(b) With respect to state, municipal, and private
forest land the following standards apply:
(1) to the maximum extent possible, all applicable
data and information of applicable disciplines shall be
updated and used in making decisions relative to the
management of forest resources;
(2) environmentally sensitive areas shall be
recognized in the development of regulations and best
management practices that are designed to implement nonpoint
source pollution control measures authorized under this
chapter;
(3) administration of forest land shall consider
marketing conditions and other economic constraints
affecting the forest land owner, timber owner, or the
operator ;
(4) to the fullest extent practicable, harvested
forest land shall be reforested, naturally or artificially,
so as to result in a sustained yield of merchantable timber
from that land; if artificial planting is required,
silviculturally acceptable seedlings must first be available
for planting at an economically fair price in the state; and
(5) significant adverse effects of soil erosion
and mass wasting on water quality and fish habitat shall be
prevented or minimized.
(c) With respect to state and municipal forest land
only, the following standards also apply:
(1) forest land shall be administered for the
multiple use of the renewable and nonrenewable resources and
for the sustained yield of the renewable resources of the
land in the manner that best provides for the present needs
and preserves the future options of the people of the state;
(2) a system of allocating predominant uses or
values to particular units within a contiguous area of land
shall reflect in reasonable proportion the various resources
and values present in that area;
(3) to the extent its capacity permits, forest
land shall be administered so as to provide for the
continuation of businesses, activities, and lifestyles that
are dependent upon or derived from forest resources;
(4) timber harvesting is limited to areas where
data and information demonstrate that natural or artificial
reforestation techniques will result in the production of a
sustained yield of merchantable timber from that area;
(5) there may not be significant impairment of the
productivity of the land and water with respect to renewable
resources ;
(6) allowance shall be made for scenic quality in
or adjacent to areas of substantial importance to the
tourism and recreation industry; and
(7) allowance shall be made for important fish and
wildlife habitat.
AS 41.17.119 MINIMUM RIPARIAN STANDARDS FOR OTHER PUBLIC
LAND. On other public land, harvest of timber may not occur
(1) within 100 feet from the shore or bank of an
anadromous or high value resident fish water body that is
located south of the Alaska Range;
(2) within 100 feet immediately adjacent to an
anadromous or high value resident fish water body north of
the Alaska Range unless the commissioner determines that
adequate protection remains for the fish habitat.
When timber harvest activities are reviewed for federal
consistency the above statutes are the sole basis for the
consistency decision. As I see it there are three separate areas
to address. First does this timber harvest activity require a
state or federal authorization under a provision of law other
than AS 41.17.900. If it does the consistency review for that
activity (such as a LTF , or rafting area) will be outside the
Forest Practice Act.
Second, If the Timber harvest activity includes riparian
habitat, the standards of AS 41.17.119 must be applied. This
standard requires that "harvest of timber may not occur (1)
within 100 feet from the shore or bank of an anadromous or high
value resident fish water body that is located south of the
Alaska Range". This section does not speak to windf irmness ,
effectiveness, or any other attributes of a "buffer". It only
requires that trees not be cut within 100 ft. of a fish creek.
High value resident fish means resident fish populations that are
used for recreational, personal use, commercial, or subsistence
purposes .
Third, does the federal land management plans, guidelines,
and standards applicable to the activity provide on less resource
protection that the standards established by the Forest Practice
Act. Two issues appear to affect this standard. The issue of
resolution. At what level does the federal action have to
consider and protect items 41.17.060 (b) and (c) . On the forest
level, on a management area level, on a drainage level, on a
timber sale level, or on each and every unit. Since the law
specifically addresses federal land management plans, guidelines
and standards it intends that the "no less resource protection"
be applied at the level relevant to those plans, guidelines and
standards. It is not meant to apply to individual units or even
to timber sales. This seems appropriate since land is allocated
amongst timber, habitat, etc. on a drainage or forest basis and
does not need to again be allocated at the unit or timber sales
level .
The second issue regarding "no less resource protection" is
the issue of adequacy. Does the federal plans, guidelines and
standards protect the resources as well as AS 41.17.060 (b) and
(c) . Only (c) (4) has a firm measurable standard "timber
harvesting is limited to areas .... The other "standards" are in
fact a list of guidelines requiring judgement decisions related
to resource issues. As long as the federal agency has considered
these issues through their planning process and NEPA reviews, and
has made their best decision considering the factors involved,
they have provided "no less resource protection" .
If the above three areas comply then the federal timber
harvesting activity complies with the Alaska coastal zone
management program. Any other thoughts, comments, or requested
stipulations regarding the activity should be addressed through
the NEPA public review process.
Letter From Daryl McRoberts, Assistant S.E. Regional Forester,
State of Alaska
Comment 1: (paraphrased)
It is recommended to consider Alternative 6 as the preferred alternative in the final EIS. If another
alternative is chosen, incorporate the lower road system around Salt Lake up to the State’s boundary
at Leask Lake.
Response 1:
The Shelter cove DEIS evaluates a timber sale proposal. Road links to Ketchikan are not within the scope
of the project. Linking the Shelter Cove area to Ketchikan will require a separate environmental evalua-
tion.
Comment 2: (paraphrased)
In order to be consistent, the buffers that are being left along anadromous or high value resident fish
water bodies be at least 1 00 feet wide.
Response 2:
With the passage of TTRA, all Class I streams (anadromous and high value resident fish streams) will
receive at least 100’ no-cut leave areas (FEIS, Chapter 2).
Cape Fox Corporation
P.O. Box 8558
Ketchikan, Alaska 99901
(907) 225-5163
January 2, 1991
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan/ Alaska 99901
Dear Mr. Ambr^o'se :
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I would like to compliment you and your staff on the accuracy
and comprehensiveness of the Shelter Cove Draft EIS. As
adjacent land owner and in view of our land exchange proposal
with the State of Alaska, we have reviewed the document with
interest and have the following comments.
We believe that the implementation of Alternative 3 or 6
would best meet the needs of the local community while
providing balanced resource use and protection. Either
alternative creates the opportunity to interconnect the
proposed Forest Service road system with the main road that
we have proposed under a land exchange with the State of
Alaska. The Ketchikan Community Survey prepared for the
Ketchikan Gateway Borough as a part of their review of our
land exchange proposal found that 9 of 10 residents would
like to have the road system expanded. Alternatives 3 and 6
retain this opportunity. Proposed roads in both alternatives
end within a mile of the CFC proposed road. We can not
support alternative 5 which effectively forecloses a road \
connection from Shelter Cove to Ketchikan. Old growth
retention as shown on figure A5 completely encompasses
potential road routes north and west of Salt Lagoon. If
Alternative 5 were implemented, a road connection to
Ketchikan through this area would, in our opinion, be a
highly unlikely prospect. Timber would not be available to
assist in funding of road construction. In addition, the
Community Survey results regarding fish and wildlife were not
a response to concern for the general protection of these
resources but a reply to three specific questions that
focused on sport or recreation use. On page 80 of the report
the questions posed are shown and v/ere as follows:
Please rate the importance of the following . . . .
- Maintaining the wildlife resource in potential outdoor
recreation areas.
- Preservation of the fisheries resource for fresh-water
sport fishing.
- Preservation of the fisheries resource for salt-water sport
Without road access to the project area and therefore, use by
the general public, these become doubtful concerns to the
larger community that would not have an alternate mode of
travel .
We support the balance of resource use and protection
presented in Alternatives 3 and 6. The recreation
opportunities that would be created are coordinated well with
the proposed timber harvest. The areas that would be
retained for wildlife habitat and use appear to be
substantial, to be able to support more than viable
populations, and to create, in conjunction with future road
access from town, hunting and fishing opportunities. The
specific areas of old growth retention particularly in the
western section of VCU 747 and the northeastern section of
VCU 748 are well placed as our resource review for the land •>
exchange indicates. We are curious that more emphasis was
not given to VCU 753, as it appears to meet the primary deer
winter range criteria as presented in several USFS documents -
and the deer habitat capability model. Alternative 5 appears
to over emphasize old growth retention and to place large
acreages in retention that appear to be of secondary
importance for deer.
We believe that balanced resource development, particularly
an active timber industry, is key to the growth of our
community, to its economic health and to the creation of
increased recreation and cultural opportunities. We
encourage the Forest Service to continue multiple use
development of forest resources on Revilla Island. There is
a definite need for the associated opportunities that are
created from resource development as has occurred on Prince
of Wales Island.
Thank you for the opportunity to comment.
Sincerely,
fishing.
Douglas M. Campbell
Land and Resource Manager
Letter From Douglas M. Campbell, Land and Resource Manager,
Cape Fox Corporation
Comment 1: (paraphrased)
We cannot support Alternative 5 which effectively forecloses a road connection from Shelter Cove to
Ketchikan.
Response 1:
The Shelter Cove DEIS was prepared to plan timber sales in the Shelter Cove Area. Consideration of
a Shelter Cove - Ketchikan road would need to be planned under a separate environmental document.
Alternative 5 defers road and harvest development in the upper Salt Lagoon Creek area until a link-up
plan is undertaken. Thus, all road and harvest options are retained until a road link plan is developed.
Comment 2: (paraphrased)
If Alternative 5 were implemented, a road connection to Ketchikan through old-growth retention would,
in our opinion, be a highly unlikely prospect. Timber would not be available to assist in funding of road
construction.
Response 2:
The old-growth retention plan can be modified by a subsequent NEPA document.
Comment 3: (paraphrased)
We are curious that more emphasis was not given to VCU 753, as it appears to meet the primary deer
winter range criteria as presented in several USFS documents and the deer habitat capability model.
Response 3:
It is anticipated that the land south and west of VCU 753 would not provide populations necessary for
the recolonization of unoccupied habitat patches as the LUD II lands would be able to.
Comment 4: (paraphrased)
We are concerned that Alternative 5 appears to over emphasize old-growth retention and to place large
acreages in retention that appear to be of secondary importance for deer.
Response 4:
Sitka black-tailed deer were not the only species taken into consideration when location the blocks of
old-growth prescription. Today, when management encompasses a much broader spectrum of con-
cerns, with more emphasis being placed on a broad-based ecosystem approach to management rather
than a single species approach. Please see Chapter 4, section on Old-Growth Prescription for more
details.
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Letter From Robert D. Widness, Bell Island, U.G.I.S.
Response: We thank you.
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Response: We thank you.
Alaska Loggers Association, Inc.
Ill STEDMAN, SUITE 200
KETCHIKAN, ALASKA 99901-6599
Phone 907-225-6114
FAX 907-225-5920
January 21, 1991
Forest Supervisor
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Sir:
We have reviewed the Shelter Cove DEIS and
have the following comments:
The Shelter Cove area is going to supply three
major links that are very important to the people
in the Ketchikan area. Development of the area
will provide an immediate supply of timber for the
forest products industry and eventually provide a
transportation link and important recreational
opportunities. To the extent possible, all of
these resources should be maximized.
The forest products industry in Southeast has
an annual raw material need of 565 MMFBM annually.
If there is to be any opportunity for growth in our
industry, which also constitutes economic and
physical growth for the region, the timber sale
program must have the potential to be larger than
.that. In order for the Forest Service to meet this
need as required by Sec. 705 of the Tongass Timber -
Reform Act: •'
"...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 market-
demand from such forest for each planning'
cycle."
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SERVING ALASKA’S TIMBER INDUSTRY
Forest Supervisor
January 21, 1991
Page 2
Timber sale programs will need to have more
emphasis than they have in the past. We,
therefore, recommend that the timber sale program
in Alternative 4 (95.6 MMBF) be the preferred
alternative .
There are important reasons for emphasizing
timber in the early development of the area. It
pays for the basic transportation system that will
be required for future recreation development. By
harvesting the area at this time, the clearcuts
will have begun to heal by the time a road link is
built to Ketchikan.
Ketchikan is in a real bind for forest
recreation opportunities . A road link to the
Shelter Cove area will supply a much needed outlet
as a place to drive to "get out of town". This
will give some relief to the existing areas that
are now accessable. We do not need roadless areas.
There are plenty of those already available. A
future road link to the Misty Fjords National
Monument can take care of any future needs .
The transportation system that will develop
from this program is extremely important. It is
important to the forest products industry because
it will access future timber supplies. It begins
the long-awaited program to link Ketchikan to the
outside world by road. When the road system is
finally tied to Ketchikan, it will provide a
recreational outlet that is sorely needed.
Recreational driving is one of the main
recreational uses of national forest lands
everywhere and the need is great in Ketchikan. We,
therefore, recommend that the road system be a
combination of Alternatives 4 and 6 and may even
consider eventually linking the road system through
the private land on the east side of George Inlet.
Thank you for the opportunity to present our
views .
Sincerely,
Jaufl $■
Laryy B. Biasing
Administrative ‘Assistant
Letter From Larry B. Biasing, Administrative Asst.,
Alaska Loggers Assoc., Inc.
Comment 1: (paraphrased)
There are important reasons for emphasizing timber in the early development of the area. It pays for the
basic transportation system that will be required for future recreation development.
Response 1:
The Shelter Cove plan is intended to provide timber sales in the Shelter Cove area. The Shelter Cove
- Ketchikan road link is not within the scope of this plan. However, all alternatives develop a mainline
road that can become part of that link.
Other roads in the project area will support future sales.
It is expected that recreational use of the area will be low until a link to Ketchikan is developed.
Development of that link will require a separate environmental assessment which will include a complete
recreation assessment and implementation plan.
Comment 2: (paraphrased)
A road link to the Shelter Cove area will supply a much needed outlet as a place to drive to "get out of
town".
Response 2:
See Response 1.
Comment 3: (paraphrased)
A future road link to the Misty Fjords National Monument can take care of any future needs.
Response 3:
See Response 1 .
Comment 4: (paraphrased)
The transportation system that will develop from this program is extremely important to the forest
products industry.
Response 4:
See Response 1.
Comment 5: (paraphrased)
The transportation system begins the long-awaited program to link Ketchikan to the outside world by
road.
Response 5:
See Response 1.
January 21 1991
Eric Muench
228 Martin St.
P.O.Box 681 1
Ketchikan, Alaska 99901
Forest Supervisor
Ketchikan Area
Tongass National Forest RE: SHELTER COVE D.E.I.S.
Federal Bldg.
Ketchikan, Alaska 99901
Dear Sir,
Having studied your documents and talked to your well-informed
people at the meeting I would like to comment on the choice before
you .
I prefer Alternate 2 for the following reasons; ■
1 ) It offers the highest potential return to the government,
which is important to me as a taxpayer. Also by creating
better returns there is going to be less critism in Congress
of deficit sales and timber money loss. Untill other resources
can be identified and charged up the additional costs that
is incurred in their behalf during timber operations, economics
should beaprimary consideration.
2) It offers access to the two identified fish pass potential
sites .
3) It utilizes the least and smallest percentage of vol. class-4.
It is poor management to depend heavily on low volume areas
for timber production. They are almost always low sites.
They will be economically impossible to do intensive silvicul-
tural work on. They will take the longest time to reforest
to a "natural" look. Management - wise they are a one-shot
deal .
3
4) There are no unacceptable impacts. 35 years of intensive clearcut
logging, most of it under environmental guidelines less demanding
than present practice, has not ruined permanently any fish
streams in Southeast, with one possible exception. Most short-
term impacts have been minor and unmeasureable against other
natural phenomenon that affect fish runs.
In this generally "hinterland" area immediate views are not
important. It will be years before the road connects through
and clearcuts are not ugly anyway. We should not be ashamed
of a good management practice. The Saddle Lakes recreational
potentials are well protected by this alternate.
<
I would like to offer one revision to alternate 2 however.
Units 30, 31, 32, and 33 in VCU 748 , just above Leask Cove and
east of Leask Creek on the ridge, have been identified as important
deer wintering areas. They were known to recently retired and
-page 2-
very experienced wildlife biologist Bob Wood of the ADF&G
and their heavy winter use has been confirmed this winter by aerial
observation. This is a major winter destination for Leask Lakes
area deer herd and some of it, particularly that just northeast
of the mouth of Leask Creek may be "critical" winter range. I
suggest those be dropped from entry and placed in retention.
A few general observations:
1) Vol . I, Chapter 3, Recreation Demand;
A recent survey by the Ketchikan Gateway Borough indicated
public willingness to use recreation areas <»ithin sight of
clearcuts and to travel through clearcuts to get to them.
This should be reflected in your list and should help inform
your choices.
2) I believe the Hairy Woodpecker and Bald Eagle are not good
indicator species. The Downy Woodpecker is too nearly alike
to be easily distingquished in the field and the eagle will
use any area with nest sites and open feeding ground.
3) Subsistence is not an important consideration when the population
entitled to such use is so small and so arbitrarily and discrimin-
atorily chosen and when Saxman is a mere suburb of Kethchikan
and Metlakatla has a large reservation to itself.
4) The computer drawn maps and scenes in Vol II are hard to read.
5) Your description of the "Hume Isl." (Salmonberry Point) LTF
in Vol. II, Chapter 2 , LTF sites discussion does not taKE INTO
account that the thing already exists. Also there are 3, not
2 eagle trees there and they do not need to be disposed of
and they have been used throughout the recent activity period.
6) In Vol II, Chapter 3 maps, "EXISTING ROADS" is not up to date. £
The Cape Fox Corp can supply you with maps of recently built
roads in the Salmonberry Creek, and Coon Cove areas.
7) It is very important that you do not consider any ad
unless they are first exposed to the public in a sep
ument. These are presently of greater concern to more people
in the Ketchikan area (due to accessibility) than most of the
Shelter Cove area.
In closing, thank you for your excellent public involvment
efforts in this project and for this oppurtonity to comment.
cutting units in the Brown Mountain or Harriet Hunt
Eric Muench
Letter From Eric Muench, Ketchikan, AK
Comment 1: (paraphrased)
It is recommended that until other resources can be identified and charged up, the additional costs that
is incurred in their behalf during timber operations, economics should be primary consideration.
Response 1 :
Economics is important, but not the only consideration in the decision making process. The economics
of each alternative is displayed relative to one another, but to focus only on this issue would not meet
the objectives of planning for multiple use/resource management.
Comment 2: (paraphrased)
It is poor management to depend heavily on low volume areas for timber production. They will be
economically impossible to do intensive silvicultural work on.
Response 2:
TheTongass Land Management Plan (TLMP) gives direction to harvest in lower volume classes. We feel
that silvicultural treatment will improve the capacity of these lower volume stands.
Comment 3: (paraphrased)
Units 30, 31 , 32, and 33 in VCU 748, just above Leask Cove and east of Leask Creek on the ridge, have
been identified as important deer wintering areas. They were known to recently retired and very
experienced wildlife biologist Bob Wood of the ADF&G and their heavy winter use has been confirmed
this winter by aerial observation. This is a major destination for Leask Lakes area deer herd and some
of it, particularly that just northeast of the mouth of Leask Creek may be ■critical' winter range. I suggest
those be dropped from entry and placed in retention.
Response 3:
Alternatives 4, 5 and the Record of Decision reflect this concern.
Comment 4: (paraphrased)
I believe the Hairy Woodpecker and Bald Eagle are not good indicator species. The Downy Woodpecker
is too nearly alike to be easily distinguished in the field and the eagle will use any area with nest sites
and open feeding ground.
Response 4:
In 1 985, the Forest Service, in cooperation with the Alaska Department of Fish and Game, U.S. Fish and
Wildlife Service, and National Marine Fisheries Service, developed and implemented a process to
identify species having the greatest potential to serve as MIS for the Alaska Region. The Hairy Wood-
pecker and Bald Eagle are designated as Managment Indicator Specis (MIS) for the Alaska Region of
the Forest Service.
The Hairy Woodpecker is much larger than the Down Woodpecker and has a large bill and the outer
tail feathers are entirely white. The Bald Eagle requires special habitats that are discussed in great detail
in the Model (Suring et al. 1988d).
Comment 5: (paraphrased)
Subsistence is not an important consideration when the population entitled to such use is so small and
so arbitrarily and discriminatorily chosen and when Saxman is a mere suburb of Ketchikan and Metlakat-
la has a large reservation to itself.
Response 5:
Subsistence rights are not determined by the size of the community.
Comment 6: (paraphrased)
I am concerned that the computer drawn maps and scenes in Vol II are hard to read.
Response 6:
We agree, and have attempted to resolve this in the FEIS.
Comment 7: (paraphrased)
Your description of the "Hume Isl.' (Salmonberry Point) LTF in Vol. II, Chapter 2, LTF sites discussion
does not take into account that the thing already exists. Also, there are 3, not 2 eagle trees there and
they do not need to be disposed of and they have been used throughout the recent activity period.
Response 7:
Hume Island LTF is portrayed as existing on the Hume Island map, Vol. II, Chapter 2 - LTF Sites
Investigated. Existing LTF is printed directly under the title 'Hume Island'.
Comment 8: (paraphrased)
In Vol II, Chapter 3 maps, 'EXISTING ROADS' is not up to date.
Response 8:
At the time of this writing, Cape Fox Corp. was expanding their road system. The roads shown on the
maps were those known at the time. The private roads of most interest to use were those that might
provide access from National Forest lands to private log transfer facilities.
Comment 9: (paraphrased)
It is very important that you do not consider any additional cutting units in the Brown Mountain or Harriet
Hunt Lake areas unless they are first exposed to the public in a separate document.
Response 9:
Harvest in these areas have not been considered in the Final EIS.
<&rb
STEVE COWPER, GOVERNOR
DEPARTMENT OF FISH AIVD GAME
HABITAT DIVISION i
2030 SEA LEVEL DRIVE
SUITE 205
KETCHIKAN, ALASKA 99901-6064
PHONE: (907) 225-2027
January 18, 1991
Mr. Steven T. Segovia
Ketchikan Ranger District
3031 Tongass Avenue
Ketchikan, Alaska 99901
Re: Shelter Cove DEIS
Dear Steve:
Upon examination of the Shelter Cove DEIS, we were pleased to
find such a well written and presented preliminary draft
outlining possible management alternatives for southern Revilla
Island. The quality of work in its preparation appears to be a
significant improvement over some past sale plans, and local
Forest Service staff is to be complimented for their efforts.
However, certain proposals contained within the plan would be
counter-productive to the protection of fish and wildlife and
the public's use of such resources. Provided such options are
omitted from the selected alternative, our staff would consider
the Shelter Cove EIS an example of a job well-done.
GENERAL COMMENTS
The maps showing unit lay-outs in the draft are somewhat / /
difficult to read and interpret. Logging unit numbers are \
oftentimes illegible. We recommend that an improved high-
quality map of at least the preferred alternative be included in
the Final EIS.
Figures and maps throughout the DEIS are sometimes poorly and / 2
inconsistently labeled. Some tables need appropriate summary \
columns and rows.
This draft was prepared before President Bush signed the Tongass
Timber Reform Act on November 28, 1990. Stream protection
guidelines need modification to meet prescribed minimum
standards designated by Congress. Perhaps other .things in the
draft also need to be adjusted to meet Congressional intent or
guidelines .
Mr. Steven T. Segovia
-2-
January 18, 1991
A new state forest practices act was passed in 1990 which
considerably upgraded fisheries habitat protection within the
riparian zone. The Forest Service Standards and Guidelines and
Mitigation Measures described in Chapter 2 of this document must
be similarly upgraded to be consistent with these new state
standards and the ACMP. Paragraph 2 of Chapter 1, page 7,
(Coastal Zone Management) must also reflect that the Forest
Service has likewise up-graded their standards to be consistent
with Alaska's Coastal Management Program and the 1990 revisions
to the Forest Resources and Practices Act.
We would like to review proposed road crossings and other
instream activities in more detail. Mitigation measures to
protect fishery resources affected by instream work need to be
strengthened and given individual site-specific prescriptions.
For example, the general May 15-August 15 timing window (page 35)
proposed for instream activities is oftentimes not applicable for
adequate protection of fisheries resources. Individual timing
windows need to be described and implemented on a site-specific
basis to assure consistency with our ACMP review.
The term "overmature" in reference to old-growth is obsolete,
except perhaps if used in a strictly silvicultural context. This
term should be defined in the glossary, and needs to be deleted
in its general association with old-growth in the text of the
FEIS .
We would disagree with the statement contained in Mr. Lunn's
November 23, 1990 cover letter that, "the alternatives selected
for the Shelter Cove DEIS reflect the New Perspective approach."
If good decisions are made in the eventual selection of a
preferred alternative, certain aspects of "New Perspectives"
could be incorporated into a final plan. Even though the draft
alternatives are clearly presented, it does not appear any of
them are examples of a "New Perspectives" approach in their
present form. How will future entries be handled, for example?
This DEIS lacks a lif e-of-the-rotation plan, permanently
designated wildlife retention, and a definitive cumulative
effects analysis. Consequently, the alternatives presented look
much like a typical timber sale, which will likely be followed by
other future small timber sales in the same area, of which we
know nothing about at the present time.
In an attempt to improve the clarity of this response, we have
separated out many of our individual page-specific comments from
the concepts to which they apply. Following the presentation of
some of these main points are the more detailed page-specific
comments pertaining to this DEIS (Enclosure A) .
Mr. Steven T. Segovia
-3-
January 18, 1991
SALT LAGOON /LAKE UNITS
All alternatives, except for #1, propose what we consider ^
unacceptable impacts to wildlife around the Salt Lagoon and the _j
old growth block in this drainage. It is extremely important for
the future of wildlife and biological diversity on southern
Revilla Island that the old growth block located between this
salt lagoon and the Naha remain in an unfragmented and unlogged
condition. The identification of this area as particularly
critical for permanent wildlife retention represents the
collective thoughts and agreement of Forest Service and Alaska
Department of Fish and Game biologists with decades of cumulative
field experience in southern Southeast Alaska.
The state-owned land around the saltchuck has been proposed as a
Critical Wildlife Habitat Area. This should be mentioned in the
final EIS . We have attached an informational sheet on wildlife
resources within the saltchuck (Enclosure B) . Even though a road
may eventually pass through this drainage, it would definitely be
counter-productive to wildlife in a "New Perspectives" approach
to construct any roading in this drainage during this initial
entry. We recommend units in this area be deleted from a final
alternative selected in the Record of Decision.
Alternative 5 comes the closest to meeting the objectives stated
in the previous paragraph, but has at least three units which
would adversely affect the integrity of the old growth block
around the saltchuck. Although the unit numbers on the map are
very difficult to read, it appears they are numbered 747-23, 747-
24, and 747-25. These units are adjacent to riparian areas of
major saltchuck tributaries, have generally southwest-facing
aspects, and appear to be valuable as important wildlife habitat
even if they were not a part of this critical block of old-
growth. We would like to request that these units be deleted
from the final alternative selected in the Record of Decision.
We should also note that some of the units in and around the
Saltchuck Creek/Lake drainage have significant potential
conflicts with fisheries concerns. In particular, there are six
or more units located on steep slopes and sensitive soils above
the Saltchuck Creek/Lake coho spawning habitat. Roading
throughout this drainage could also have a significant impact to
the water quality in this presently unimpacted stream. Road
building to and across the creek has additional adverse impacts
because of the potential for the overharvest of sensitive summer
run coho stocks within the saltchuck and its main inlet stream.
Mr. Steven T. Segovia
-4-
January 18, 1991
LEASK COVE UNITS
Extensive impacts around Leask Cove are also proposed in
Alternatives 2, 3, 4, and 6. If left unlogged, Leask Cove is
another area of exceptional wildlife/recreational values which
will likely eventually be available to Ketchikan residents via
the road system. The slopes of these proposed units have some of
the highest known deer densities in the immediate Ketchikan area.
The cutting of old growth here would result in a significant loss
of deer winter range, and the loss of hunting and other
recreational opportunities. Lacking a connective road system, it
would seem premature to cause such disruptive impacts to this
high quality wildlife habitat and recreational area at this time.
If timber harvest is to occur here, it should follow the
selection of a final connective roading alignment. This is
currently being explored by ADOT/PF, but the results of their
preliminary work will probably be unavailable until next year.
At present, there are no plans for having even a single roaded
but unlogged drainage anywhere on Revilla Island. As the lands
adjacent to the ridge above Leask Cove are currently undesignated
state-owned lands, the option still exists for making this a very
high-quality roaded recreational area available to the community.
Unfortunately, the proposed Forest Service units in the Leask
Cove area would be extremely incompatible with such an objective.
We recommend the Forest Service take no action in the Leask Cove
area until after ADOT/PF has studied a connective road alignment
and ADNR has designated a use for the adjacent state-owned lands.
Objectives should be set for wil
for adequate monitoring programs
for clearly displaying the trade
of resources. In addition, development of wildlife objectives
for the project area should include consideration of the demands
and needs of all users, not only subsistence users. (See comment
W-9 for ADF&G deer population objectives.)
The FEIS should mention that some of the unit lay-outs could
result in the logging of natal denning habitat used by river
otter. This impact appeared to be overlooked in the river otter
assessment.
Wetland losses could be dealt with in a more informative and
clearly descriptive manner. For example, what are the various
categories or types of wetlands, and which type will experience
the most impacts?
WILDLIFE
with those for timber harvest
Mr. Steven T. Segovia
-5-
January 18, 1991
The monitoring and mitigation section regarding wildlife needs to 72.1
be improved. Precommercial thinning and isolated "islands" in 3
clearcuts, for example, are not known to be effective as
mitigation. The wildlife monitoring plans should also be revised
to incorporate objectives and important monitoring and management
principles .
Although there may be sufficient deer for subsistence users at \
the present time, we are concerned with meeting recreational J
hunter demands. Any further loss of habitat will mean an even / 2Z
greater inability of the area to meet the demand of Ketchikan \
(non-subsistence) hunters. Restrictions to seasons and bag \
limits many occur as a result and Ketchikan hunters may be forced )
to hunt elsewhere. This should be clearly and explicitly
discussed in the FEIS.
We agree with the DEIS that "Due to projections of future habitat
reductions and projected demand increases ... a restriction to
subsistence users of deer, fish, black bear and furbearer species
may potentially occur in the future." This is one reason why we
feel it is essential to minimize wildlife impacts in an initial
timber harvest entry, and why Alternative 5 should be the maximum
allowable timber harvest unit dispersion which should occur under
this EIS.
CUMULATIVE EFFECTS ANALYSIS
Although some portions of the DEIS relating to wildlife are quite A
good (especially the old-growth retention plan in Alt. 5) , the I
cumulative effects analysis is not complete in any alternative. J
It is quite possible that cumulative impacts are significantly /
underestimated. The FEIS needs to consider, describe, and C 33
analyze all present impacts, and the likely future cumulative
impacts within a geographical area. This proposed action should \
be analyzed in the context of what is occurring around it, as \
well as in the context of prior and succeeding actions. For 1
example, this DEIS does not evaluate the impacts to wildlife of J
subsequent timber sales by the Forest Service, the location and
effects of increased human access over time, or the intensive
logging activities occurring on the adjacent privately-owned
lands .
In a re-analysis of cumulative impacts, we should also, perhaps,
consider expanding the analysis area. We suggest southern
Revilla island is an appropriate area for cumulative impacts
analysis; an area corresponding to Wildlife Analysis Areas 404,
405, 406, 407, and 408.
Mr. Steven T. Segovia
-6-
January 18, 1991
We raise this issue because neighboring prior timber sales and
development have already caused impacts on wildlife in the south
Revilla area. During the past five years, approximately 120
million board feet of timber was cut in several independent sales
immediately across Carroll Inlet from Shelter Cove. Timber
harvest on private land in the project area has been quite
extensive. The effects on wildlife and wildlife users of these
activities in combination with the effects of the proposed action
may be quite significant. For instance, widespread habitat loss
associated with timber harvest may result in limited hunting
opportunities throughout the southern Revilla area. Hunters,
trappers, and other wildlife users should also know what
opportunities they have elsewhere as those in the project area
become more limited. Proper assessment of cumulative impacts
should include sales in surrounding areas as well as non-Forest
Service sales within the project area.
In addition to present and future activities in areas surrounding
the project area, we also need to know the likely location of all
units, roads, and old growth retention as proposed at the end of
the rotation. To meet this essential objective, it seems
necessary to publish a proposed, or preliminary, "lif e-of-the-
rotation" map depicting how the Forest Service envisions this
planning area will appear in the year 2060. It is essential to
have such a map in the FEIS showing all present and likely future
units, roads, and retention (on lands of all ownership) so that
cumulative impacts can be put into a more meaningful context.
This would also help the public to better understand the
potential cumulative impacts. In addition, it would provide a
more realistic basis in working toward the development of a more
accurate and quantitative cumulative effects analysis regarding
future wildlife resources on southern Revilla Island.
ALTERNATIVES HARVESTED DISPROPORTIONATE TO
VOLUME CLASS OCCURRENCE
In recent Tongass Reform Legislation, Congress expressed an
intent to discontinue the practice of cutting the best volume
classes at a rate disproportionate to their occurrence on the
shown in our attached tabular summary (Enclosure C) ,
4 is under-utilized in all alternatives, while
5 is over-harvested. Disproportionate harvesting of
6 is proposed under Alternatives 2 , 4 , and 6 and
that of Volume Class 7 under Alternative 3. Alternative 5,
however, appears to come closest to harvesting in proportion to
volume class occurrence. In addition to displaying harvest
distribution by volume class as a percent of total acres
harvested (as shown in Table 4-37, Ch. 4, Pg. 39) , it would be
beneficial to also display harvest distribution by
Tongass. As
Volume Class
Volume Class
Volume Class
Mr. Steven T. Segovia
-7-
January 18, 1991
volume class as a percent of existing volume class acreage. This
would present a more accurate description of proposed harvesting
by volume class occurrence.
21 cc
ROADING WITHIN DESIGNATED LUD II LANDS
Another major concern with this DEIS is that Alternatives 2, 3,
4, and 6 propose road construction in a Congressionally
designated LUD II area for the purpose of accessing timber.
A potential road link between Ketchikan and the project area, and
the establishment of a suitable alignment for an inter-island
road corridor was not examined in this planning effort. The DEIS
states that, "This issue was not considered because it is felt
that a separate environmental document would best address the
many complex issues involved." We agree. TLMP also requires
that roads into a LUD II area, "... will not be built except to
serve authorized activities such as mining, power and water
developments, aquaculture developments, transportation needs
determined by the State of Alaska, and vital forest
transportation system linkages." Roads cannot be built into a < 'Xfc
LUD II area for the purpose of achieving access to adjacent \
logging units as a part of a routine timber sale.
There are several alternative routes which need to be evaluated
with regards to a future transportation corridor or a "vital
forest transportation system linkage," It is doubtful that more
than one linkage transversing the Naha LUD II area could be
justified as essential. With several potential alignments
available, it should be recognized that proposed roading into a
LUD II area and a connective transportation linkage should,
therefore, not occupy more than one route through designated LUD
II.
It is not expected that the State of Alaska, Department of
Transportation and Public Facilities, will be able to identify a
preferred transportation corridor until sometime after completing
scheduled preliminary assessments. It is our understanding the
results of this work will not be available for about a year.
Consequently, it would be premature to build any roading into a
LUD II area until all transportation alternatives have been
addressed in a separate environmental document involving ADOT/PF
as a lead participant. As such a document will not be available J
in draft form for a least a year, it appears that roading into f 3°
the Naha LUD II area may not be a legal option if selected as an ^
alternative under this particular EIS.
Mr. Steven T. Segovia
-8-
January 18, 1991
SALMONBERRY CREEK LOG TRANSFER FACILITY
There are several problems with using the Salmonberry LTF located )_
near Hume Island. We would suggest building the small section ofC^'
connective road to these units so that timber from this area
could be transferred to saltwater at Shelter Cove.
The original intent in the permitting of this site was that it be
temporary in nature. A main reason for this was its close
proximity to eagle nest trees, which could preclude the
successful nesting of one to three pairs of bald eagles at this
location. We continue to believe that, with logging nearly
completed, activities at this LTF need to be closed-out as soon
as possible to mitigate continuing impacts to bald eagles.
The Sport Fish Division has also noted conflicts with the
occupation of surface waters near Hume Island, and in 1988 ADF&G
asked for the close-out of temporary logging activities near Hume
Island within two years. Staff therefore anticipated no permit
renewal and expected the cessation of activities at this LTF in
the summer of 1991.
We feel that fish, wildlife, and public-use conflicts as a result
of the Forest Service's proposed timber sale should be minimized
by confining impacts to a single LTF located at Shelter Cove.
This decision would hopefully allow problems with bald eagles and
various user-groups to subside in the vicinity of Hume Island and
Salmonberry Creek in the relatively near future.
RECOMMENDED REVISIONS TO ALTERNATIVE 3 (RECREATION)
Wildlife and outdoor recreation are directly linked. For both
consumptive and non-consumptive users of wildlife resources there
is an inseparable association between the abundance and diversity
of wildlife and the quality of recreational experiences. Certain
types of outdoor recreation, though are not particularly
wildlife-related. Roading and logging can occur to promote these
types of recreation, but proper planning should be used to locate
such recreational developments away from sensitive wildlife
habitats.
Our staff would disagree with the presentation of Alternative 3 / 3*2.
a recreational alternative. As presented. Alternative 3 does \
as
not promote recreation and is quite detrimental to wildlife.
However, Alternative 3 could be modified so that it can -77
accomplish recreational objectives without significantly \ 5 ^
Mr. Steven T. Segovia
-9-
January 18, 1991
impacting wildlife habitat. To accomplish this, all of the
roading and cutting units in the Saltchuck drainage and the Leask
Cove area should be omitted. A recreational/timber access road,
however, could be extended from the other direction to provide
immediate recreational benefits without significantly affecting
sensitive wildlife habitats. This alternative road would go from
the existing Harriet Hunt parking lot, around the north side of
Harriet Hunt Lake, over the saddle located to the northeast of
Harriet Hunt Lake, and north into Sections 34 and 27 along the
Forest Service/State boundary ownership. Several logging units
could be located in the east half of Sections 34 and 27 without
affecting the Harriet Hunt viewshed. Also, as this road would go
transversely through uncut old growth in an east-west direction,
it would be virtually invisible from Harriet Hunt Lake.
Approximately 3\ miles of new roading would be built, which would
serve to greatly expand roaded recreational opportunities
currently available to Ketchikan residents.
Our proposed units in T.73S., R.91E., S.27 and 34 could be
patterned after the same principles presented in the Brown
Mountain Sale EIS. Like Brown Mountain, these would be higher-
elevation units with potentially low-value timber receipts.
Wildlife impacts would be relatively minor and recreational
monies could be used to partially fund roading costs. A new
community firewood collection program and greatly increased
recreational opportunities are obvious benefits from a sale in
this area, as they were with Brown Mountain units, which were
supported by ADF&G . This new roading would then access an area
experiencing the best winter-time snow conditions available on
the Ketchikan road system, and would be extremely beneficial to
those interested in cross country skiing, sledding and
snowmobiling. In the summer-time, this sale area would provide
for feasible hiking access into the Leask Creek drainage, with
roaded access becoming available to within only ih, mile of Leask
Lake. Additionally, this route may also eventually be used as a
portion of a future transportation linkage extending to the rest
of the sale in Shelter Cove planning area. Forest Service
roading engineers have preliminarily identified this option as
the most direct, least costly, and most feasible corridor linkage
alignment extending from the present road system.
ADVANTAGES OF ALTERNATIVE 5
We believe the selection of Alternative 5, with certain
modifications, is the logical and most acceptable option in the
event of an initial timber harvest entry into this planning area.
This alternative has the following advantages:
- is the only action alternative which retains a suitable
block of old-growth for the long-term maintenance of
wildlife diversity and abundance.
Mr. Steven T. Segovia
-10-
January 18, 1991
- is the only action alternative which retains important
travel corridors for wildlife between the Saltchuck, Naha,
and Leask Lakes drainages.
- is the most compatible with possible future management of
the George Inlet Saltchuck as a Critical Habitat Area.
- Maintains the Leask Cove area (if perhaps only
temporarily) for its wildlife and recreational values.
- does not unacceptably road a designated LUD II prior the
preparation of an adequate EIS for such an activity.
- is economically viable.
- with modification, would meet the requirements of the
existing MOU regarding the protection of bald eagle nests.
- appears to be the only alternative that meets current
VQOs .
- does not high-grade volume classes 6 and 7 , and comes the
closest to logging in relation to volume class occurrence.
- has the least impact to present and future subsistence
activities.
- has the fewest number of bridges and major culverts with
the lowest bridge/ reconstruction costs.
- has the least amount of road construction in or near
stream buffers.
- does not propose units located on steep soil areas above
the Salt Lake coho spawning areas.
- does not create conflicts with a rare and sensitive summer
coho run found in the Saltchuck drainage.
- has the fewest overall impacts to fisheries.
- if combined with roading and units into T.73S., R.91E., S.
27 and 34, it could provide immediate year-round
recreational and firewood collection benefits to community
residents.
SUMMARY
All action alternatives except Alternative 5 have significant
conflicts with resources other than timber harvest. In order to
adequately protect wildlife values, roading and units should be
kept out of the Saltchuck/ Lake basin and the Leask Cove area
Mr. Steven T. Segovia
-11-
January 18, 1991
during this planning phase. This old growth block is important
for the maintenance of healthy wildlife populations on southern
Revilla Island and is also needed for possible upcoming wildlife
research. Units located on the steep sensitive soils above the
Salt Lake coho spawning areas could also prove to be quite
detrimental to fisheries concerns. Additionally, any roading
into a designated LUD II area appears to be unacceptable under
this EIS . The DEIS has recognized that a route identifying the
alignment of a proposed road linkage needs to be addressed in a
separate environmental document. Such planning effort is also
required for roading into a LUD II area.
Therefore, selecting Alternative 5 of the DEIS appears to meet
both timber harvest objectives and most short-term wildlife
concerns. We recommend at least three units, though, be deleted
from Alternative 5. However, as no alternatives provide for
significant roaded recreational opportunities, we also recommend
extending about 3% miles of additional roading from the Harriet
Hunt parking lot to access several units in a higher-elevation
winter-time recreational area located in T.73S., R.91E., S.27 and
34. This roading would also promote hike-in recreational access
to Leask Lake, located only l\ mile to the north. We feel this
specific additional roading and logging could greatly increase
real and immediate recreational attributes, which are currently
lacking in the EIS for this planning area. The additional
alternative units and roads we have proposed would significantly
improve the community's present recreational options, while
minimizing impacts to sensitive wildlife habitats in other
locations .
If the selected alternative and Record of Decision can
incorporate these suggestions, we would consider this a
successful cooperative planning effort, which would set a very
positive direction for future planning endeavors on Revilla
Island.
Thank you for seeking our review of this DEIS. We extend our
compliments for the hard work of the Forest Service staff in the
preparation of this document.
Sincerely,
/Jack Gustafson
(Area Habitat Biologist
cc: Frank Rue
Rick Reed
Dave Anderson
Lorraine Marshall
3 Enclosures (10 pages)
Enclosure A
Page 1 of 6
DETAILED PAGE-SPECIFIC COMMENTS
Wildlife
W-l) We urge that wildlife habitat capability model outputs be
used for the analyses for the Final EIS as suggested on
page 4-53. We applaud the effort to use habitat
capability estimates for MIS but believe the models will
give more accurate estimates than the procedure that was
used.
An imprecise examination of some model outputs for
existing habitat capability shows deer habitat capability
considerably lower than that given in the DEIS (table
6-66, pg. 4-73) — 1,523 (all elevations) vs. 2,504 in
DEIS. Other modeled species habitat capabilities appear
to be considerably higher than those given in the DEIS
(table 4-51, pg. 4-60) : Marten 152 vs. 76 in DEIS; Black
bear 109 vs. 7 in DEIS; and River otter 29 vs. 11 in DEIS
The habitat capability models should be used in the Final
EIS to determine current habitat capability and habitat
capability for all alternatives, and to show cumulative
effects of alternatives over time to 2060.
W-2 ) It is good to see block size analysis employed for habitat
capabilities for some MIS (Chapter 4) . This is an
important factor that is left out of current habitat
capability models as they are currently run by computer.
In lieu of using the patch or block size factors of the
capability models, the DEIS block size analysis should be
retained in the Final EIS as a complement to the model
outputs .
W-3 ) We support the "effective block procedure" of old growth
block designation as described in the section title "Old
Growth Analysis 2" on page 4-56. Fragmenting of old
growth blocks as described in "Old Growth Analysis 1"
renders them useless for their purpose. Old growth
retention should remain inviolate for the life of the
rotation.
W-4 ) Criteria for wildlife old growth blocks are given in last
paragraph of pg. 4-54. However, no criteria or
description is given for what constitutes "recreation old
growth" (page 4-56 and table 4-47) . The implication is
that it is different from wildlife old growth, but how?
Unless a definition and criteria are given for "recreation
old growth" the term is vague and misleading and should be
dropped.
Enclosure A
Page 2 of 6
W-5 )
W-6)
The Cumulative Effects statements for all Management
Indicator Species (Chapter 4) mention only the acres of
that species 1 habitat that would be in old growth
prescription at the end of the rotation. Acres of habitat
do not tell a person much. All acres are not the same and
the value of habitat varies widely. The analysis should
be expanded to include how many animals that habitat will
support at the end of the rotation; in other words, give
the habitat capability for each species using the
assumptions listed in paragraph one of the deer cumulative
effects section. The analysis must also show (on a map)
exactly where permanent old growth prescription will be
located at the end of the rotation in order to be truly
meaningful.
Page 4-58 says that for each MIS, effects analyses are
discussed for the year 2060. However, we were unable to
locate them in the DEIS.
W— 7 )
W-8)
W-9)
Table 4-51, page 4-60; eliminate "Populations Estimates"
from the title. Habitat capabilities and population
estimates are different things and are not usually
equivalent. Similarly, table 4-61 and discussion on hairy
woodpeckers seems to deal with habitat capability rather
than actual population. This should be clarified.
Page 4-61, Tables 4-52 and 4-53 show only effects of
timber harvest on deer habitat quantity, not quality as
stated by the DEIS.
Page 4-73, the analysis of the effects of the alternatives i ‘
on use of Sitka black-tailed deer is inadequate and makes J
some wrong assumptions:
a) Hunter demand for deer in the DEIS is low. Hunter
demand for deer in Wildlife Analysis Areas 406 and 407, .
which include the project area, was derived by ADF&G from )
responses to a 1987 ADF&G deer hunter survey. Results \
showed demand exceeds actual harvest somewhat and amounts
to 99 deer in WAA 406 and 123 deer in WAA 407.
b) In table 6-66 (and table 2-26) , the number of deer that
habitat can support in 1990 (and consequently in 2000) , is
too large. Habitat capability model outputs should be
used to get this figure. (See comment W-l above.)
Another column should be added to the table showing
habitat capability in the year 2060 to show the effects of
clearcuts aging into less productive second growth stands.
Enclosure A
Page 3 of 6
c) In table 6-66, the DEIS derived the number of deer
needed to meet demand in 1990 by assuming an annual
harvest rate of 30%. This harvest rate is far too high
and, consequently, the number of deer needed to meet
demand is too low. ADF&G believes a sustainable annual
harvest rate for a deer population at habitat capability
is 10% (see Flynn and Suring, 1989, attached). At a
harvest rate of 10%, the number of deer needed in WAA's
406 and 407 to meet current hunter demand is 990 and 1230
respectively. Habitat capability model outputs show the
current habitat capability in all of WAA 406 to be 2473
deer, and in WAA 407 to be 1182 deer. From these figures
it is apparent that hunter demand already exceeds the
capability of the habitat in all of WAA 407 (which
contains the majority of the project area) . Although
there may be sufficient deer for subsistence users, any
further loss of habitat will mean an even greater
inability of the area to meet the demand of all other
hunters. Restrictions to seasons and bag limits may occur
as a result and Ketchikan hunters may be forced to go
elsewhere for the deer they want and need. This should be
stated clearly and explicity in the Final EIS discussion.
d) ADF&G deer population objectives for WAA's 406 and 407
from its Strategic Management Plan for deer (in prep.)
are: WAA 406, 2,102 deer; WAA 407, 1,182 deer.
Mitigation and Monitoring
M&M-l) In table 2-29 pg. 2-30, Wildlife Mitigation Measures #1,
precommercial thinning should be deleted. The improvement
to wildlife habitat by thinning second growth has proved
to be only negligible and is insignificant when compared
to the loss of habitat through clearcut logging. In
addition, there are serious doubts that such treatment is
realistically possible on a large scale given the cost and
manpower requirements. Until such time as measurable,
positive, cost-effective benefits of second growth
thinning are demonstrated, it is inappropriate to continue
to present it as a mitigation measure.
M&M-2 )
pg. 2-31, #6. The features of this Access Management
that would make it beneficial for wildlife should be
listed. An access management plan by itself is not
wildlife mitigation.
Plan
M&M-3 ) pg. 2-31, #7. This wildlife mitigation measure has little
foundation in current ecological application and is not
known to be effective. However, assuming there is value
Enclosure A
Page 4 of 6
in leaving 3 to 5 acre windfirm islands within clearcuts,
that value would be lost if the clearcuts were enlarged to
make up for the timber left standing in the islands. For
this measure to be useful for wildlife, the size of
clearcuts must remain the same and the amount of timber
cut must be reduced. For instance, if five five-acre
islands are designed for a clearcut block of 100 acres,
then only 75 acres of trees should actually be cut. If
instead, 25 acres were cut along the side of the clearcut
to make up for the timber lost to old-growth islands, the
result would be a more fragmented and less valuable
wildlife habitat. Better to leave the 25 acres of
old-growth intact on the edge of the clearcut as part of a
larger block of habitat than fragmented into mostly
useless islands in the clearcut.
M&M-4) In Appendix B, Fish Mitigation Measures For all
alternatives, riparian prescriptions for buffer strips
should be changed to comply with the Tongass Timber Refor
Act (HR 987). Minimum 100' no cut buffers should be
prescribed for all AHMU class I streams and class II
streams which feed into I's.
M&M-5 ) Monitoring, pages 2-44, 2-45. The wildlife monitoring
plan is inadequate. The plan emphasizes the measurement
of wildlife mitigation measures. Although this is a
useful type of monitoring, it generally fails to determir
the actual utility of the wildlife mitigation measures.
The one exception is the monitoring of bald eagle nestinc
activity. The bald eagle monitoring plan is
well-designed, yet like the rest of the monitoring plan,
no objectives are stated a priori. For example, the
monitoring plan fails to state what will happen if the
eagle monitoring plan detects a decrease in bald eagle
nesting activity. This is a major flaw.
indicator populations that include monitoring before,
during, and after project implementation.
c) the inclusion of mitigation measures that will be
instituted should population indices fall below specified
levels .
The monitoring plan should include:
a) wildlife population or time-trend objectives,
particularly for management indicator species.
b) the design of surveys to sample time-trends of
As stated, none of these important tenets of wildlife
monitoring are included, hence the plan is inadequate.
Enclosure A
Page 5 of 6
Maos and Figures
M-l) A map displaying place names in the project area should be
put at the beginning of the maps section. The lakes of
the area, although referred to often in the DEIS text, are
identified only on Fig. 3-7. It took some time to
discover this key. Also, South Saddle Lake on Fig. 3-7 is
different from the S. Saddle Lake on the USGS Ketchikan
C— 5 Quadrangle topographic map. This discrepancy should
be rectified or explained to avoid confusion. Leask Cove,
although referred to several times in the DEIS, is never
identified on a map.
M-2 ) Many of the harvest unit numbers on Figs. 2-1 through 2-5
and Alternative maps (Figs. A2-A6) are extremely difficult
or impossible to make out. These should be made more
readable.
M-3 )
Major Channel Types, Fig. 3-11, are illegible.
Topographic views in Figs. 4-2, 4-6, and 4-17 are not
identified.
M-4 )
We are happy to see old growth retention displayed on the
same maps as proposed cutting units for alternatives.
This makes review of alternatives much easier. Also
needed, however, are maps showing the rest of operable
forest land in the project area so that reviewers can see
where future logging is likely to occur and thus have a
visual reference of cumulative impacts. Remaining
operable forest land should be displayed on the same map
with old growth retention and cutting units. Such maps
would be more readable if produced in color.
Timber
T-l)
Page 4-42, para. 4. A sentence should be added noting
that the value of second growth trees and products is
considerably less than the value of old growth trees and
products .
T-2 )
Page 4-42, para. 5. What is the basis for the statement
that stands with volumes of 20-30 MBF/acre and those of
30-50 MBF/acre have the same future growth potential? Are
you asserting they have the same site productivity index?
T-3 )
Why does this DEIS in table 4-39 base growth/yield
projections on current inventory volume rather than site
productivity? Site productivity is used in most other
yield projections used by the USFS including the TLMP
Revision. Site productivity should be used here as well.
£o
Enclosure A
Page 6 of 6
T— 4 ) In tables 4-37 and 4-39, how are you determining acreage
scheduled by volume class — through stand exams or from
timber type maps? Given the recognized difficulties with
the accuracy of the current timber inventory, project
level plans should all rely only on data from stand exams.
Roads
R— 1 )
Vol. I, Chapter 3, page 13: The 7.6 miles of Forest
Development Roads are more than the total of 3 miles of
usable and 3.8 miles of unusable roads.
Transfer Sites
T-l) Vol. II, Chapter 2: All figures should be given numbers
in this chapter. The DEIS shows 3 preferred sites (1, 5,
and 7) , but only 2 LTF site maps (1 and 5) are given. The
profiles and site descriptions that follow are somewhat
confusing, as all proposed sites except 5, 6, and 7 have
individual profiles. The statement under site 5 that,
"Impacts must be evaluated to determine if it will be
necessary to dispose of any eagle trees," is quite
confusing and should be reworded. We agree that site 6 is
biologically unsuitable for continued log transfer (as
explained in Vol. I) , but think sites 5 and 7 should also
be removed from the list of preferred sites.
Enclosure B
PROPOSED
GEORGE INLET SALTCHUCK
CRITICAL HABITAT AREA
Nearly all species of wildlife found on Revilla Island occur at the
George Inlet Saltchuck, but typically in higher concentrations than
normal. Five streams supporting four species of salmon, and also
steelhead, flow into the chuck, and comprise an important link in the
food web of the area. There also used to be a large wintering
concentration of herring occupying the waters in and near the chuck,
though herring have not inhabited the area in large numbers since the
1970s. Very large concentrations (thousands) of mergansers and other
diving ducks (goldeneye, bufflehead, etc.) were found in the area when
large numbers of herring were present, with numbers in the hundreds
during lesser herring densities. This saltchuck is particularly
critical for its consistent use by wintering swans, except during
short periods of icing. The chuck is an important waterfowl staging
area, especially in the fall and is an important wintering area for
mallards and Canada geese. Canada goose nesting is common, including
nesting on the numerous nearby lakes. Young broods use the area for
staging when they first start flying, with flocks congregating there
in the fall. The area may be somewhat unique in its heavy usage by
pintails and teal early in the fall (September 1) .
The area is also important in other respects for subsistence,
recreational, wildlife and natural values. Dungeness crab occupy the
eelgrass beds in the chuck, and are utilized by local residents.
Commercial shrimp are taken outside the entrance to the chuck, with
both pot fishing for "spots" and pink shrimp trawling in the 50 fathom
trench in upper George Inlet. The chuck has been a popular wolf
trapping spot, along with trapping of other species of furbearers.
The territories of two wolf packs overlap the chuck, with the area
utilized by wolves year-round. The sedge meadows and grassflats are
intensively used by black bears in the spring. The two major fish
streams are heavily utilized by both bears and wolves during the
summer and fall salmon runs. Population densities of land otters and
mink are relatively high. Harbor seals use the area year round with
particularly heavy winter concentrations that haul out on the ice.
Deer hunting is also good in parts of the chuck, with harvest levels
especially high during the late 1960s. An early run of coho (July 1) ,
and runs of spring steelhead, and red, pink, and chum salmon provide
an availability of adult anadromous fish in the area for many months
of the year. The chuck's unique tidal flushing action, along with
bathemetry, flow, circulation, and other physical characteristics of
the area, contributes to overall biological fertility. The fish and
wildlife species diversity and abundance found in the chuck are
relatively rare, and are an extremely valuable resource. Special
management considerations available under the Critical Habitat Area
designation would help to assure the perpetuation of these values.
The taking of wildlife however, is usually permitted in critical
habitat areas, provided it is compatible with harvestable surplus
concepts .
Enclosure C
Page 1 of 3
PROPORTION OF VOLUME CLASS HARVESTED BY ALTERNATIVE
ALTERNATIVE 2 ; 2,191 acres scheduled for harvest
TOTAL ACRES BY VOLUME CLASS
(ACRES SCHEDULED FOR HARVEST IN PARENTHESES)
vcu
VC
4
VC
5
VC
6
VC
7
746
3,649
(92)
4,431
(447)
336
(50)
0
(0)
747
3,745
(235)
5,194
(995)
731
(244)
114
(0)
748
3 . 145
(33)
3.265
(34)
158
(6)
265
(55)
25,033
Total Acres
= 10,539 (360)
12,890 (1,476)
1,225 (300)
379
(55)
Percent of Acres
= 42% (16%)
51% (67%)
5% (14%)
2%
(2%)
Percent of Existing
Volume Class Acres
to be Harvested = 3% 11% 24% 14%
ALTERNATIVE 3 : 2,231 acres scheduled for harvest
TOTAL ACRES BY VOLUME CLASS
(ACRES SCHEDULED FOR HARVEST IN PARENTHESES)
VCU
VC
4
VC
5
VC
6
VC
7
746
3,649
(196)
4,431
(484)
336
(10)
0
(0)
747
3,745
(375)
5,194
(935)
731
(91)
114
(3)
748
3,145
(31)
3.265
(25)
158
(Q)
265
(811
25,033
Total Acres
= 10,539 (602)
12,890 (1,444) 1,225
(101)
379
(84)
Percent of Acres
= 42% (27%)
51% (65%) 5%
(4%)
2%
(4%)
Percent of Existing
Volume Class Acres
to be Harvested = 6% 11% 8%
22%
Enclosure C
Page 2 of 3
ALTERNATIVE 4 : 3,603 acres scheduled for harvest
TOTAL ACRES BY VOLUME CLASS
(ACRES SCHEDULED FOR HARVEST IN PARENTHESES)
vcu
VC 4
746
3 , 649
(489)
747
3,745
(304)
753
22 , 539
2 .703
-C3401
Total Acres
= 10,097 (1,133)
Percent of Acres
= 45% (31%)
VC
5
VC
6
VC
7
4,431
(910)
336
(65)
0
(0)
5,194
(954)
731
(221)
114
(1)
1.636
(319)
0
(0)
0
( 0 )
11,261
(2,183)
1,067
(286)
114
(1)
50%
(61%)
5%
(8%)
.5%
( . 02%)
Percent of Existing
Volume Class Acres
to be Harvested = 11% 19% 27% .9%
ALTERNATIVE 5 ; 2,581 acres scheduled for harvest
TOTAL ACRES BY VOLUME CLASS
(ACRES SCHEDULED FOR HARVEST IN PARENTHESES)
VCU
VC
4
VC
5
VC 6
VC 7
746
3,649
(262)
4,431
(757)
336 (0)
0
(0)
747
3,745
(236)
5,194
(565)
731 (34)
114
(0)
753
2.703
( 377 )
1.636
(350)
Q (0)
0
(0)
22,539
Total Acres
= 10,097 (875)
11,261 (1,672)
1,067
(34)
114 (0)
Percent of Acres
= 45% (34%)
50% (65%)
5%
(1%)
.5% (0%)
Percent of Existing
Volume Class Acres
to be Harvested = 9%
15%
3%
0%
Enclosure C I
Page 3 or 3 ’
ALTERNATIVE 6 : 3,060 acres scheduled for harvest
TOTAL ACRES BY VOLUME CLASS
(ACRES SCHEDULED FOR HARVEST IN PARENTHESES)
I
vcu
VC 4
VC
5
VC
6
VC
7
746
3 , 649
(294)
4,431
(538)
336
(33)
0
(0)
747
3,745
(407)
5,194
(1,086)
731
(187)
114
(5)
748
3 . 145
(21)
3,265
(22)
158
(0)
265
(36)
753
2.703
(268)
1.636
(164)
0
(0)
0
(0)
29,213
Total Acres =
13,242
(990)
14,526
(1,810)
1,225
(220)
379
(41)
Percent of Acres =
45%
(32%)
50%
(59%)
4%
(7%)
1%
(1%)
Percent of Existing
Volume Class Acres
to be Harvested =
7%
12%
18%
11%
I
I
I
Letter From Jack Gustafson, Area Habitat Biologist, State of Alaska
Comment 1: (paraphrased)
I am concerned that the maps showing unit lay-outs in the draft are somewhat difficult to read and
interpret and the logging unit numbers are often times illegible.
Response 1 :
We agree, and have attempted to resolve this in the Final EIS.
Comment 2: (paraphrased)
I am concerned that the figures and maps throughout the DEIS are sometimes poorly and inconsistently
labeled.
Response 2:
We agree, and have attempted to resolve this in the Final EIS.
Comment 3: (paraphrased)
Stream protection guidelines need modification to meet prescribed minimum standards designated by
Congress.
Response 3:
The stream protection standards and guidelines have been modified to meet the requirement estab-
lished in the Tongass Timber Reform Act. See FEIS, Chapter, page 36.
Comment 4: (paraphrased)
A new State forest practices act was passed in 1 990 which considerably upgraded fisheries habitat
protection within the riparian zone. The Forest Service Standards and Guidelines and Mitigation Mea-
sures described in Chapter 2 of this document must be similarly upgraded to be consistent with these
new State standards and the ACMP.
Response 4:
The modified fisheries standards and guidelines in Chapter 2 and the new Region 1 0 Forest Service Best
Management Practices are consistent with the new State forest practices act.
Comment 5: (paraphrased)
Paragraph 2 of Chapter 1 , page 7, (Coastal Zone Management) must also reflect that the Forest Service
has likewise upgraded their standards to be consistent with Alaska’s Coastal Management Program and
the 1990 revisions to the Forest Resources and Practices Act.
Response 5:
See response number 4.
Comment 6: (paraphrased)
It is recommended that mitigation measures to protect fishery resources affected by in-stream work
need to be strengthened and given individual site-specific prescriptions.
Response 6:
The Ketchikan Area implementation process will detail the site-specific prescriptions where in-stream
work is required. The Forest Service plans to consult and notify with ADF&G on all in-stream work outside
the normal May 1 5 to August 1 5 timing windows.
Comment 7: (paraphrased)
It is recommended that individual timing windows need to be described and implemented on a site-
specific basis to assure consistency with our ACMP review.
Response 7:
The objective of the timing window is to prevent disturbance of anadromous fish adults, eggs, or fry.
The May 1 5 to August 1 5 timing window is the general window when anadromous adults, fry, or eggs
are in the streams. If there is evidence of fish in the stream during the timing window, the objective of
preventing a reduction in egg or fry survival still applies. Site-specific prescriptions will be designed to
prevent impacts to egg, fry, or spawning adults (FEIS, Chapter 2, Page 35).
Comment 8: (paraphrased)
The term ■overmature* in reference to old growth is obsolete. This term should be defined in the glossary.
Response 8:
The term is used in a silvicultural context and reflects the silvicultural concept that growth is offset by
mortality. The term has been defined in the glossary.
Comment 9: (paraphrased)
I disagree with the statement the alternatives selected for the Shelter Cove DEIS reflect the New
Perspective approach'.
Response 9:
The Action Alternatives utilize the new perspective concept of old-growth blocks, however, Alternative
5 represents this concept the best.
Comment 10: (paraphrased)
How will future entries be handled, for example? This DEIS lacks a life-of-the-rotation plan, permanently
designated wildlife retention, and a definitive cumulative effects analysis.
Response 10:
Future entries and designated wildlife retention will be handled by separate NEPA documents. The FEIS
displays the cumulative effects over the rotation.
Comment 1 1 : (paraphrased)
All alternatives, except for #1, propose what we consider unacceptable impacts to wildlife around the
Salt Lagoon and the old-growth block in this drainage.
Response 11:
We disagree. We feel that our analysis has taken the impacts to wildlife around Salt Lagoon and the
old-growth blocks of that drainage into consideration. Alternative 5, for example, proposes only two units
be harvested in the Salt Lagoon drainage.
Comment 12: (paraphrased)
The State-owned land around the saltchuck has been proposed as a Critical Wildlife Habitat Area. This
Should be mentioned in the final EIS.
Response 12:
Your concern has been addressed in the FEIS.
Comment 13: (paraphrased)
It would definitely be counter-productive to wildlife in a ’New Perspectives* approach to construct any
roading around Salt Chuck drainage during this initial entry. We recommend units in this area be deleted
from a final alternative selected in the Record of Decision.
Response 13:
Alternative 5 constructs roads only on the east side of Salt Lagoon and maintains the *New Perspectives*
approach to management.
Comment 14: (paraphrased)
Alternative 5 comes the closest to meeting ADF&G objectives, but has at least three units which would
adversely affect the integrity of the old-growth block around the saltchuck. Although the unit numbers
on the map are very difficult to read, it appears they are numbered 747-23, 747-24, and 747-25. These
units are adjacent to riparian areas of major saltchuck tributaries, have generally southwest-facing
aspects, and appear to be valuable as important wildlife habitat even if they were not a part of this critical
block of old growth. We would like to request that these units be deleted from the final alternative
selected in the Record of Decision.
Response 14:
These areas you refer to have wildlife value. However, the ID Team felt the corridor from the NAHA was
more valuable. With the implementation of the modified AHMU standards and guidelines, and the soil
and water standards, we feel these areas will be protected.
Comment 15: (paraphrased)
Some of the units in and around the Saltchuck Creek/Lake drainage have significant potential conflicts
with fisheries concerns. Roading throughout this drainage could also have a significant impact to the
water quality in this presently unimpacted stream. Road building to and across the creek has additional
adverse impacts because of the potential for the overharvest of sensitive summer-run coho stocks within
the saltchuck and its main inlet stream.
Response 15:
We disagree. With implementation of modified AHMU standards and guidelines, and the soil and water
standards, no significant long-term damage to fish habitat productivity will occur. The potential impacts
of timber harvest within Salt Creek has been detailed in the comparison of alternatives, effects of timber
harvest activities (DEIS, Chapter 2, Pages 19-20). This information will be used by the Forest Supervisor
in making a decision on which of the seven alternatives, or another alternative, to select.
Comment 16: (paraphrased)
Extensive impacts around Leask Cove are also proposed in Alternatives 2, 3, 4, and 6. If left unlogged,
Leask Cove is another area of exceptional wildlife/recreational values. Lacking a connective road
system, it would seem premature to cause such disruptive impacts to this high quality wildlife habitat
and recreational area at this time. If timber harvest is to occur here, it should follow the selection of a
final connective roading alignment.
Response 16:
Alternatives 2 and 5 reflect this concern.
Comment 17: (paraphrased)
As the lands adjacent to the ridge above Leask Cove are currently undesignated State-owned lands,
the option still exists for making this a very high-quality roaded recreational area available to the
community. Unfortunately, the proposed Forest Service units in the Leask Cove area would be extremely
incompatible with such an objective. We recommend the Forest Service take no action in the Leask Cove
area until after ADOT/PF has studied a connective road alignment and ADNR has designated a use for
the adjacent State-owned lands.
Response 17:
Alternatives 2, 5, and the ROD reflect this concern.
Comment 18: (paraphrased)
Objectives should be set for wildlife and other resources along with those for timber harvest. Wildlife
objectives are necessary for adequate monitoring programs as well as for clearly displaying the trade-
offs necessary in any allocation of resources.
Response 18:
Page 4-64 of the DEIS stated The Alaska Department of Fish and Game has designed a process to
establish population objectives for deer based on human demand. The process is in its early stages and
has not yielded estimates of desired harvest levels.' To this date, Tongass Forest Leadership and Alaska
Department of Fish and Game Leadership have not yeat set population objectives.
Comment 19: (paraphrased)
The FEIS should mention that some of the unit lay-outs could result in the logging of natal denning
habitat used by river otter.
Response 19:
Your concern has been addressed in the FEIS.
Comment 20: (paraphrased)
What are the various categories or types of wetlands, and which type will experience the most impacts?
Response 20:
Some information on wetlands is provided on page 3 of Chapter 3 of the DEIS. Table 3-2 of the draft
shows that approxiamtely 2/3 of the wetlands are forested. These lands generally have a tree cover.
These trees, however, generally grow slower and are smaller in size though the same age of trees we
generally think of as typical in southeast Alaska. This is because water is often just below the surface
and within the rooting depth of the trees. These forests on wetlands are often not commercially or
economically viable forests (i.e., production is less than 8,000 board feet per acre), or these wetlands
support the lowest volume class of commercial timber (class 4, 8,000 to 20,000 board feet per acre).
Muskegs comprise about 1/3 of the wetlands, and this water may be visible on the surface or apparent
if one walks across the area. The vegetation usually does not include trees. Vegetation includes other
life forms, such as mosses, sedges, grasses, and low shrubs.
Table 4-5 on page 5 of Chapter 4 of the DEIS shows that forested wetlands will be affected more than
muskegs for the action alternatives. Tables 4-6 and 4-7 of the DEIS show that proposed activities for
harvest are greater than proposed activities for road construction. Harvesting timber on forest wetlands
will be done in areas of volume class 4 timber in the action alternatives.
Comment 21 : (paraphrased)
The monitoring and mitigation section regarding wildlife needs to be improved. The wildlife monitoring
plans should also be revised to incorporate objectives and important monitoring and management
principles.
Response 21 :
The monitoring and mitigation section of this document has been designed to monitor habitat conditions
and monitor implementation.
Comment 22: (paraphrased)
Although there may be sufficient deer for subsistence users at the present time, we are concerned with
meeting recreational hunter demands. Any further loss of habitat will mean an even greater inability of
the area to meet the demand of Ketchikan (non-subsistence) hunters. Restrictions to seasons and bay
limits may occur as a result and Ketchikan hunters may be forced to hunt elsewhere. This should be
clearly and explicitly discussed in the FEIS.
Response 22:
Your concern has been addressed in the FEIS.
Comment 23: (paraphrased)
Although some portions of the DEIS relating to wildlife are quite good (especially the old-growth
retention plan in Alternative 5), the cumulative effects analysis is not complete in any alternative. It is
quite possible that cumulative impacts are significantly underestimated. The FEIS needs to consider,
describe, and analyze all present impacts, and the likely future cumulative impacts within a geographical
area This proposed action should be analyzed in the context of what is occurring around it, as well as
in the context of prior and succeeding actions. The DEIS does not evaluate the impacts to wildlife of
subsequent timber sales by the Forest Service, the location and effects of increased human access over
time, or the intensive logging activities occurring on the adjacent privately-owned lands.
Response 23:
Your concern has been addressed in the Subsistence section of the FEIS.
Comment 24: (paraphrased)
In a re-analysis of cumulative impacts, we should also, perhaps, consider expanding the analysis area
We suggest southern Revilla Island is an appropriate area for cumulative impacts analysis; an area
corresponding to Wildlife Analysis Areas 404, 405, 406, 407, and 408.
Response 24:
Your concern has been addressed in the Subsistence section of the FEIS.
Comment 25: (paraphrased)
In addition to present and future activities in areas surrounding the project area, we also need to know
the likely location of all units, roads, and old-growth retention as proposed at the end of the rotation.
To meet this essential objective, it seems necessary to publish a proposed, or preliminary, ’life-of-the-
rotation* map depicting how the Forest Service envisions this planning area will appear in the year 2060.
Response 25:
Exact locations of such activities will not be known until analyzed under subsequent NEPA documents.
Effects of such activity is addressed the the cumulative effects section which assumes harvest of all
operable Forest Service, State and private land in the project area.
Comment 26: (paraphrased)
We are concerned that Volume Class 4 is under-utilized in all alternatives, while Volume Class 5 is
over-harvested. Disproportionate harvesting of Volume Class 6 is proposed under Alternatives 2, 4, and
6 and that of Volume Class 7 under Alternative 3.
Response 26:
Proportionality is measured by management area. In the Shelter Cove project two management areas
are included, these are K35 and K39. All action alternatives, except Alternative 2 which was the economic
alternative, do not harvest a disproportion in the higher volume classes. This analysis is displayed in
the FEIS.
Comment 27: (paraphrased)
In addition to displaying harvest distribution by volume class as a percent of total acres harvested (as
shown in Table 4-37, Ch. 4, Pg. 39), it would be beneficial to also display harvest distribution by volume
class as a percent of existing volume class acreage.
Response 27:
This has been done in the FEIS in Chapter 4, Timber.
Comment 28: (paraphrased)
Roads cannot be built into a LUD II area for the purpose of achieving access to adjacent logging units
as a part of a routine timber sale.
Response 28:
See Response 29.
Comment 29: (paraphrased)
There are several alternative routes which need to be evaluated with regards to a future transportation
corridor or a Vital forest transportation system linkage’. It is doubtful that more than one linkage
transversing the Naha LUD II area could be justified as essential. With several potential alignments
available, it should be recognized that proposed roading into a LUD II area and a connective transporta-
tion linkage should, therefore, not occupy more than one route through designated LUD II.
Response 29:
In your letter you discussed the viability of roading in the Naha LUD II area. Criteria concerning LUD II
road development is reiterated for your convenience in the following discussions. These criteria are from
the Tongass Land Management Plan, amended Winter 1985-89; USDA Forest Service, Alaska Region,
Admin. Doc. Number 174, pp. 9.
’Roads will not be built except to serve authorized activities such as mining, power and water
developments, aquaculture developments, transportation needs determined by the State of Alaska,
and vital Forest Transportation system linkages. e+
Additional criteria is displayed in footnote 6 and is included as follows:
*+ Vital Forest Transportation system linkages refer to necessary additions to the permanent road
network. Such linkages may be built through LUD II areas when either no other feasible land or water
routes exist to access adjacent LUD III or IV areas or when it can be demonstrated that the routing
through the LUD II area is clearly environmentally preferable and and site-specific mitigation mea-
sures can be designed to minimize the impact of the road on the surrounding LUD II area. A clear
need to build such linkages must be demonstrated through a comparative analysis of transportation
alternatives during the NEPA process and must be approved by the Forest Supervisor, in consulta-
tion with the other Tongass Forest Supervisors.
A detailed analysis investigating roading the LUD III lands adjacent to LUD II lands was conducted and
is in the administrative records at the Ketchikan Area Supervisor’s Office. In summary, it was found that
the roading along the border of the Naha LUD II area was environmentally preferable.
Comment 30: (paraphrased)
It appears that roading into the Naha LUD II area may not be a legal option if selected as an alternative
under this particular EIS.
Response 30:
See Response 29.
Comment 31 : (paraphrased)
There are several problems with using the Salmonberry LTF located near Hume Island. We would
suggest building the small section of connective road to these units so that timber from this area could
be transferred to saltwater at Shelter Cove.
Response 31 :
Use of the Hume Island LTF is dependent upon developing an equitable agreement with Cape Fox
Corporation. If the site is not usable, such an agreement could not be reached and all resource access
would be accomplished via the Shelter Cove LTF. This is provided for in discussions in Chapter 4, pp.
33 of the DEIS.
Comment 32: (paraphrased)
As presented, Alternative 3 does not promote recreation and is quite detrimental to wildlife.
Response 32:
Alternative 3 has the lowest harvest of any of the action alternatives, has the smallest average harvest
unit size and keeps development away for potential recreation sites. The harvest units are also widely
dispersed which lends this alternative to a recreational theme.
Comment 33: (paraphrased)
Alternative 3 could be modified so that it can accomplish recreational objectives without significantly
impacting wildlife habitat.
Response 33:
Your comment is important and the type we encourage to help us refine the draft into a final document
that incorporates public comment.
Comment 34: (paraphrased)
We urge that wildlife habitat capability model outputs be used for the analyses for the Final EIS as
suggested on page 4-53. We applaud the effort to use habitat capability estimates for MIS, but believe
the models will give more accurate estimates than the procedure that was used.
Response 34:
Your concern has been addressed in the Subsistence portion of the FEIS.
Comment 35: (paraphrased)
An imprecise examination of some model outputs for existing habitat capability shows deer habitat
capability considerably lower than that given in the DEIS (table 6-66, pg. 4-73) - 1,523 (all elevations)
vs. 2,504 in DEIS. Other modeled species habitat capabilities appear to be considerably higher than
those given in the DEIS (table 4-51, pg. 4-60): Marten 152 vs. 76 in DEIS; Black bear 109 vs. 7 in DEIS;
and River otter 39 vs. 1 1 in DEIS. The habitat capability models should be used in the Final EIS to
determine current habitat capability and habitat capability for all alternatives, and to show cumulative
effects of alternatives over time to 2060.
Response 35:
Possibly confusion occurred when comparing the Wildlife and Subsistence sections. Please note that
the 2,504 figure for deer in the Subsistence section does not incorporate the block size effects which
figure 1 ,327 in the Wildlife section does.
Comment 36: (paraphrased)
We support the 'effective block procedure' of old-growth block designation as described in the section
title 'Old-growth Analysis 2* on page 4-56. Fragmenting of old-growth blocks as described in 'Old-
growth Analysis 1' renders them useless for their purpose. Old-growth retention should remain inviolate
for the life of the rotation.
Response 36:
Wildlife retention areas established by this decision are not permanent. Retention designations will be
re-evaluated as part of any future planning for this project area. That planning process will involve the
identification of issues and concerns during the public involvement phase. Any modification to retention
as part of future planning processes will adhere to the National Environmental Policy Act.
Comment 37: (paraphrased)
Criteria for wildlife old-growth blocks are given in last paragraph of pg. 4-54. However, no criteria or
description is given for what constitutes 'recreation old growth* (page 4-56 and table 4-47). The
implication is that it is different from wildlife old growth, but how? Unless a definition and criteria are given
for 'recreation old growth' the term is vague and misleading and should be dropped.
Response 37:
The aspect of recreation old-growth prescription has been deleted from the FEIS.
Comment 38: (paraphrased)
The Cumulative Effects statements for all Management Indicator Species (Chapter 4) mention only the
acres of that species’ habitat that would be in old-growth prescription at the end of the rotation. Acres
of habitat do not tell a person much. All acres are not the same and the value of habitat varies widely.
The analysis should be expanded to include how many animals that habitat will support at the end of
the rotation; in other words, give the habitat capability for each species using the assumptions listed
in paragraph one of the deer cumulative effects section. The analysis must also show (on a map) exactly
where permanent old-growth prescription will be located at the end of the rotation in order to be truly
meaningful.
Response 38:
The analysis for the cumulative effects assumes the retention by alternative through the rotation.
Comment 39: (paraphrased)
Page 4-58 says that for each MIS, effects analyses are discussed for the year 2060. However, we were
unable to locate them in the DEIS.
Response 39:
General long-term effects were discussed in the Cumulative Effects section for each MIS.
Comment 40: (paraphrased)
Table 4-51 , page 4-60; eliminate 'Population Estimates' from the title. Habitat capabilities and population
estimates are different things and are not usually equivalent. Similarly, table 4-61 and discussion on
hairy woodpeckers seems to deal with habitat capability rather than actual population. This should be
clarified.
Response 40:
Your concern has been addressed in the FEIS.
Comment 41 : (paraphrased)
Page 4-61 , Tables 4-52 and 4-53 show only effects of timber harvest on deer habitat quantity, not quality
as stated by the DEIS.
Response 41 :
The word 'quality' has been deleted from the sentence.
Comment 42: (paraphrased)
Page 4-73, the analysis of the effects of the alternatives on use of Sitka black-tailed deer is inadequate
and makes some wrong assumptions.
Response 42:
This has been addressed in the FEIS.
Comment 43: (paraphrased)
Hunter demand for deer in the DEIS is low. Hunter demand for deer in Wildlife analysis Areas 406 and
407, which include the project area, was derived by ADF&G from responses to a 1 987 ADF&G deer
hunter survey. Results showed demand exceeds actual harvest somewhat and amounts to 99 deer in
WAA 406 and 123 deer in WAA 407.
Response 43:
This has been addressed in the FEIS.
Comment 44: (paraphrased)
In table 6-66 (and table 2-26), the number of deer that habitat can support in 1990 (and consequently
in 2000), is too large. Habitat capability model outputs should be used to get this figure. Another volume
should be added to the table showing habitat capability in the year 2060 to show the effects of clearcuts
aging into less productive second-growth stands.
Response 44:
The tables you refer to have been updated.
Comment 45: (paraphrased)
In table 6-66, the DEIS derived the number of deer needed to meet demand in 1 990 by assuming an
annual harvest rate of 30 percent. This harvest rate is far too high and, consequently, the number of deer
needed to meet demand is too low. ADF&G believes a sustainable annual harvest rate for a deer
population at habitat capability is 1 0 percent. At a harvest rate of 1 0 percent, the number of deer needed
in WAA’s 406 and 407 to meet current hunter demand is 990 and 1230 respectively. Habitat capability
model outputs show the current habitat capability in all of WAA 406 to be 2473 deer, and in WAA 407
to be 1182 deer. From these figures it is apparent that hunter demand already exceeds the capability
of the habitat in all of WAA 407 (which contains the majority of the project area). Although there may
be sufficient deer for subsistence users, any further loss of habitat will mean an even greater inability
of the area to meet the demand of all other hunters. Restrictions to seasons and bag limits may occur
as a result and Ketchikan Hunters may be forced to go elsewhere for the deer they want and need. This
should be stated clearly and explicitly in the Final EIS discussion.
Response 45:
These concerns have been addressed in the FEIS.
Comment 46: (paraphrased)
In table 2-29, pg. 2-30, Wildlife Mitigation Measures #1, precommercial thinning should be deleted. The
improvement to wildlife habitat by thinning second growth has proved to be only negligible and is
insignificant when compared to the loss of habitat through clearcut logging. In addition, there are
serious doubts that such treatment is realistically possible on a large scale given the cost and manpower
requirements. Until such time as measurable, positive, cost-effective benefits of second-growth thinning
are demonstrated, it is inappropriate to continue to present it as a mitigation measure.
Response 46:
Precommercial thinning is discussed in detail on page 2-134 of the 1989-94 Operating Period for the
Ketchikan Pulp Company FEIS.
Comment 47: (paraphrased)
Page 2-31 , #6. The features of this Access Management Plan that would make it beneficial for wildlife
should be listed. An access management plan by itself is not wildlife mitigation.
Response 47:
It is expected that after timber harvest operations are complete, human access to the Shelter Cove road
system will be very limited, because the project on an isolated road system.
Comment 48: (paraphrased)
Page 2-31 , #7. This wildlife mitigation measure has little foundation in current ecological application and
is not known to be effective. However, assuming there is value in leaving 3 to 5 acre windfirm islands
within clearcuts, that value would be lot if the clearcuts were enlarged to make up for the timber left
standing in the islands. For this measure to be useful for wildlife, the size of clearcuts must remain the
same and the amount of timber cut must be reduced. For instance, if five five-acre islands are designed
for a clearcut block of 100 acres, then only 75 acres of trees should actually be cut. If instead, 25 acres
were cut along the side of the clearcut to make up for the timber lost to old-growth islands, the result
would be a more fragmented and less valuable wildlife habitat. Better to leave the 25 acres of old growth
intact on the edge of the clearcut as part of a larger block of habitat then fragmented into mostly useless
islands in the clearcut.
Response 48:
Dr. Jerry Franklin presented a paper at the New Perspective Conference in Petersburg, Alaska in 1990.
He recommended incorporating new knowledge at the stand level by trying to maintain or recreate
stands that have a higher level of structural diversity'. One way to accomplish this would be to provide
for large standing dead and down woody debris. He also recommended leaving green trees. This
technique would provide a more structurally diverse stand in a lesser number of years than a solid
clearcut would.
Comment 49: (paraphrased)
In Appendix B, Fish Mitigation Measures - For all alternatives, riparian prescriptions buffer strips should
be changed to comply with the Tongass Timber Reform Act (HR 987). Minimum 100’ no-cut buffers
should be prescribed for all AHMU class I streams and class II streams which feed into I’s.
Response 49:
Appendix B, Fish Mitigation Measures, has been modified to comply with TTRA.
Comment 50: (paraphrased)
Pages 2-44 and 2-45, the wildlife monitoring plan is inadequate. The plan emphasizes the measurement
of wildlife mitigation measures. Although this is a useful type of monitoring, it generally fails to determine
the actual utility of the wildlife mitigation measures. The one exception is the monitoring of bald eagle
nesting activity. The bald eagle monitoring plan is well-designed, yet like the rest of the monitoring plan,
no objectives are stated a priority. The monitoring plan fails to state what will happen if the eagle
monitoring plan detects a decrease in bald eagle nesting activity. This is a major flaw.
Response 50:
The Tongass Land Management Plan is currently working on addressing NFMA population trends
monitoring in the revision. The intention of this monitoring plan was to monitor habitat conditions and
monitor implementation.
Comment 51 : (paraphrased)
The monitoring plan should include wildlife population or time-trend objectives, particularly for manage-
ment indicator species.
Response 51 :
The Tongass Land Management Plan is currently working on addressing NFMA population trends
monitoring in the revision. The intention of this monitoring plan was to monitor habitat conditions and
monitor implementation.
Comment 52: (paraphrased)
The monitoring plan should include the design of surveys to sample time-trends of indicator populations
that include monitoring before, during, and after project implementation.
Response 52:
The Tongass Land Management Plan is currently working on addressing NFMA population trends
monitoring in the revision. The intention of this monitoring plan was to monitor habitat conditions and
monitor implementation.
Comment 53: (paraphrased)
The monitoring plan should include the inclusion of mitigation measures that will be instituted should
population indices fall below specified levels.
Response 53:
The Tongass Land Management Plan is currently working on addressing NFMA population trends
monitoring in the revision. The intention of this monitoring plan was to monitor habitat conditions and
monitor implementation.
Comment 54: (paraphrased)
A map displaying places names in the project area should be put at the beginning of the maps section.
The lakes of the area, although referred to often in the DEIS text, are identified only on Fig. 3-7. It took
some time to discover this key. Also, South Saddle Lake on Fig. 3-7 is different from the S. Saddle Lake
on the USGS Ketchikan C-5 Quadrangle topographic map. This discrepancy should be rectified or
explained to avoid confusion. Leask Cove, although referred to several times in the DEIS, is never
identified on a map.
Response 54:
We agree.
Comment 55: (paraphrased)
Many of the harvest unit numbers on Figs. 2-1 through 2-5 and Alternative maps (Figs. A2-A6) are
extremely difficult or impossible to make out. These should be made more readable.
Response 55:
We agree.
Comment 56: (paraphrased)
Major Channel Types, Fig. 3-11, are illegible. Topographic views in Figs. 4-2, 4-6, and 4-17 are not
identified.
Response 56:
We agree. Identification of views were hidden by graphics. Plots have been labeled.
Comment 57: (paraphrased)
We are happy to see old-growth retention displayed on the same maps as proposed cutting units for
alternatives. This makes review of alternatives much easier. Also needed, however, are maps showing
the rest of operable forest land in the project area so that reviewers can see where future logging is likely
to occur and thus have a visual reference of cumulative impacts. Remaining operable forest land should
be displayed on the same map with old-growth retention and cutting units. Such maps would be more
readable if produced in color.
Response 57:
Thank you. Next time we will be sure to include a map displaying this. This type of map is available as
part or the administrative record and was shown at numerous public meetings.
Comment 58: (paraphrased)
Page 4-42, para. 4 should have a sentence added noting that the value of second-growth trees and
products is considerably less than the value of old-growth trees and products.
Response 58:
Over a 1 02 year rotation, it is felt that the value of second-growth trees and products, because of the
reduction in defect, will compete with old-growth products.
Comment 59: (paraphrased)
Page 4-42, para. 5. What is the basis for the statement that stands with volumes of 20-30 MBF/acre and
those of 30-50 MBF/acre have the same future growth potential. Are you asserting they have the same
site productivity index?
Response 59:
For this analysis, yes. As we track timber harvest by volume class we will, through time, be able to
assertain a distinct site productivity index for these classes. We feel these are conservative estimates.
Comment 60: (paraphrased)
Why does this DEIS in table 4-39 base growth/yield projections on current inventory volume rather than
site productivity? Site productivity is used in most other yield projections used by the USFS including
the TLMP Revision. Site productivity should be used here as well.
Response 60:
Volume class is a measure of site productivity.
Comment 61 : (paraphrased)
In tables 4-37 and 4-39, how are you determining acreage scheduled by volume class ~ through stand
exams or from timber type maps? Given the recognized difficulties with the accuracy of the current
timber inventory, project level plans should all rely only on data from stand exams.
Response 61 :
Stand exam data was used to determine volume by timber type.
Comment 62: (paraphrased)
In Vol. I, Chapter 3, page 13, the 7.6 miles of Forest Development Roads are more than the total of 3
miles of usable and 3.8 miles of usable roads.
Response 62:
This is a typographical error and has been corrected in the Final EIS.
Comment 63: (paraphrased)
In Vol. II, Chapter 2 all figures should be given numbers in this chapter, the DEIS shows 3 preferred sites
(1 , 5, and 7), but only 2 LTF site maps (1 and 5) are given. The profiles and site descriptions that follow
are somewhat confusing, as all proposed sites except 5, 6, and 7 have individual profiles. The statement
under site 5 that, 'Impacts must be evaluated to determine if it will be necessary to dispose of any eagle
trees,' is quite confusing and should be reworded. We agree that site 6 is biologically unsuitable for
continued log transfer (as explained in Vol. I), but think sites 5 and 7 should also be removed from the
list of preferred sites.
Response 63:
Maps in Vol. II, Chapter 2 will be assigned figure numbers in the FEIS.
Figure 2-6 'Area LT.F. Sites; George and Carroll Inlets’ was portrayed twice which will be corrected.
Seven LTF sites were considered as all seven could potentially serve the project area. Only those
proposed for use in the various alternatives were shown on individual site maps.
Simple plan and profile sketches were included with the preliminary reconnaissance reports. These
simplistic sketches were to show a very general preliminary idea concerning possible LT.F. configura-
tion.
January 27, 1991
USDA-FOREST SERVICE
R E C t i V E 0
Forest Supervisor
Ketchikan Area rrn Q4 iCJQ1
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Dear Forest Supervisor:
I appreciate the opportunity to comment on the DEIS prepared by
your staff for the Shelter Cove Project Area. Alternative 5 best
reflects the New Perspective direction currently being implemented
by the Forest Service with a few modifications. As reflected in
this alternative, I applaud your efforts to begin looking at all
the values of our national forest on an equal basis as dictated by
the Tongass Reform Act.
Alternative 5 comes closest to addressing wildlife protection
concerns and yet timber harvest levels are high enough to satisfy
economic returns. This plan provides for effective old-growth
retention blocks and ensures protection of unfragmented wildlife
corridor to adjacent areas. The alternative 5 approach begins to
address long standing environmental concerns about sustaining
wildlife populations and biodiversity issues lacking in past timber
harvest management. However, there are a few modifications to this
proposal that I feel are essential in protecting the fisheries
populations and ultimately the quality of recreation opportunities
and other economic values other than timber in the Upper George
Inlet Area. I would like to see the timber units on the
tributaries to all creeks feeding into the Salt Lagoon removed from
the timber harvest plan. There are about six units in question and
I am unable to read the VCU numbers. These units are located near
riparian areas of on Saltchuck Creek tributaries and some are on
steep slopes. Negative impacts on coho spawning and rearing
habitat poses a risk as soils may become unstable from clearcutting
and road building over these creeks. I feel the value of the
summer coho run known to local sportfish enthusiasts far exceeds
the timber value they represent. In addition, the sportfishing
charter business that uses the chuck during this run may be
adversely impacted and must be given more of a priority if multiple
use of this area is going to be realized. I concur with Mr. Lunn's
statement in his cover letter accompanying the Shelter Cove DEIS
that Alternative 5 "...would have less impact on Coho habitat
because it harvests the least amount in watersheds most important
to salmon." He also goes on to state that this alternative has
the least amount of negative impact on the area's viewsheds. I am
confused as to why Alternative 3 is considered the . recreational
alternative. Again referring to Mr. Lunn's cover letter, it
appears this distinction was made because it includes a possible
link up to the Ketchikan road system He goes on to cite a recent
borough community survey that supports roaded access to
recreational opportunities and a favorable response to recreating
in or adjacent to logged areas. First of all, of the nine
recreational values prioritized by this community, protection of
fisheries habitat for saltwater fishing was number one in
importance. The second and third priorities concerned protection
of wildlife habitat and fisheries habitat for freshwater
sportfishing. These are the very values emphasized in Alternative
5 and stated by Mr. Lunn in the preceding paragraph of his cover
letter. Roaded access to recreation came in fourth and a
willingness to recreate in or near a clearcut was low on the
priority list. Also a word of caution, in using this survey
question must be considered. Participants were not asked if given
the choice between recreating in a logged area or old growth stand,
which would they prefer. They were only asked how they felt about
recreating in or near a clearcut
The fifth alternative is the only one that does not have roads
entering the Lud II area designated in the Naha drainage. As I
understand the law, roads cannot be built in Lud II areas for the
express purpose of harvesting timber. It cannot be argued
convincingly at this time that these roads would also serve as a
potential transportation/utility road because ADOT/PF as not
concluded their study on the best road route through this area.
Alternative 5 best expresses the Tongass Reform Act intent on
disallowing high grading the higher volume class timber in the
Tongass National Forest.
Lastly, I am requesting your staff to include the cumulative
effects of logging for the entire southern portion on Revilla
Island. This has been extensively logged in the past on private
lands in this area.
In conclusion, I strongly urge your to adopt Alternative 5
management plan for the Shelter Cove area with a few modifications
I have outlined in my comments. It is the only choice other than
alternative 1 that protects the extremely important wildlife and
fisheries habitat and resources surrounding the George Inlet
Saltchuck. This protection includes several important processes
aimed at developing the New Perspective approach such as effective
old-growth blocks, protection of recreational wildlife and
fisheries resources and harvesting timber proportionate to volume
class to name a few examples. I support you in continuing this new
direction and addressing a true multiple use of our public lands.
^S^incerelv
Meg Cartwright ^
P.0. Box 9506
Ketchikan, Alaska 99901
Letter From Meg Cartwright, Ketchikan, AK
Comment 1 : (paraphrased)
I would like to see the timber units on the tributaries to all creeks feeding into the Salt Lagoon removed
from the timber harvest plan. These units are located near riparian areas on Saltchuck Creek tributaries
and some are on steep slopes.
Response 1 :
It is felt that the standards and guidelines and mitigation measures will protect these areas.
Comment 2: (paraphrased)
I am confused as to why Alternative 3 is considered the recreational alternative.
Response 2:
Alternative 3 would harvest the least amount of timber, thus retaining old-growth values for recreation
and wildlife. This alternative proposes the smallest average harvest unit size, 43 acres, thereby retaining
visual quality. The alternative also disperses the harvest units.
Comment 3: (paraphrased)
The fifth alternative is the only one that does not have roads entering the LUD II area designated in the
Naha drainage. As I understand the law, roads cannot be built in LUD II areas for the express purpose
of harvesting timber. It cannot be argued convincingly at this time that these roads would also serve as
a potential transportation/utility road because ADOT/PF has not concluded their study on the best road
route through this area.
Response 3:
The Shelter Cove DEIS proposes a timber sale project. An intra-island, road corridor will be addressed
in a separate environmental study in the future. Access through LUD II lands are provided for in the
Tongass Land Management Plan, amended 1985-86; USDA Forest Service, Alaska Region, Admin.
Dec., Number 147, pp. 9.
Quotations concerning such access is as follows:
"Roads will not be built except to serve authorized activities such as mining, power and water
developments, aquaculture developments, transportation needs determined by the State of Alaska,
and vital Forest Transportation system linkages.
Further qualifications are included in footnote 6 of the same:
«+ Vital Forest Transportation system linkages refer to necessary additions to the permanent road
network. Such linkages may be built through LUD II areas when either no other feasible land or water
routes exist to access adjacent LUD III or IV areas or when it can be demonstrated that the routing
through the LUD II area is clearly environmentally preferable and and site-specific mitigation mea-
sures can be designed to minimize the impact of the road on the surrounding LUD II area. A clear
need to build such linkages must be demonstrated through a comparative analysis of transportation
alternatives during the NEPA process and must be approved by the Forest Supervisor, in consulta-
tion with the other Tongass Forest Supervisors.
A detailed analysis investigating roading the LUD III lands adjacent to LUD II lands was conducted and
is in the administrative records at the Ketchikan Area Supervisor’s Office. In summary, it was found to
be environmentally preferable to road along and within the border of the Naha LUD II area.
Comment 4: (paraphrased)
Alternative 5 best expresses the Tongass Reform Act intent on disallowing high grading the higher
volume class timber in the Tongass National Forest.
Response 4:
The portion of the act you refer to pertains to the Long Term sale contract with KPC. Proportionality is
measured by management area. In the Shelter Cove project two management areas are included, these
are K35 and K39. All alternatives, except alternative 2 which is the timber economic alternative and an
objective of that alternative was to harvest high volume stands to improve economics, do not harvest
a disproportion in the higher volume classes. This analysis is displayed in the FEIS.
Comment 5: (paraphrased)
I am requesting your staff to include the cumulative effects of logging for the entire southern portion on
Revilla Island. This has been extensively logged in the past on private lands in this area.
Response 5:
This has been reflected in the FEIS.
•* terry-
(£)
Ketchikan Pulp Company
Post Office Box 6600
Ketchikan. Alaska 99901
907/225-2151
February 1, 1991
Mr. Steve Ambrose
Forest Supervisor
Ketchikan Area
Federal Building
Ketchikan, AK 99901
Dear Steve:
usr •.-COHE3" SrF.V CE
KETCHIKAN AfiEA.
h £ C ^ 1 ^ ^ ^
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jrl
Ketchikan Pulp Company (KPC) would like to comment on the
Shelter Cove Draft Environmental Impact Statement.
There are a number of specific issues KPC would like to
address .
A. KPC supports alternative 4 in the DEIS. This'X
alternative provides the most not only in terms of \
volume to harvest, but in recreational opportunities J
and access as well. Also with the decline in private /
timber harvest now beginning to accelerate, the volume (
made available under this alternative should be in \
great demand. Minor changes can be made to this \
alternative both to improve economics and to stay
outside the Cape Fox Corporation proposed selections.
B. Recreational opportunities are woefully undeveloped in
this DEIS. All the primitive (i.e. remote) types of
recreation can easily be practiced in the nearby 2.2
million acre Misty Fjords area. The Forest Service
should concentrate on developed recreation (i.e.
roaded) so that people in Ketchikan who have limited
time or resources can have improved recreational
opportunities. Those families with small children or
handicapped family members need places to access woods,
streams, lakes, etc. To leave most of the area in
primitive recreational status denies recreational
opportunities to a large segment of Ketchikan's
population .
The tone of the DEIS when comparing alternatives seems
to indicate that more logging means more damage. It
should be explained that mitigation measures are the
same in all cases.
I
53
i
4
C.
Mr. Steve Ambrose
February 1, 1991
Page 2
D. Visual concerns should not get the high priority they
presently receive in this DEIS. Visual concerns are
very subjective and are much less important in a area
of developed recreation.
E. KPC supports the concept of designing mainline roads in
this DEIS to be adaptable to the proposed tie road to
North Revilla and the mainland. It is this road more
than anything else which will allow recreation,
tourism, business and Ketchikan in general to grow.
F. Preserving huge blocks of old growth timber in order to
preserve species integrity is unnecessary when the
study area has so much timber that is not proposed for
harvest and is also adjacent to a 2.2 million acre
roadless area. Animal populations are not harmed by
the introduction of timber harvest, for example, Black
Tail deer populations normally increase. Examples of
this are Heceta and Prince of Wales Islands. Diversity
of species will increase when portions of an area are
managed for timber harvest.
G. Many of the mitigation methods talked about call for
selective harvest. This could easily create
unharvestable areas if great care isn't taken during
unit design. Ground conditions should dictate where
this is used and costly helicopter harvesting should
not be considered due to its' limited availability and
affordability. Please don't allow inexperi-enced
people to make decisions at this point in your EIS and
consequently, limit your options for timber harvest at
a later date when the site specific layout is occuring.
H. KPC has some concerns with the stream mitigation
measures. They are so complex that following them may
be impossible. Several of the mitigation measures are
so broadly written that they could easily be
interpreted to prohibit harvest altogether.
Some specific examples:
Page 32 #1-A — this could be interpreted to
mean all class 3 streams must have a 25 '
buffer. That amount of protection is
unwarranted.
I 0
Page 33 #4 — this calls for buffers on the
buffers. This is totally unnecessary when
the primary purpose is to create LOD in the
stream. More to the point, the mandated
Mr. Steve Ambrose
February 1, 1991
Page 2
buffers themselves should be managed
for wind firmness.
Page 33 #3-F — KPC feels this prescription is /
neither feasible or safe and may violate l
State OSHA regulations. ^
z
i .
Does the DEIS specify whether a logging camp will be
land or water? We support the option to use either
a means to attract more timber sale bidders.
J.
KPC ' s new sawmill at Ward Cove with a capacity of 60
MMBF/year has been left out of the DEIS review of {
existing industry. This is a permanent mill and should \
be included.
Ketchikan Pulp Company appreciates this opportunity to
comment and fully supports the effort to open up more of
Revilla Island.
Sincerely,
n.m.
R. M. Zresak
Planning Forester
:mk
cc :
M. R. Pihl
0 . J . Graham
R. D. Lewis
W. J. Begalka
■
Letter From R.M. Ziesak, Planning Forester, Ketchikan Pulp Company
Comment 1: (paraphrased)
KPC supports Alternative 4, but minor changes can be made to this alternative both to improve
economics and to stay outside the Cape Fox Corporation proposed selections.
Response 1:
Other resources may preclude economics to meet the objective of planning for multiple/use resource
management.
Comment 2: (paraphrased)
Recreational opportunities are woefully undeveloped in this DEIS.
Response 2:
The development of roaded recreation opportunities will be addressed under a separate NEPA docu-
ment, if and when the area is linked to Ketchikan. Until that time, only potential recreation opportunities
can be addressed.
Comment 3: (paraphrased)
The Forest Service should concentrate on developed recreation so that people in Ketchikan who have
limited time or resources can have improved recreational opportunities.
Response 3:
We agree. However, the Shelter Cove project is on an isolated road system and without a link to town
would be hard to justify the expense.
Comment 4: (paraphrased)
The tone of the DEIS when comparing alternatives seems to indicate that more logging means more
damage. It should be explained that mitigation measures are the same in all cases.
Response 4:
Mitigation measures are the same, but not impacts.
Comment 5: (paraphrased)
Visual concerns should not get the high priority they presently receive in this DEIS. Visual concerns are
very subjective and are much less important in an area of developed recreation.
Response 5:
The visual resource is of concern to the Forest Service and we have direction to manage this resource
according to the standards and guidelines outlined in the Tongass Land Management Plan.
Comment 6: (paraphrased)
Preserving huge blocks of old-growth timber in order to preserve species integrity is unnecessary when
the study area has so much timber that is not proposed for harvest and is also adjacent to a 2.2 million
acre roadless area.
Response 6:
The continguous landscape of Old-growth Retention, defined in Alternative 5 between the Naha LUD
II and George Inlet, and nearly to Carroll Inlet, was carefully designed to assure dispersal of wildlife from
the Naha LUD II to areas of intensive, traditional use of wildlife. The Naha is known to be a prime producer
of many wildlife species, but successful dispersal from the Naha is necessary to maintain hunting and
trapping opportunities elsewhere, as well as to recolonize habitats where the animals are lost. Without
excellent biological corridors, some wildlife populations within the Naha are more likely to grow until they
harm their food base there.
Comment 7: (paraphrased)
Animal populations are not harmed by the introduction of timber harvest. Black-tail deer populations
normally increase. Examples of this are Heceta and Prince of Wales Islands. Diversity of species will
increase when portions of an area are managed for timber harvest.
Response 7:
Deer habitat capability and deer populations in the project area will be affected by timber harvest.
Clearcuts 0-1 5 (Yeo 1 990) years old provide abundant forage and improve the opportunity for more deer
to enter the winter in good conditions, but lack of canopy cover to intercept snow, thereby, making
herbaceous forage unavailable during intermediate or deep-snow winters. In the long term.Trtimber
harvest converts old-growth stands into even-aged, closed canopy stands from 25 through 1 00 years.
The closed-canopy stand intercept sknow well and provides thermal cover, but eliminated preferred
browse species and therefore, reduces habitat capability for deer.
Diversity of species will increase with the increase of forest fragmentation. Research shows that forest
fragmentation results In an increased ratio of forest edge to forest interior and can have a strong
negative affect on forest-interior species. As more edge habitat becomes available as a result of
fragmentation, the edge-dwelling species invade the interior environment and become a major threat
to the survival of the forest interior dwelling species. By maintaining large contiguous blocks of habitat,
the forest interior dwelling species would realize less competition and predation from open-forest and
edge species.
Comment 8: (paraphrased)
Many of the mitigation methods talked about call for selective harvest, this could easily create unhar-
vestable areas if great care is not taken during unit design. Ground conditions should dictate where this
is used and costly helicopter harvesting should not be considered due to its limited availability and
affordability.
Response 8:
The selective harvest prescription will be determined on a site-specific unit implementation basis. Where
clearcutting is determined to be the optimum harvest method given the site-specific circumstances, it
will be applied.
Comment 9: (paraphrased)
KPC has some concerns with the stream mitigation measures, they are so complex that following them
may be impossible. Several of the mitigation measures are so broadly written that they could easily be
interpreted to prohibit harvest altogether.
Response 9:
The fisheries standards and guidelines are similar to those implemented in the KPC 1 989-94 Long-Term
Sale. These guidelines, though complex, have been successfully implemented in the 1989-94 Sale and
we feel confident that they may also be successfully followed in Shelter Cove.
Comment 10: (paraphrased)
Page 32, #1-A could be interpreted to mean all class 3 streams must have a 25’ buffer. That amount
of protection is unwarranted.
Response 10:
This applies to streams where stream stability is controlled by vegetation and not by bedrock. The
majority of Class II streams are bedrock contained streams, so this mitigation would not apply to these
streams.
Comment 1 1 : (paraphrased)
Page 33, #4 calls for buffers on the buffers. This is totally unnecessary when the primary purpose is to
create LOD in the stream. More to the point, the mandated buffers themselves should be managed for
windfirmness.
Response 1 1 :
We agree that one of the primary reasons for the 'buffers1 is maintenance of long-term sources of LOD.
Other reasons for buffers is protection of small 'unmapped' off channel habitat, protection of wildlife
habitat, bank stability. Those other purposes could be affected by windthrow within buffers. The
prescription will be applied site specifically.
Comment 12: (paraphrased)
Page 33 #3-F, KPC feels this prescription is neither feasible or safe and may violate State OSHA
regulations.
Response 12:
We agree and are exploring this issue with OSHA.
Comment 13: (paraphrased)
Does the DEIS specify whether a logging camp will be on land or water? We support the option to use
either as a means to attract more timber sale bidders.
Response 13:
The Shelter Cove DEIS does not preclude either land or water based camps, both were analyzed. See
Vol. I, Chapter 4, page 36 of the DEIS.
Comment 14: (paraphrased)
KPC’s new sawmill at Ward Cove with a capacity of 60 MMBF/year has been left out of the DEIS review
of existing industry. This is a permanent mill and should be included.
Response 14:
Thank you.
X
FOREST SUPERVISER
KETCHIKAN, AREA
TONGASS NATIONAL FOREST
JANUARY 31
FEDERAL BUILDING
KETCHIKAN, ALASKA 99901
, 19 9 1
USDA-FOREST SERVICE
R L 0 •- i V E D
FEB 04 1991
DEAR SIR:
I FEEL THAT ALTERNATIVE SIX IN THE SHELTER COVE DRAFT
ENVIRONMENTAL IMPACT STATEMENT TO BE THE MOST VIABLE
ALTERNATIVE OFFERED FOR SEVERAL REASONS:
1 . IT WILL PROVIDE INCREASED HABITAT ACREAGE FOR
WILDLIFE .
2. IT WILL PROVIDE FOR TIMBER RELATED JOBS WHICH IS
A DEFINITE PLUS TO THE REVENUE IN THE KETCHIKAN
AREA .
3. I ALSO BELIEVE THE ROAD ACCESS IS ESSENTIAL TO THE
RESIDENTS AND VISITORS OF KETCHIKAN. I SAY "ESSENTIAL"
2ND NOT "BENEFICIAL" BECAUSE I HAVE HAD THE ENVIABLE
OPPORTUNITY TO RESIDE ON THE WHITERIVER AREA FOR
MANY YEARS DURING WHICH TIME I SAW THE QUANTITY OF
OF PEOPLE WHO WOULD DO JUST ABOUT ANYTHING TO "HAVE
ANOTHER PLACE" TO SEE, FISH, HUNT, WALK, BIKE, RUN,
SKI, OR DRIVE IN SPITE OF ALL THE "PRIVATE PROPERTY"
SIGNS, "NO TRESSPASSING" SIGNS AND THE "NO_ HUNTING OR
FISHING" SIGNS. STILL, IN SPITE OF SIGNS AND A
WATCHMAN VERBALLY REINFORCING WHAT THEY HAVE ALREADY
READ MANY WERE WILLING TO ARGUE. THESE AFORE MENTIONED
INDIVIDUALS ARE ONLY A SMALL QUANTITY OF THOSE WHQ
WOULD RATHER DRIVE IF THE OPPORTUNITY WERE PRESENTED
TO THEM AS ATTESTED BY THE NUMBER OF VEHICLES THAT
COME DOWN THE ROAD WHEN THE GATE IS LEFT OPEN.
HAVING LIVED IN KETCHIKAN VIRTUALLY ALL MY LIFE I KNOW
THAT THIS TOWN-CITY HAS GROWN CONSIDERABLY IN THE PAST
DECADE AS FAR AS POPULATION AND BUSINESS OPPORTUNITIES
ARE CONCERNED BUT RECREAT I ON AL OPPORTUNITIES AND
ROAD ACCESS HAS NOT MATCHED THIS GROWTH. I WOULD HOPE
THAT ALL THESE THINGS WOULD BE CONSIDERED IN THE DECISION
f ,
MAKING ON THIS ISSUE.
2.
//JANICE UPDIKE
Letter From Janice Updike
Comment 1: (paraphrased)
We feel that Alternative 6 will provide increased habitat acreage for wildlife.
Response 1:
We feel that our analysis show that Alternative 5 provides this acreage the best.
Comment 2: (paraphrased)
We are concerned that recreation opportunities and road access has not matched the growth of the
population.
Response 2:
The roaded recreation opportunities for the residents and visitors of Ketchikan would increase if a road
link from Ketchikan to the Shelter Cove project is built. Such issues will be addressed in a separate NEPA
document.
DEPARTMENT OF FISH AND GAME
HABITAT DIVISION
i
/
/
j
j
j
i
/
WALTER f. HICKEL, GOVERNOR
2030 SEA LEVEL DRIVE
SUITE 205
KETCHIKAN, ALASKA 99901-6064
PHONE: (907) 225-2027
January 23, 1991
Mr. Steven T. Segovia
Ketchikan Ranger District
3031 Tongass Avenue
Ketchikan, Alaska 99901
Re: Shelter Cove DEIS
Dear Steve:
In our Shelter Cove DEIS comments of January 18, 1991, we
referenced a paper intended to accompany our response. This
paper, "Harvest Rates of Sitka Black-Tailed Deer Populations in
Southeast Alaska for Land-Use Planning" (enclosed) is the
result of a joint Forest Service/Alaska Department of Fish and
Game effort. It pertains to comment W-9c on page 3 of
Enclosure A and should have been an attachment to our Shelter
Cove DEIS comments, but was inadvertently omitted.
Briefly, this paper states that, "The results of the simulation
modelling and other factors described previously indicate a >
harvest rate of 10% should be used in land-use and population
management planning in southeast Alaska." Unfortunately, the
Shelter Cove DEIS derived the number of deer needed to meet
demand in 1990 by assuming an annual harvest rate of 30%. This
harvest rate is far too high and, consequently, the number of
deer needed to meet demand is too low. A sustainable annual
harvest rate for a deer population at habitat capability is
more realistically in the vicinity of 10%. 1
Based upon the enclosed ADF&G/USFS paper by Flynn and Suring,
we would like to request that computations for the numbers of
deer needed to meet demand in the years 1990, 2000, and 2060 be
computed using the 10% figure in the Final EIS for Shelter
Cove. Thank you for incorporating this into the- final version
of the EIS.
</$
1-K69LH
'A* A/
Mr. Steven T. Segovia
Sincerely,
Lck Gustafson
iArea Habitat Biologist
Attachment
cc : Frank Rue
Rick Reed
Dave Anderson
Lorraine Marshall
-2-
January 23, 1991
HARVEST RATES OF SITKA BLACK-TAILED DEER
POPULATIONS IN SOUTHEAST ALASKA FOR LAND-USE
PLANNING
Rodney W. Flynn. Alaska Department of Fish and Game. Division of Wildlife
Conservation, Douglas. AK 99824
Lowell H. Suring, Alaska Region, USDA Forest Service. Juneau. AK 99801
Land managers need to evaluate the impact of land-use activities on the
human harvests of Sitka black-tailed deer ( Odocoileus hemionus sitkensis ) in
southeast Alaska. Also, population managers need the ability to estimate the
number of deer required in a population to provide for human harvest
objectives. A habitat capability model for deer in southeast Alaska has been
developed to estimate the potential number of deer the habitat in a planning
area can support (Suring et al 1988). In addition, an understanding of
sustainable harvest rates of a deer population is needed to determine whether
a planning area with a given habitat capability can meet harvest objectives.
Because rates of increase or sustainable harvest rates for deer populations in
southeast Alaska are not known, the selection of an appropriate rate for use in
planning projects has been the topic of much discussion among management
agencies. In this paper, we provide a rationale for a sustainable harvest rate
for use in deer habitat and population management planning in southeast
Alaska. The rationale draws on the theory and data provided in McCullough
(1987) and our simulations of deer populations using a deterministic model
with available data from southeast Alaska.
Caughley (1977) and McCullough (1987) provide a theoretical basis for deer
population management. The theory assumes that deer recruitment is strongly
density dependent, and potential yield for hunters is highly dependent on
recruitment. Thus, high recruitment occurs at low population densities, and
recruitment rates decline as density increases because of intraspecific
competition for food. Likewise, hunter yield decreases as net recruitment
decreases.
McCullough (1987) provides information on net recruitment rates for white-
tailed deer depending on residual population size based on his research on the
George Reserve population. Although similar data did not exist for mule or
black- tailed deer, McCullough (1987) estimated net recruitment curves for
HARVEST RATES OF DEER
-2-
19 SEPTEMBER 1989
mule deer for comparative purposes using information reported in the
literature from the Rocky Mountain area (primarily Robinette et al 1977 and
Connolly 1981). Net recruitment rates, or rates of population increase, can be
used to estimate sustainable harvest rates. A population can be harvested at
the same rate as the rate the population would increase in the absence of
hunter harvesting (Caughley 1977).
Sustainable harvest rates are only part of the equation. The human population
must be able to harvest deer with a certain level of success in order to meet
harvest objectives. Generally, hunter success depends on population density
(McCullough 1987). The average deer taken from a low population requires
more effort compared with an average deer taken from a high population. As
population density decreases, a greater hunter effort is needed to maintain a
harvest objective. If hunter effort does not increase, the harvest will decrease
until the population increases again. Generally, the public prefers that deer
populations be maintained at high levels, so the time and effort required to
locate a deer is not excessive.
D. Anderson, M. Kirchhoff, T. Paul, and J. Schoen provided critical reviews and
contributed ideas to this paper.
TERMINOLOGY
The terminology of population biology can cause confusion. Caughley (1977)
provides a good discussion of appropriate terminology and symbols for
population increase; his terminology and symbols are used here. Caughley
(1977) describes several measures of population increase. These measures can
be expressed either in the finite (TO or the exponential (d form (X = e1*), and are
defined as follows;
1) Observed rate (71 ), the observed change in population numbers. The
observed rate is a general measure that may not be constant over time,
the age distribution may not be constant over the period, and resources
may not be superabundant;
2) Survival-fecundity rate (rs orT. s), the rate a population would increase
with given schedules of survival and fecundity held constant;
HARVEST RATES OF DEER
-3-
19 SEPTEMBER 1989
3) Intrinsic rate (rm orA.m). the rate achieved by a population with a
stable age distribution in the absence of crowding or resource shortage;
and
4) Potential rate (rp or^p), the rate a population would increase if a given
agent of mortality was removed (e.g. hunting or predation).
In order to understand McCullough (1987) and concepts presented here,
additional terms need clarification:
1) Residual population, the number of animals at the end of the
biological year (i.e. before the birth pulse);
2) Recruitment, the number (or percentage) of young of the year alive at
the beginning of the hunting season;
3) Net recruitment, the net increase in the size (or percentage increase) of
the residual population at the beginning of the next hunting season (in
contrast to young of the year);
4) Sustainable harvest (or yield), any level of harvest from a population
that could be maintained in perpetuity under a given set of
environmental conditions; and
5) Maximum sustainable harvest (or yield), the greatest sustainable
harvest from a population under a given set of environmental conditions.
MCCULLOUGH’S YIELD CURVES
McCullough (1987) provides a potential yield curve for white-tailed and mule
deer depending on residual population size. These curves can be used to
predict the response of deer populations to various exploitation rates. Also, the
curves can be used to estimate harvest rates that will sustain a given residual
population size. Although these curves provide a useful theoretical framework,
they provide a best case scenario because hunting is assumed to be the only
cause of traumatic mortality. Thus, the impacts of predation or severe winter
weather are not incorporated (McCullough 1979). Also, the reproductive rates
assumed for mule deer are much higher than those measured for black-tailed
deer from Vancouver Island (Thomas 1983) or southeast Alaska.(Johnson
1987). McCullough (1987) assumed that the pregnancy rate for fawn females
was 30% and yearling females were as productive as adults. He does not
HARVEST RATES OF DEER
-4-
19 SEPTEMBER 1989
provide the actual survival or productivity rates of adults. Johnson (1987)
found no fawns pregnant and only 67% of the yearling females pregnant.
An interpolation of McCullough's yield curve indicates that the maximum
sustainable yield for mule deer would be 27% of a residual population at 63%
of carrying capacity (K). A residual population at 90% of K would provide a
sustainable yield of 10%. If K = 100 deer, then a residual population at 63% K
would yield a maximum sustained harvest of 17 deer, and a population at 90%
K would provide a sustained yield of 9 deer.
POPULATION SIMULATIONS
In order to explore possible rates of increase for Sitka black-tailed deer in
southeast Alaska, we simulated the growth of a hypothetical deer population
using 4 different assumptions for age-specific mortality. Each of these
simulations provided a value for rs, expressed as the finite rate X s. The
deterministic population model POP-II (Fossil Creek Software, Fort Collins, CO)
running on a microcomputer was used for the simulations. This model allows
the user to specify age-specific mortality rates for the summer and winter
seasons, initial population sex and age composition, and birth rate. The
specified birth rate must be applied to all age classes of females considered
adults. Simulations were run for 25 years with a given set of parameters,
sufficient time to generate a stable age distribution. The model outputs the sex
and age composition of the population at 4 time steps during the biological
year - after the birth pulse, prehunt, posthunt, and post winter.
Assumptions for all simulations
A birth rate of 150 fawns: 100 adult does was used for each simulation.
Females 2 years of age and older were considered adults. Because the model
does not allow for age-specific birth rates, the same rate was used for all age
classes of does considered to be reproductively mature. The birth rate used
was based on fertility information gathered from 54 female deer collected
during February 1985 in Hoonah Sound, Chichagof Island (Johnson 1987).
This study found 2 of the 3 yearling does in the sample pregnant; none of 7
fawns in the sample were pregnant. The 46 mature does contained 7 1 fetuses
(155 fetuses: 100 does). Because of fetal mortality, fetal counts provide an
estimate of maximum birth rate. The actual live-birth rate would be lower.
Thomas (1983) found a fetal mortality rate of 3.3% in Columbian black-tailed
deer ( Odocoileus hemionus columbianus) on Vancouver Island. For these
simulations, we assumed a fetal fawn mortality rate of 3.5%, leaving a live-birth
rate of 150 fawns: 100 adult does. Because deer fertility was found to be age
HARVEST RATES OF DEER
-5-
19 SEPTEMBER 1989
specific (Johnson 1987), the actual birth rate of a population will depend on
the age-structure of the population. Also, fertility will probably decrease as a
deer population approaches carrying capacity (McCullough 1987).
The sex composition of the initial adult population and the sex ratio at birth
was assumed to be 50:50. Maximum longevity was set at 15 years, so all
adults die after their 1 5^ year.
Simulation I - No Fawn Or Adult Mortality
The finite rate of increase of the population under this scenario was 1.5. The
fall population was composed of 100 fawns: 100 does. This growth rate would
never occur in the wild because many of the fawns and some adults would die
during the year. This scenario establishes the maximum potential growth rate
Simulation EE - High Fawn Recruitment and High Adult Survival
For this scenario, the fawn mortality rates were set at 40% for summer and
10% for winter. The adult mortality rate was set at 6% for all age classes. This
scenario yielded a finite rate of increase of 1 .24. This rate of increase would
seldom occur because the fawn recruitment rate is high and the adult mortality
rate is low. This scenario generates an early fall deer population composed of
69 fawns: 100 does. Although little information exists on deer sex and age
composition, Johnson (1984) conducted 3 late-summer deer composition
counts between 1978 and 1983. He recorded an average of 16% fawns, or an
early fall population composed of 38 fawns: 100 does (assuming a 50:50 adult
sex ratio). Johnson (1984) never recorded fall fawn counts above 50 fawns: 100
does. The rate of increase observed in this scenario probably represents the
intrinsic rate of increase for Sitka black-tailed in southeast Alaska during mild
winters; or the rate of increase that would be observed in the absence of
crowding or resource shortage (i.e. density-dependent factors).
Simulation HI - Moderately High Fawn Recruitment and High Adult
Survival
For this scenario, the fawn mortality rates were set at 55% for summer and
10% for winter. The adult mortality rate was set at 6% for all age classes. This
scenario yielded a finite rate of increase of 1.17, and a early fall population
composed of 54 fawns: 100 does. The fawn recruitment assumed in this
HARVEST RATES OF DEER
-6-
19 SEPTEMBER 1989
scenario is substantially greater than the 3-year average observed by Johnson
(1984).
Simulation IV - Moderate Fawn Recruitment and High Adult Survival
For this scenario, the fawn mortality rates were set at 80% for summer and
10% for winter. The adult mortality rate was set at 6% for all age classes. This
simulation yielded a finite rate of increase of 1.09. The scenario generated an
early fall population composed of 38 fawns: 100 does. This level of recruitment
is near the 3-year average observed by Johnson (1984). This scenario probably
reflects the dynamics of a deer population near carrying capacity in the
northern portions of southeast Alaska during a year with moderate winter
weather.
Simulation V - Moderate Fawn Recruitment, Low Fawn Winter Survival
and Moderate Adult Survival
For this scenario, the fawn mortality rates were set at 75% for summer and
50% for winter. The adult mortality rate was set at 12% for all age classes,
double the previous scenarios. This scenario yielded a finite rate of increase of
0.91, or a population decreasing at the rate of 9%. This scenario probably
reflects the dynamics of a deer population near carrying capacity in the
northern portions of southeast Alaska during a year with moderately severe
winter weather. The early fall population was composed of 34 fawns: 100 does,
about the same composition as Simulation IV, and near the 3-year average
observed by Johnson (1984). The over- win ter survival rate for fawns and
adults would be expected under moderately severe winter conditions.
DISCUSSION
The computer simulations produced results that were relatively consistent with
the hypothetical yield curves of McCullough (1987). The computer simulations
indicated that finite rates of increase for deer in southeast Alaska ranged from
0.91 to 1.24. Growth rates above 1.2 would occur only when fawn recruitment
and adult survival are high (i.e. population numbers substantially below K and
mild winter conditions). In high density populations near K with an older age
structure, the finite rate of increase would be about 1.09, and perhaps lower.
Moderately severe winters would cause deer populations to decrease at the rate
of 10% or more.
HARVEST RATES OF DEER
-7-
19 SEPTEMBER 1989
McCullough (1987) predicted that a residual mule deer population at 90% of K
would provide a sustainable harvest of about 10% and a residual population at
63% of K would produce a maximum sustained yield harvest rate of 27%.
Because of lower productivity, the maximum sustained yield for Sitka black-
tailed deer in southeast Alaska is probably less. The computer simulations
indicated that for Sitka black-tailed deer a residual population near K would
provide a sustainable harvest of about 9% and a residual population
substantially below K might provide a sustainable harvest from 17-24%.
As populations approach carrying capacity, the finite growth rate will approach
zero as density-dependent factors reduce productivity and survival. The deer
habitat capabilities estimated by the habitat capability model developed for
deer habitat and population planning in southeast Alaska (Suring et al 1988)
assumed the residual population to be about 90% of K. Thus, the habitat
capabilities estimated by the model allows for a hunter yield from the
population.
Because of other factors not included in the population simulations (e.g.
crippling loss, predation, severe winter weather), a 10% harvest level is not
overly conservative for use in long-term planning. Predation by wolves and
bears may greatly reduce hunter yields. In portions of southeast Alaska
occupied by wolves, the harvest rate or habitat capabilities should be reduced.
The current model reduces habitat capability in areas with wolves (Suring et al
1988). Because of crippling loss (deer wounded but not retrieved), all deer
killed by hunters do not contribute to hunter harvest objectives. Connolly
(1981) found reports of crippling loss in the literature to range from 8 to 92% of
the reported hunter kill; the average of 13 studies was 38%. Thus, the actual
hunter kill may be about 38% greater than the harvest realized by hunters.
Currently, crippling loss is not directly incorporated into any model.
The size and potential yield of deer populations is southeast Alaska fluctuate
yearly because of variation in winter severity. Typically, southeast Alaska
receives abundant snowfall. Deep snow winters occur periodically, depending
on location. Severe winter weather can cause large increases in natural
mortality, reducing residual population size and rate of increase. During years
with deep snow winters, the population growth rate would be less than 1.0
because of low fawn survival and high adult mortality. Thus, the same amount
of hunter harvest during the following year would reduce the size of the
residual population. Also, the management objective may be actual population
growth for several years to restock ranges after severe winters. --
Hunter success is likely to drop as deer density decreases. The public wants
deer populations to be maintained at high levels near carrying capacity, so
HARVEST RATES OF DEER
-8-
19 SEPTEMBER 1989
hunter success rates are high and deer are observed frequently. High hunter
success rates are especially important for subsistence hunters because they
are hunting to provide food for their families.
The results of the simulation modelling and other factors described previously
indicate that a harvest rate of 10% should be used in land-use and population
management planning in southeast Alaska. This harvest rate is appropriate to
use in conjunction with habitat capability estimates available from models
developed for use in southeast Alaska. It is important to realize that the yield
may be higher for some years and situations; for some years and situations the
yield will be lower than 10%.
REFERENCES
Caughley, G. 1977. Analysis of vertebrate populations. John Wiley & Sons.
New York. 234pp.
Connolly, G. 1981. Assessing populations. Pages 287-345 in C. Wallmo , ed.
Mule and black-tailed deer of North America. Univ. Nebraska Press,
Lincoln.
Johnson, L. 1984. Unit 4 deer survey-inventory progress report. Pages 13-17
in A. Seward, ed. Annual report of survey- inventory activities. Part VI.
Deer. Vol. XV. Alaska Dep. Fish and Game. Fed. Aid. in Wildl. Rest.
Prog. Proj. W-22-3. Job. 2.0 Juneau. 23pp.
. 1987. Reproductive potential of Sitka black- tailed deer in southeast
Alaska. Alaska Dep. Fish and Game. Fed. Aid in Wildl. Rest. Final
Report. Proj. W-22-4. Job 2.8R. Juneau. 29pp.
McCullough, D. 1979. The George Reserve Deer Herd. Univ. Michigan Press.
Ann Arbor. 271pp.
. 1987. The theory and management of Odocoileus populations. Pages
535-549 in C. Wemmer, ed. Biology and management of the Cervidae.
Smithsonian Inst. Press, Washington.
Robinette, W., N. Hancock, and D. Jones. 1977. The Oak Creek mule deer
herd in Utah. Resource Publication 77-15. Utah Div. of Wildlife, Salt
Lake City, Utah.
HARVEST RATES OF DEER
-9-
19 SEPTEMBER 1989
Suring, L., G. DeGayner, R. Flynn, M. Kirchhoff, J. Martin, J. Schoen, and L.
Shea. 1988. Habitat capability model for black-tailed deer in southeast
Alaska: winter habitat. USDA Forest Service, unpublished. 25pp.
Thomas. D. 1983. Age-specific fertility of female Columbian black-tailed deer.
J. Wildl. Manage. 47(2):501-506.
Letter Form Jack Gustafson Area Habitat Biologist ADF&G
Comment 1: (paraphrased)
The Shelter Cove DEIS derived the number of deer needed to meet Demand in 1 990 by assuming an
annual harvest rate of 30 percent. This harvest rate is far too high and, consequently, the number of deer
needed to meet demand is too low. A sustainable annual harvest rate for deer populations at habitat
capability is more realistically in the vicinity of 10 percent. Based upon ADF&S/USFS studies, we would
like to request that computations for the numbers of deer needed to meet demand in the years 1 990,
2000, and 2060 be computed using the 10 percent figure in the Final EIS for Shelter Cove.
Response 1 :
Your concerns are reflected in the FEIS.
State of Alaska
Alaska Energy Authority
A Public Corporation
February 6, 1991
Mr. J. Michael Lunn, Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Subject: Shelter Cove DEIS
Dear Mr. Lunn:
The Alaska Energy Authority has reviewed the Shelter Cove DEIS and
offers the following comments.
Our concerns with respect to the Shelter Cove management unit relate to
operation and maintenance of the Swan Lake hydroelectric project
transmission line.
Our interests and the interests of the Ketchikan area rate payers might
best be served by adopting the forest management alternative that could |
provide road access along the transmission line and, eventually, be
linked with the existing Ketchikan road system. From this perspective -
alone, Alternative 4 would best accomplish this. The next best option,
again solely from the perspective of transmission line operation and
maintenance, would be Alternative 3.
Once an alternative is adopted and actual Itarvests are anticipated, we"~]
would appreciate the opportunity to work with you on detailed road 1 “Z
layout in anticipation of improving access for maintenance of thej
transmission line.
Thank you for the opportunities to comment and please do not hesitate to
contact me if you have any questions.
Sincerely,
Brent N. Petrie
Director of Agency Operations
TA:BNP: jd
cc: Stanley E. Sieczkowski, Alaska Energy Authority
Jim Lang, Alaska Energy Authority
Tom Stevenson, Ketchikan Public Utilities
Z PO. Box AM Juneau. Alaska 99811 (907)465-3575
X PO. Box 190869 701 East Tudor Road Anchorage. Alaska 99519-0869 (907)561-7877
oiUnnofifiM i
-/l/
Letter from Alaska Energy Authority
Comment 1 : (paraphrased)
Our interests might best be served by adopting the forest management alternative that could provide
road access along the transmission line and, eventually, be linked with the existing Ketchikan road
system. Alternative 4 would best accomplish this. The next best option would be Alternative 3.
Response 1:
See Response 2.
Comment 2: (paraphrased)
Once an alternative is adopted and actual harvest are anticipated, we would appreciate the opportunity
to work with you on detailed road layout in anticipation of improving access for maintenance of the
transmission line.
Response 2:
Close coordination of power line maintenance and access during our road layout, design, and construc-
tion phase would be most welcome.
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
EPA
REPLY TO
ATTN OF: WD-136
Alaska
Idaho
Oregon
Washington
FEB 1 3 1391
Steven T. Segovia
Ketchikan District Ranger
USDA - Forest Service
Tongass National Forest
3031 Tongass
Ketchikan, Alaska 99901
Dear Mr. Segovia:
In accordance with our responsibilities under the National Environmental Policy
Act (NEPA) and § 309 of the Clean Air Act, the Environmental Protection Agency we
has reviewed the Shelter Cove Draft Environmental Impact Statement (draft EIS). This
draft EIS evaluates alternatives to provide six timber harvest alternatives in the Shelter
Cove area on the southern end of Revillagigedo Island north of Ketchikan in the
Tongass National Forest. The alternatives range from 26.3 to 95.6 million board feet
and cover 60,383 acres.
Based on our review, we have rated the draft EIS EC-2 (Environmental
Concerns - Insufficient Information). Our main concern is the effect of the action
alternatives on water quality and fisheries. Additional information is needed on
standards and guidelines, monitoring, mitigation, log transfer facilities, and air quality.
Our detailed comments are enclosed.
Thank you for the opportunity to review this draft EIS. We regret the delays in
making our comments available. Please contact Wayne Elson at (206) 553-1463 if you
have any questions about our comments.
Enclosure
cc: Drew Grant, ADEC
ADFG
NMFS
Sincerely,
Ronald A. Lee, Chief
E ranch
BAN&aOOTBCl
KBvn
FEB 1 9 ’91
RANGER
8.8.S.
TM/FIRE/SILV
REC/ LANDS
F18H/WLDF
FAC/MTCE
ENG
-
DETAILED EPA COMMENTS ON THE SHELTER COVE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
Standards and Guidelines
Many of the Soil and Watershed, Wildlife, and Aquatic Habitat Management
Units Timber Harvest Mitigation Measures have as an objective to ,,maintain,,
environmental quality. In instances where environmental conditions are already
degraded this objective would be unacceptable. These objectives should be reworded
to read "maintain or improve when degraded." ^
Monitoring
The monitoring plan is presented in Table 2-36. An introduction should be
added that describes the feedback mechanism which uses the monitoring results to
adjust standards and guidelines, best management practices, standard operating
procedures, intensity of monitoring, and timber sale administration when adverse
effects are first detected. Providing such a process for adjustment will ensure that /
mitigation will improve in the future and that unforeseen adverse effects are recognized
and minimized.
Z
The monitoring plan cites one of the items to be measured as "effectiveness of
standards and guidelines" for aquatic habitat management. There are fifteen
objectives listed in the standards and guidelines for aquatic habitat management. The
Objective column (first of three) in Table 2-28, however, includes goals that are too
general to describe levels of environmental quality that could be definitively measured,
especially for a site specific project. One of the "Items to be Measured" under the first
objective for aquatic habitat management, for example, is "Maintain streambank
stability and lateral scouring (page 2-32)." What parameter will be measured to
determine if this level of environmental quality has been achieved? As an objective it is
acceptable, but it is not a meaningful "Items to be Measured." This question applies to
all "Items to be Measured" in Table 2-36 which reference the standards and guidelines
including fish habitat. If the standards and guidelines are to provide a meaningful ~\
reference in the monitoring plan, they need to be more specific. ^
Another concern is that the fifteen "Items to be Measured" implied for fish
habitat could represent a rather ambitious effort even if only 5-15% of the units are
evaluated. The costs for each item in the monitoring plan needs to estimated and
disclosed to insure that priority areas are covered and the plan is feasible.
4
Page 2-47 cites a "Unit Monitoring Report" as to how the "Effectiveness of
standards and guidelines" will be measured. No further explanation is offered in the
draft EIS. This needs to be explained in much more detail in order for the reviewer to
determine the adequacy of the monitoring plan.
r
2
Mitigation
A comprehensive discussion of proposed mitigation for direct, indirect and
cumulative impacts is required by the Council on Environmental Quality (CEQ)
Regulations for Implementing the Procedural Provisions of NEPA. The CEQ
regulations indicate that an EIS should include the means to mitigate adverse
environmental effects (40 CFR 1508.7) as well as disclose the effectiveness of the
mitigation measures to minimize adverse effects.
Site specific details on the effectiveness of mitigation is appropriate for a site] C
specific timber sale. The EIS should provide a quantitative (if possible) or qualitative^)
description of mitigation effectiveness. Prior timber sales in the Tongass National
Forest could be used as a basis for these discussions.
Log Transfer Facilities
Several of the alternatives include construction of new log transfer facilities. We 1
recommend that existing log transfer facilities be used where possible.
Two publications are referenced to satisfy disclosure of effects from site bark ' ) r>
deposition on page 4-34. A summary of bark deposition effects needs to be include in i 0
the final EIS. ^
Prescribed burning is mentioned on page 3-18. It is unclear to what extent it i °[
proposed. Additional information regarding the location and frequency of prescribed
burning activities and the potential downwind air quality effects is needed. Particulate
concentrations have been measured that exceed health standards up to three miles
downwind of a prescribed burn. Any residences, recreational areas, or areas of
expected human activity that could be affected by this activity should be presented 'in
the draft EIS.
A description of prescribed burning activity would provide useful information.
Will slash be machine piled and burned? Will broadcast burning be conducted in the
spring or fall? What are the likely effects to soils and large woody debris if units are
burned during the fall? How many acres are planned to be burned?
The EIS should also complete an analysis of the effect of slash burning on air
quality. The EIS should describe the meteorological conditions and existing air quality,
using data applicable to the project site and appropriate for use in dispersion
modeling. The air quality analysis should identify all activities and sources, from direct
and indirect activities, that could emit air contaminants. Once emissions from the
proposed action have been quantified, screening level dispersion modeling must be
performed to determine whether there will be any adverse air quality effects. If the
screening level analyses indicate that potential exceedences could exist, then
reductions in particulates from burning activities or more sophisticated modeling may
Air Quality
3
be necessary. The air quality analysis must demonstrate that the proposed action will
not cause or contribute to any violations of the National Ambient Air Quality Standards,
that it will not cause the air quality to degrade by more than any applicable Class II
Prevention of Significant Deterioration (PSD) increments, and it will not cause or
contribute to visibility impairment.
Questions regarding the emissions inventory or regulatory requirements may be
directed to Dave Bray in EPA's Air Programs Development Program at (206) 553-4253.
Rob Wilson of our Air Monitoring and Analysis Section can be contacted
(206) 553-1531 regarding specific meteorology and dispersion modeling
considerations.
SUMMARY OF THE EPA RATING SYSTEM
FOR DRAFT ENVIRONMENTAL IMPACT STATEMENTS:
DEFINITIONS AND FOLLOW-UP ACTION *
Environmental Impact of the Action
L0--Lack of Objections
The 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 accomplished with no more than minor
changes to the proposal .
EC--Envi ronmental Concerns
The EPA review has identified envi ronmental 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 the
environmental impcCt. EPA -'ntends to work with the lead agency to reduce these impacts.
EO — Environmental Objections
The E^A 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--Envi ronmental 1 y Unsatisfactory
The EPA review has identified adverse environmental impacts that are of sufficient
magnitude that they are unsatisfactory from the standpoint of public health or welfare
on environmental quality. EPA intends to work with the lead agency to reduce these
impacts. If the potential unsatisfactory impacts are not corrected at the final EIS
stage, this proposal will be recommended for referral to the CEQ.
Adequacy of the Impact Statement
Category I--Adequate
E°A believes the draft EIS adequately sets forth the environmental 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
envi ronmental impacts that should be avoided in order to fully protect the environment,
or the EPA reviewer has identifieo 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
environmental impacts. EPA believes 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 NEPA 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 a"d Procedures for the Review of Federal Actions Impacting
the Environment
February, 1987
Letter from United States Environmental Protection Agency
Comment 1: (paraphrased)
Many of the mitigation measures have as an objective to ■maintain' environmental quality. In instances
where environmental conditions are already degraded this objective would be unacceptable. These
objectives should be reworded to read, 'maintain or improve when degraded.'
Response 2:
With the case of the Shelter Cove project area, this is the first entry and there are no known instances
where environmental conditions have been degraded due to past activity.
Comment 2: (paraphrased)
The monitoring plan is presented in Table 2-36. An introduction should be added that describes the
feedback mechanism which uses the monitoring results to adjust standards and guidelines, best
management practices, standard operating procedures, intensity of monitoring, and timber sale admin-
istration when adverse effects are first detected. Such a process for adjustment will ensure that
mitigation will improve in the future and that unforeseen adverse effects are recognized and minimized.
Response 2:
We agree. All monitoring is collected and analyzed for need of change. The Ketchikan Area is presently
evaluating additions to its unit harvest and road card system which will strengthen the existing feed
back' system.
Comment 3: (paraphrased)
The monitoring plan cites one of the items to be measured as 'effectiveness of standards and guidelines'
for aquatic habitat management. If the standards and guidelines are to provide a meaningful reference
in the monitoring plan, they need to be more specific.
Response 3:
We agree. The Monitoring Plan has been rewritten FEIS, Chapter 2, pg. 47) to explain the items to be
measured in determining the effectiveness of the fish habitat standards and guidelines.
Comment 4: (paraphrased)
The costs for each item in the monitoring plan needs to be estimated and disclosed to insure that priority
areas are covered and the plan is feasible.
Response 4:
We agree and the Ketchikan Area is striving to meet this need through the budgeting process.
Comment 5: (paraphrased)
Page 2-47 cites a 'Unit Monitoring Report'. No further explanation is offered in the DEIS. This needs to
be explained in more detail.
Response 5:
The fisheries monitoring plan has been rewritten to better explain the monitoring planned to determine
the implementation effectiveness of the fisheries mitigation standards and guidelines. The monitoring
report forms have also been included in the appendix.
Comment 6: (paraphrased)
Site specific details on the effectiveness of mitigation is appropriate for a site specific timber sale. The
EIS should provide a quantitative (if possible) or qualitative description of mitigation effectiveness.
Response 6:
We have picked mitigation measures that have worked in the past. Through monitoring, we are able to
update the measures to ensure they continue to achieve the desired results in the future.
Comment 7: (paraphrased)
Several of the alternatives include construction of new log transfer facilities. We recommend that existing
log transfer facilities be used where possible.
Response 7:
All existing LTFs are privately owned and require joint use agreements. If equitable agreements cannot
be made, a new LTF is required. Two of the existing sites are short-term use sites and may not be
permitted for extended use. The White River LTF does not serve the Shelter Cove area.
Comment 8: (paraphrased)
Two publications are referenced to satisfy disclosure of effects from site bark deposition on page 4-34.
A summary of bark deposition effects needs to be included in the final EIS.
Response 8:
This was a printing defect. The effects will be included in the Final EIS.
Comment 9: (paraphrased)
Prescribed burning is mentioned on page 3-18. It is unclear to what extent it is proposed.
Response 9:
No prescribed burning is planned on the project area
WALTER J. HICK EL, GOVERNOR
(ZOJ
\
\
DEPARTMENT OF NATURAL RESOURCES
DIVISION OF PARKS AND OUTDOOR RECREATION
3601 C STREET
ANCHORAGE, ALASKA 99503
PHONE: (907) 561-2020
MAILING ADDRESS:
PO. Box 107001
ANCHORAGE, ALASKA 99510-7001
January 22, 1991
File No. : 3130-1R USFS
Subject: Shelter Cove DEIS
AK901218-05J
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Sir:
The proposed action appears to be consistent with Ketchikan Gateway Borough
Coastal Management Program standards for the protection and management of
significant archaeological and historic cultural resources.
We appreciate your consideration of cultural resources and look forward to
Section 106 consultation during project implementation.
Sincerely,
<XXCv
Judith E. Bittner
State Historic Preservation Officer
JEB : TAS : dw
cc: Lorraine Marshall, DGC, Juneau
Letter From State of Alaska Department of Natural Resources
Division of Parks and Outdoor Recreation
Response:
Thank you.
KETCHIKAN
VISITORS BUREAU
USD * — P OREST SERVICE
KETCHIKAN AREA
RECEIVED
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1, 1991
Mr. Steven Ambrose
Acting Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
In re: Shelter Cove Draft Environmental Impact Statement (DEIS)
Dear Mr. Ambrose:
After carefully reviewing the DEIS, I feel that Alternative 3 best reflects
the incorporation of Ketchikan's needs and interests related to recreational
and economical impacts on tourism. The New Perspectives approach of the
DEIS is to be commended for its aim toward balancing timber production
and environmental preservation.
Please be aware that this comment does not reflect a KVB Board
recommendation as the DEIS was not presented to the Board due to time
constraints. It will be on the agenda of our next Board meeting on
February 19, 1991. Further comments coming out of that meeting will be
forwarded to you.
Sincerely,
Ketchikan Visitors Bureau
LLLlZ^± A
Susan Wilcox
Executive Director
Phone (907) 225-6166
131 Front Street. Ketchikan. Alaska 99901
Letter From Ketchikan Visitors Bureau
Response:
Thank you.
February 1, 1991
Mr. Steve Ambrose
Forest Supervisor
Ketchikan Area
Federal Building
Ketchikan, AK 99901
Dear Steve:
The following are my comments on the Shelter Cove DEIS.
A. I support alternative 4 in the DEIS. This alternative
provides the most not only in terms of volume to harvest, but
in recreational opportunities and access as well. With all
the mandated land set asides on the Tongass, I feel it is
important to aggressively manage the timber lands that are
left. Minor changes can be made to enhance the economics and
to stay outside the Cape Fox Corporation proposed selections.
B. Recreational opportunities are woefully undeveloped in this'
DEIS. All the primitive (i.e. remote) types of recreation can
already be practiced in areas like Naha and Misty Fjords.
There is no need to create further opportunities like these.'
Instead the Forest Service should concentrate on developed
recreation (i.e. roaded) so that all people can have equal
access. Not all of us have the time or money to fly in to a
primitive area. We need areas that have recreational
opportunities available on a drive to basis as this area will
be when the tie road is connected. Those families with small
children or handicapped family members also need places to
access woods, streams, lakes, etc. To leave most of the area
in primitive recreational status denies those same
recreational opportunities to a large segment of Ketchikan's
population. This is a problem on Revilla Island the Forest
Service has long recognized and should take this opportunity
to finally address.
C. Visual concerns should not get the high priority they
presently receive in this DEIS. Carrying visual concerns to
the extreme can destroy the economics of a timber sale, merely
to preserve a view that arguably is repeated many times over
on the road system.
D. I strongly support the concept of designing mainline roads in
this DEIS to be adaptable to the proposed tie road to North
Revilla and the mainland. It is this road more than anything
else which will allow recreation, tourism, business and
Ketchikan in general to grow.
E . Preserving huge blocks of old growth timber in order to
preserve species integrity is unnecessary when the study area
has so much timber that is not proposed for harvest. Animal
populations are not harmed by the introduction of timber
harvest, in fact. Black Tail deer populations ususally"~)
increase. Biodiversity is important to keep species healthy ( ~1
and adaptable. To trap them in pockets of old growth is to ^
try micromanaging a species to the point of creating
subspecies that will be impossible to protect from the real
world .
It is important to point out that the intent of this document
(such as total harvest volume for example) should be followed
when laying out harvest units and not strictly adhereing to
drawings or a map as the final say in unit location or
configuration. The EIS says where a unit should go, but let
ground conditions reflect how a unit should actually look.
%
Many of the mitigation methods talked about call for selective
harvest. This could easily create unharvestable areas if
great care isn't taken during unit design. Ground conditions
should dictate where this is used and costly helicopter
harvesting should not be the only option considered due to
its' limited availability and affordability.
H. I also have concerns with the stream mitigation measures.
They are so complex and unweildly that following them may be
impossible. Several of the mitigation measures are so broadly
written that they could easily be interpreted to prohibit
harvest altogether. They need to be condensed into a clear,
concise prescription that can be followed when unit layout is
being done so that excess acres are not deleted from harvest
because of conflicting guidelines.
1 0
Some examples :
Page 32 #1-A — this could be interpreted to mean all
streams must have a 25' buffer. That amount of
protection is unwarranted.
Page 33 #4 — this calls for buffers on the buffers.
Totally unnecessary when the primary purpose is to
create LOD in the stream. More to the point, the
mandated buffers themselves should be managed for
wind firmness.
I applaud this effort by the Forest Service to make more timber
available to the growing timber industry here in southern Southeast
Alaska. I appreciate this opportunity to comment and fully support
the effort to open up more of Revilla Island.
Sincerely, t
R. M. Ziesax
15033 N. Tongass
Ketchikan, AK 99901
Letter From R.M. Ziesak
Comment 1: (paraphrased)
I support alternative 4. This alternative provides the most timber volume and recreational opportunities.
I feel it is important to aggressively manage the timber lands that are set aside for other resources. Minor
changes can be made to Alternative 4 to enhance the economics and stay outside the Cape Fox
selections.
Response 1:
Other resources may preclude economics to meet the objective of planning for multiple/use resource
management.
Comment 2: (paraphrased)
Recreation opportunities are woefully undeveloped in this DEIS.
Response 2:
The development of roaded recreation opportunities will be addressed under a separate NEPA docu-
ment, if and when the area is linked to Ketchikan. Until that time, only potential recreation opportunities
can be addressed.
Comment 3: (paraphrased)
The Forest Service should concentrate on developed recreation (i.e. roaded) so that all people can have
equal access.
Response 3:
We agree. However, the project area will be on an isolated road system. Developed recreation impossi-
ble under this document in that a road link to town is outside the scope. Should the project area be linked
to town, developed recreation would be one issue addressed as part of that process.
Comment 4: (paraphrased)
Visual concerns should not get the high priority they receive in this DEIS.
Response 4:
The management of the visual resource is if high importance to the Forest Service.
Comment 5: (paraphrased)
I strongly support the concept of designing mainline roads in this DEIS to be adaptable to the proposed
tie road to North Revilla and the mainland.
Response 5:
Portions of the transportation system that are potential mainline roads will be designed with this in mind.
Comment 6: (paraphrased)
Preserving huge blocks of old growth timber in order to preserve species integrity is unnecessary when
the study area has so much timber that is not proposed for harvest.
Response 6:
The old-growth retention, defined in Alternative 5 was designed to assure dispersal of wildlife from the
Naha LUD II to areas of traditional use of wildlife. Without biological corridors as designed, some wildlife
populations within the Naha are more likely to grow until they harm their food base.
Comment 7: (paraphrased)
Animal populations are not harmed by the introduction of timber harvest, in fact, Black Tail deer
populations usually increase.
Response 7:
This is true, but clearcuts 0-1 5 years old lack canopy cover to intercept snow, making forage unavailable
during deep-snow winters. As these stands grow, the canopy closes and lack of sunlight eliminates
browse species, thus reducing the habitat capability for deer.
Comment 8: (paraphrased)
It is important to point out that the intent of this document should be followed, and not strictly adhere
to drawings or a map as the final say in unit location or configuration. Let ground conditions reflect how
the unit should actually look.
Response 8:
We agree, but not at the expense of the standards and guidelines. The phase card system addresses
your concerns.
Comment 9: (paraphrased)
Many of the mitigation methods talked about call for selective harvest. This could easily create unhar-
vestable areas if great care isn’t taken during design. Ground conditions should dictate where this is
used and costly helicopter harvesting should not be the only option considered due to its’ limited
availability and affordability.
Response 9:
The selective harvest prescriptions will be determined on a site-specific unit implementation basis.
Where clearcutting is determined to be the optimum harvest method given the site-specific circum-
stances, it will be applied.
Comment 10: (paraphrased)
I have concerns with the stream mitigation measures. They are so complex and unweildly that following
them may be impossible.
Response 10:
The fisheries standards and guidelines are similar to those implemented in the KPC 1 989-94 Long-T erm
Sale. These guidelines, though complex, have been successfully implemented. We feel confident they
will also be successful in the Shelter Cove project.
Comment 1 1 : (paraphrased)
Page 32 #1-A - this could be interpreted to mean all streams must have a 25 foot buffer.
Response 1 1 :
This applies to streams where stream stability is controlled by vegetation and not by bedrock. The
majority of Class II streams are bedrock contained streams, so this mitigation would not apply to these
streams.
Comment 12: (paraphrased)
Page 33 #4 - this calls for buffers on the buffers. Totally unnecessary when the primary purpose is to
create LOD in the stream.
Response 12:
We agree. The prescription will be applied site specifically.
Tongass Conservation Society
Box 3377
Ketchikan, AK 99901
February 1, 1991
Mr. Steve Ambrose, Acting Forest Supervisor
United States Forest Service
Federal Building
Ketchikan, AK 99901
Dear Steve,
Re; Shelter Cove DEIS
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The Tongass Conservation Society (TCS) found the Shelter Cove
DEIS to be generally clearly written and presented, and obviously
the product of a lot of hard work. We were encouraged by the
Forest Supervisor's emphasis, in his introductory letter, upon a
"New Perspectives" approach towards managing the forest, and
particularly encouraged by the appearance of Alternative 5 as one
of two preferred alternatives. We believe that Alternative 5
begins to capture the kind of management that Congress had in mind
for the Tongass when it passed the Tongass Timber Reform Act
( TTRA) , and Alternative 5 is an alternative which, under certain
circumstances, we could support.
Alternative 5 is the only potentially acceptable alternative
because it is the only one that places significant values on
resource considerations besides commodity timber. Alternative 3
does not raise or consider many of the issues that it should as a
"recreational" alternative, and thus is "recreational" in only a
superficial sense. In addition, all other action alternatives
contain roading within the Naha LUD II for the sole purpose of
timber harvest, which we believe is not "vital" and is thus
inconsistent with its LUD II status.
It appears that as it presently stands. Alternative 5 wildlife
old-growth retention in effective blocks will (i) encompass those
portions of the project area that have the highest upland wildlife
values, both for their own sake and because of their connections
with other particularly important wildlife areas on the island,
(ii) protect wildlife values that are high enough that they ought
to take precedence over timber harvest in the areas in which they
occur, and (iii) be likely to accomplish their task — to assure
viable populations and preserve biological diversity in the project
area by preventing habitat fragmentation.
However, we are concerned that due to actions not covered by
this DEIS, Alternative 5 promises more than it can deliver. The
Forest Service's full plan of operations for the Shelter Cove area
will undo most or all of the positive accomplishments of
Alternative 5. The planned road link to Ketchikan, which will pass
through the most sensitive part of the project area and facilitate
easy road access throughout the area, will significantly contribute
to this overall resource degradation.
By failing to consider the full impacts of the actions planned
for Shelter Cove, the Forest Service has fallen foul of National
Environmental Protection Act (NEPA) requirements.
In several basic ways, we believe this DEIS is inconsistent
with Council on Environmental Quality (CEQ) regulations for
environmental impact statements. We also believe that it is
inconsistent with some sections of TTRA, and is insufficient to
satisfy its responsibilities under the Alaska National Interest
Lands Conservation Act (ANILCA) . Prominent among the deficiencies
we find in this DEIS are its failure to identify a need for the
action, depict cumulative effects, consider connected or cumulative
actions as one action, provide for a sustained yield of all
renewable resources, or adequately consider impacts to subsistence.
We believe that the DEIS needs to be withdrawn, its deficiencies
remedied, and a new DEIS presented for the Forest Service's plan of
operations in Shelter Cove.
In the following pages, we (1) highlight the importance of the
area for non-commodity timber values, (2) discuss the document's
deficiencies with respect to NEPA, TTRA, and ANILCA, and (3)
include general comments that we think the Forest Service should
address .
I . Importance of the Area.
In entering the Shelter Cove area, the Forest Service is
entering an area of great importance for its wildlife, fisheries,
recreational, aesthetic, and tourism values. This importance is
recognized by the Forest Service itself, by the Alaska Department
of Fish and Game (ADFG) , and by both agencies in collaboration. In
particular, the portion of the project area encompassing lands
around Upper George Inlet-Leask Cove-Salt Creek and especially the
Salt Lagoon has been identified as one of the most important
wildlife habitat areas on Revilla Island. For example:
1. The area around the Salt Lagoon has been proposed
as a critical habitat area. "The fish and wildlife species
diversity and abundance found in the chuck are relatively
rare, and an extremely valuable resource." A variety of human
uses of the Lagoon's wildlife resources are found in and
around the Lagoon. (ADFG)
2. The DEIS acknowledges the importance of the area
for wildlife in its description of the alternative most
responsive to their needs — Alternative 5.
"Alternative 5 protects the important biological values
2
in the Assessment Area by staying out of the north end of VCU
747, which is packed with prime wildlife and fish habitats:
(1) travel corridors from Naha LUD II to VCUs 747, 746 and
748; (2) the largest contiguous block of old-growth habitat in
the Shelter Cove Assessment Area, e.g., adequately large to
support wildlife species that require very large blocks of
habitat (goshawks, boreal owls, and perhaps necessary for pine
marten); (3) this large contiguous block of old growth
connects to the old growth within the Naha LUD II, thereby
resulting in an old-growth block that better assures
perpetuation of the forest-interior species over the long
term; (4) prime deer and marten habitats; (5) priority 1
habitat in Forest Habitat Integration Program; and (6) and
unusually high density of prime riparian habitats and prime
anadromous fish habitat, which will be costly and very
difficult to fully protect under the intensive roading and
harvesting planned by most alternatives for the northern
portion of VCU 747. In contrast, the remainder of the
Assessment Area is removed from the old-growth habitat block,
and has old-growth forest in blocks too small to support all
wildlife species though they are still suitable for timber
harvest." (DEIS, p.4-57-58.) Thus, the DEIS itself identifies
this area as the most important section for wildlife within
the project area, and of great significance to wildlife on a
landscape basis.
3. ADFG and the Forest Service agree that this
portion of the project area is of great importance to wildlife
and the assurance of biodiversity: the design and location of
the top-priority old-growth block connecting the Salt Lagoon
and the Naha was developed as a collaborative effort between
ADFG and the Forest Service.
4. Management Area K-39 (relevant VCUs 747 and 748)
"contains most of the heavily used recreation areas around
Ketchikan." (Tongass Land Management Plan (TLMP), 1985-86
Amendment, p.186.)
5. The foci of the two preferred alternatives,
"Forest-Interior Species" and "Recreation/Visual Resources"
are an implicit recognition of the importance of these values
in the project area.
There are numerous other examples that could be cited — among
them the importance of the area's salt water sport fishery for its
recreational and tourism values, and the personal use fishery at
Leask Creek, both of which also highlight the area’s important
aesthetic values.
This area harbors an inordinately high concentration of
wildlife, recreation, and other non-timber-commodity resources.
3
Impacts to these resources resulting from the Forest Service's plan
of operations in this area will not be trivial. Rather, they will
be substantial and important. They must be fully depicted in this
DEIS, and they are not.
II . Inconsistencies with NEPA.
This DEIS improperly segments the Forest Service's plan of
operations for the Shelter Cove area into several smaller actions,
proposes to consider the effects of these actions separately, and
in so doing, fails to consider connected or cumulative actions as
a single action as required by Council on Environmental Quality
(CEQ) regulations regarding environmental impact statements. It
hides the cumulative impacts of all the actions planned for Shelter
Cove, again in violation of the CEQ regulations. It fails to state
adequately a need for the project or rigorously explore all
reasonable alternatives.
1 . Failure to consider connected and cumulative actions.
Under CEQ regulations, "connected actions" and
"cumulative actions" are required to be considered together in a
single EIS. See 40 C.F.R. 1508.25 (a)(1) (1984). "Connected
actions" are defined as actions that:
"(i) Automatically trigger other actions which may
require environmental impact statements.
(ii) Cannot or will not proceed unless other actions are
taken previously or simultaneously.
(iii) Are interdependent parts of a larger action and
depend on the larger action for their justification." Id.
Cumulative actions are those actions,
"which when viewed with other proposed actions have
cumulatively significant impacts and should therefore be
discussed in the same impact, statement . " Id.
This DEIS improperly fails to consider two actions that under
these regulations are connected or cumulative to the action
considered in this DEIS: (1) the proposed mainline road linkage
between Ketchikan and the project area, and (2) subsequent planned
entries into the project area for the purpose of timber harvest and
other management activities.
(a) The mainline road linkage. In its original scope as
the Revilla Plan, the road link from Ketchikan to the project area
and from the project area to Canada supplied one of the major
4
rationales behind the plan’s development and timber entry in the
Shelter Cove project area. As described by the DEIS, in its
original scope as the Revilla Plan,
”[t]he intent was to meet the public's demand for multiple use
throughout Revilla Island. This objective was to have been
accomplished by integrating timber sales and their associated
road system with a road link to Ketchikan. However,
management decided to delay the road link to the project area;
therefore, this DEIS will describe alternatives for the
harvest of timber in and around Shelter Cove and George Inlet
areas of the Tongass National Forest." (Emphasis added.)
(DEIS, p. 1-1-2.)
Management decided to embark on a project precisely to create
certain impacts throughout the project area and the island: i.e.,
to facilitate access and multiple use. Management has not
abandoned this project, only delayed one part of it. Yet in this
DEIS, it wants to consider separately the impacts of only half the
project, and consider the impacts of the other half of the project,
again separately, later on, thus masking and never considering the
full impacts of the project as a whole. This is contrary to NEPA.
(See Thomas v. Peterson, 753 F.2d 754 at 758, citing Alpine Lakes
Protection Society v. Schlapfer, 518 F.2d 1089, 1090 (Ninth Cir.
1975)). The impacts of extensive road access and multiple use on
a valuable and previously undeveloped area are greater than the sum
of the impacts of each half of the project considered separately.
Interdependent actions. The two halves of the project
are interdependent actions under the CEQ regulations, and must be \
considered together. The timber harvest roads planned in this DEIS ^
have been specifically situated and designed to be upgradable to
mainline standards in anticipation of their being connected by a
road link to Ketchikan. Much of the recreational analysis
presupposes a road link to Ketchikan (one of the preferred
alternatives, the Recreational/Visual Resources alternative,
assumes this link). In the Forest Service's informational meeting
on 1-18-91 (informational meeting), prominently featured in the
presentation on roading were the design criteria that would
facilitate upgrading once a mainline link was established; the
timber roads would then become main transportation links . So the
road link to Ketchikan, although nominally delayed, continues to be
connected to the project as described by the DEIS. Likewise, as
presently conceived, there is no "link" to anything if a road to
Ketchikan is advanced somewhere into the project area and cannot
connect with roads to be developed through timber harvest.
Automatic trigger. The presence of roading developed
through timber harvest in one section of the project area will
serve to trigger the building of the road link to Ketchikan. By
providing completion of the first stage of the project as
-
5
originally envisioned, other stages will follow in order to access
the perceived "benefits" offered by the first stage. It is highly
unlikely that, once roading penetrated much of the project area,
the link making that roading available to Ketchikan would not be
built. Under this standard as well, the road link to Ketchikan and
the rest of the project are connected actions.
Cumulative actions. The mainline link to Ketchikan and the )
project as proposed in this DEIS will have cumulatively significant L6k
impacts. The link will permit direct access by road from a major r A
population center throughout the roaded portion of the project ^
area. Without either the access link to Ketchikan or the
dispersion of possible destinations provided by the roading
contemplated by this DEIS, the impacts of either one of these
actions would be significantly less — one would either not be able
to access the area, or once accessing it would have essentially
nowhere to go. But together, these actions will facilitate
substantially increased human impacts on the project area and its
wildlife, fisheries, recreational, and subsistence resources.
These impacts are hinted at where the DEIS describes
increased human harvesting of wildlife as a result of roading (DEIS
4-62-71, passim) , impacts to fisheries through road access in its
discussion of increased pressures on the "highly susceptible to
angling and poaching" Salt Creek coho run (DEIS p.4-49), impacts to
recreation (through increased competition for wildlife and other
recreational resources (DEIS p.4-35), and impacts to subsistence
(ANILCA finding, DEIS p.4-75). These kinds of impacts all depend
on human access, and will be greatly magnified by the road access
facilitated by both of these actions taken together.
Under relevant law, if "substantial questions" exist as
to whether two actions will have significant cumulative effects,
the actions must be evaluated in the same EIS. See Thomas v.
Peterson, 753 F.2d 754 (1985) (citing Foundation for North American
Wild Sheep v. United States Dept, of Agriculture, 681 F.2d 1172,
1178 (9th Cir. 1982); City and County of San Francisco v. United
States^ 615 F.2d 498, 500 (9th Cir. 1980).)
At the very least, substantial questions exist here.
Under the CEQ regulations, the road link and the project
activities covered by this DEIS are both "connected" and
"cumulative" actions. They need to be covered in the same EIS.
This DEIS needs to be withdrawn and a new DEIS issued that covers
both of these actions.
(b) Subsequent planned entries into the project area for
the purpose of timber harvest and other management activities.
6
Connected actions. The action considered here — the
first entry into the project area — and subsequent planned entries
into the area are connected actions under the CEQ regulations. The
major connection mechanism among the actions is the establishment
of roads.
Cannot or will not proceed unless other actions are
taken previously or simultaneously. The timber harvest activities
scheduled from the end of first entry forward are dependent on
activities, namely roading associated with timber harvest, taking
place in the first entry. It is common practice for roads
established in the first entry to be used for accessing and
removing timber in subsequent entries. If these roads had to be
built in their entirety to access timber scheduled for harvest in
subsequent entries, the additional road construction would
substantially affect the economics of the operation, precluding it
or necessitating changes. The location and timing of successive
management activities will be affected by this entry. See Thomas
v. Peterson, 753 F.2d 754 at 760. As a practical matter,
subsequent planned entries in this project area would not proceed
but for this first entry. Thus these actions are connected and
their impacts must be evaluated in the same EIS.
Interdependent parts of a larger action. The plain
fact is that there is a larger plan for timber harvest in the
project area, of which this entry is only a part. The harvest
schedule on p.4-45 reflects not only acres harvested in each time
period, but also variations in this cut over time by alternative.
Long-term cumulative impacts to soil resources (4-7-11), and to
roading (4-23) have also been depicted. This is more than a rough
estimate; it reflects a plan. The larger action, according to this
harvest plan, is the harvest of all operable timber within the
project area — roughly 29,000 acres or 741mmbf (minus retention
areas) by year 2060. This goal derives from timber harvest targets
handed down from higher planning levels to the Ketchikan Ranger
District for its independent sale program. This entry and
subsequent entries are all part of the larger action of achieving
that harvest goal, and are only justifiable in its light.
Automatic trigger. The Forest Service
representation that a second entry could come in as little as five
years, and the need to achieve the cumulative harvest target,
indicate that when this entry is well established, another entry
will automatically follow.
The entry described here, and subsequent entries contemplated
by the Forest Service's plan of operations for Shelter Cove, meet
all three criteria for connected actions established by the CEQ
regulations (meeting just one would be sufficient to identify the
actions as connected). Thus they must be considered , in a single
EIS.
7
Cumulative actions. Cumulative actions are those that
have cumulatively significant impacts. Further entries into this
area are planned. Cumulative impacts over the rotation to certain
resources as a result of these actions are depicted in the DEIS: to
the timber resource, pp. 4-43-45; to soil resources (4-7-11); and to
roading (4-23). The DEIS' own portrayal of these cumulative
impacts means that the actions that caused them are cumulative
actions and must be covered in the same EIS.
It is clear that other entries into the project area will
follow this one. The Forest Service has scheduled further harvest,
and acknowledged that subsequent entries might come within five
years. The harvest schedule on DEIS p.4-45 contemplates the
harvest of all operable timber within the project area (with the
possible exception of some retention units) over the next 70 years.
This level of cutting and conversion to second growth of negligible
value as wildlife habitat will have a devastating impact on the
wildlife resource, and on recreational resources to the extent that
recreation is associated with old growth or wildlife. The
cumulative impacts of the extensive roading system associated with
this harvest plan on the previously unroaded Shelter Cove area will
be very substantial, and are nowhere considered. The cumulative
impacts of human access on subsistence and sport hunting will
likely be severe, and are nowhere considered. There will be
impacts to sport fishing from increased access. All of the impacts
considered earlier in connection with the mainline link to
Ketchikan will occur in connection with further roading for timber
harvest. As discussed in that context, the DEIS implicitly
recognizes these impacts, but does not analyze them. And these
impacts will tend to increase at an accelerating rate as a higher
percentage of old growth is harvested. For example, we state
further on in these comments that we think the old-growth block
proposed in Alternative 5 will do its job with respect to inner-
forest species habitat and biodiversity — for the activities
depicted here. We are far less confident in its success by the end
of the rotation, when all of the scheduled timber has been
converted to second growth.
The action covered by this DEIS, and further planned timber
harvest and other management activities in the project area have
cumulatively significant impacts. These impacts are discussed in
greater detail below under "Failure to depict cumulative impacts,"
"Wildlife issues," "Fisheries," and "Recreation." Under the CEQ
regulations, these impacts must be considered in the same EIS.
This DEIS needs to be withdrawn and a new DEIS needs to be issued
covering all planned timber harvest and other management activities
to the end of the rotation.
2. Failure adequately to depict cumulative impacts.
We are concerned about two kinds of cumulative impacts : \
those impacts to forest resources resulting from native corporation
logging operations in both the near term presently covered by this
DEIS and over the long term, and those resulting from timber
harvest, road building, and other management activities on national
forest land in both the near term and over the course of the
rotation .
(i) Native corporation logging. The EIS recognizes that\
extensive harvesting of native corporation lands in the vicinity of ]
upper George Inlet will have some visual impact on that area. I
However, no other impacts as a result of these harvest activities /
are noted. Deer winter range along George and Carroll Inlets has j'X
been lost. There have been extensive impacts to other wildlife
species. There have also been disproportionate impacts to high
volume timber stands. These impacts should be discussed, as they
tend to make the area's remaining wildlife habitat and the old-
growth blocks depicted in Alternative 5 all the more important.
The heavy visual impacts to the important Upper
George Inlet recreational resource tend to make any further timber
harvest visual impacts all the more important. On EIS page 3-11
the U. of Oregon recreational study concludes "Alaskans are quite
sensitive to the natural qualities and aesthetics of the
environment in which they pursue outdoor recreation." This
suggests that the visual impacts to the Upper George Inlet area
resulting under most action alternatives do have a cumulative
impact which is greater than their impact alone. This cumulative
impact should be noted for those action alternatives to which it
applies. It would be a significant loss if this important 7
recreational resource were diminished in value by surrounding it
with timber harvest visual impacts.
(ii) Cumulative impacts over the rotation. Impacts to
all resources in the project area should be depicted over the J
rotation. As noted above, impacts over the rotation are described (ola-I
only for soils, roads, and timber. They must be described for all \
other resources. The DEIS' depiction of impacts to wildlife, \
recreation, fisheries, and visual resources only to the end of the
first entry is insufficient to describe the full impacts this
project will have on the project area.
The Forest Service explained at the informational meeting that
each successive EIS issued to cover a separate entry into the
project area would consider the cumulative impacts resulting from
that and all previous management activities in the area. But the
Forest Service has made this precise argument before in Thomas v.
Peterson, where it was squarely rejected by the Ninth Circuit.
"We believe that consideration of cumulative impacts after the
[first action] has already been approved is insufficient to
fulfill the mandate of NEPA. A central purpose of an EIS is
to force the consideration of environmental impacts in the
9
decisionmaking process. [cites omitted.] That purpose
requires that the NEPA process be integrated with agency
planning "at the earliest possible time," 40 C.F.R. section
1501.2, and the purpose cannot be fully served if
consideration of the cumulative effects of successive,
interdependent steps is delayed until the first step has
already been taken." (753 F.2d at 760.)
Forest Service activities planned for Shelter Cove will
extensively transform the area. Activities taken in this period
will facilitate activities taken in subsequent periods. The
harvest schedule contained on page 4-45 portrays the harvest of
100% of the operable timber in the project area by year 2060. This
means that at year 2060, all operable acreage will be in various
stages of second-growth. This second growth will be of negligible
value as wildlife habitat. Its value for recreation will also be
greatly diminished, to the extent recreation is connected with old
growth or wildlife. Moreover, areas designated for old-growth
prescription in this EIS are protected only until the next EIS is
issued — perhaps only five years from now. There is no assurance
that over the rotation, designated old-growth retention acreage
will not be converted to second growth.
The extensive roading system that will accompany timber
harvest operations will have extensive effects on the area. The
effects of these roads, including the main link to Ketchikan, and
the human access they provide must be described for all resources.
It is insufficient for the Forest Service to say that the roading
provided in this entry will have little effect absent the road link
to Ketchikan, and that the effects of these roads once the road
link is proposed will be covered in that EIS. Quoting Thomas v.
Peterson, "[T]he consideration of cumulative impacts will serve
little purpose if th[ese] road[s] ha[ve] already been built." (753
F.2d at 760.) And building the roads planned here tips the balance
in favor of building the road link to Ketchikan. Id.
The cumulative impacts of roading for this action and the road
link to Ketchikan — and subsequent planned actions that will rely
on roads built for this action — must be considered before the
actions occur — now.
We believe that with the passage of the Tongass Timber Reform
Act, Congress has given the Forest Service direction as to the
importance of non-commodity resources on the Tongass. Impacts to
non-commodity resources were precisely what Congress had in mind
when it passed the act, and were very largely the driving force
behind the act. Section 101 states that meeting new timber harvest
targets shall be "to the extent consistent with providing for the
multiple use and sustained yield of all renewable forest
resources." (Emphasis added.) (TTRA Section 101.) „ Congressman
Miller stated on the House floor that in passing Section 101
Congress intended the Forest Service to "provide for non-commodity
10
uses of forest resources for subsistence and recreation." Thus,
Congress has directed that management of non-commodity resources is
important, and that these resources must be provided for on a
sustained yield basis. Not only does NEPA require the cumulative
impacts to be revealed, but the impacts that have not been revealed
in this DEIS are the precise ones Congress expressed concern for
through TTRA. Finally, not only are these impacts not depicted
here, they are depicted nowhere else.
The only length of rotation impacts considered in the DEIS are
those to the timber resource: pp. 4-43-45, to soil resources (4-7-
11), and to roading (4-23). The length of rotation cumulative
impacts to all resources must be depicted in this DEIS.
3 . Failure adequately to state a need for the project.
The purpose and need for the project are not described with
sufficient specificity. We believe that tiering to TLMP is
insufficient. The direction and resource targets provided from
TLMP and higher management levels are general — the Forest
Supervisor refines them into actual projects, and decides where
timber harvest will occur. (Explanation at 1-18-91 informational
meeting.) What is the need to harvest between 6 1 . 8-95 . 6mmbf of
timber, and importantly, why should this timber come from the
Shelter Cove project area?
2, CowA
We believe that under TTRA, any such need will have to fully
consider the presence of other important resource values in the
project area and abide by the Congressional mandate to provide for
their sustained yield.
Further, TTRA's amendment of ANILCA section 705(a) sets timber
targets that are keyed to market demand. What is the market demand
that justifies the timber harvest contemplated by this project, and
by the harvest action currently covered by this DEIS? We believe
the Forest Service must identify this demand.
4 . Failure to rigorously explore all reasonable alternatives.
Our concern is that in the near term, there may be only two
real alternatives presented in this DEIS, and in the long term
there may be just one — the Forest Service plan of operations,
with no alternatives to it explored.
Near term. With the exception of Alternative 5, all the
action alternatives are defined by various aspects of timber
harvest. The names attached to these alternatives are less
important than the bases on which they were drawn. All action
alternatives except Alternative 5 were drawn on the basis of timber
harvest characteristics. Even Alternative 3, contrary to its name,
was designed on the basis of timber harvest unit size, placement
11
and geographical dispersion — nothing more inherently recreation-
oriented. We discuss this further in general comments. We would
like to see a true recreational alternative. But in the short
term, the tendency is for there to be various timber harvest-based
alternatives and one wildlife alternative.
Long term. The situation in the long term is far bleaker.
Over the next 70 years, as timber harvest proceeds throughout the
area and all operable timber is harvested, all. of these
alternatives will look very much the same. Thus, there is really
only one alternative presented in the long term — the plan of
operations presented by the Forest Service. Under NEPA, the Forest
Service must present all reasonable alternatives to this plan of
operations — rigorously researched so the differences among the
alternatives are real, not merely cosmetic. The DEIS's evaluation
that "[t]he cumulative effects resulting from timber harvest
throughout the rotation are not expected to change relative to the
effects of any of the action alternatives" (p.4-45) indicates that
the alternatives are not meaningful ones.
III. Inconsistencies with TTRA. -
As stated above, we believe that in TTRA Congress has given
important new direction about how the forest should be managed.
TTRA's intent was to protect non-commodity resources on the
Tongass. This new direction should be reflected in the Forest
Service's plan of operations in Shelter Cove. The Forest Service
has said this DEIS will be amended to reflect TTRA, and we will be
interested to see what steps the Forest Service takes in that
direction. However, at this time there are two points that we wish
to address:
i
1. Roadinq in the Naha. All the action alternatives except
Alternative 5 build roads for the purpose of routine timber harvest
in the congressionally mandated LUD II. We believe that such
roading is inconsistent with TTRA and will appeal the adoption of
any alternative that contains such roading. In order to be legal,
such roading must be "vital." The very presence of Alternative 5,
which does not contain such roading and yet which shows a positive
mid-market conversion rate, and indeed is one of two preferred
alternatives, demonstrates that such roading is not vital.
Moreover, we do not believe that the term "vital forest link" is
meant to apply to roads built for no other purpose than to access
timber .
2. Sustained yield of all renewable resources. As discussed
above, the plan of operations for Shelter Cove will not provide for
the sustained yield of many non-commodity resources, including
wildlife and recreation. Rather, in particular the wildlife
resource will likely be decimated over the next 70 years. This is
contrary to sustained yield as expressed in TTRA.
12
IV. Insufficiency of ANILCA finding.
The ANILCA finding (DEIS p.4-75-76), appears to contradict
itself. P.4-75:
"Due to projections of future habitat reductions and projected
demand increases, which are independent of any action taken
during this five-year period, a restriction to subsistence
users of deer, fish, black bear and furbearer species may
potentially occur in the future. As presented in the wildlife
effects section, projected decrease in habitat capability over
the long term assumes that timber harvest remains at levels
currently scheduled in [TLMP]."
"It has been projected in this analysis that no significant
restriction to fish, Sitka black tailed deer, black bear or
furbearers would potentially occur as a result of implementing
long term management direction and future projected increase
in demand for subsistence use of these species."
This discrepancy should be remedied. We do not agree that
future habitat reductions are independent of any action taken
during the period covered by the DEIS. Rather, such reductions
will both include reductions in habitat occurring during this
period and be facilitated by actions occurring in this period.
Where timber will be harvested, and where roads will go in this
entry, will have a significant effect on long term wildlife
abundance within the area. The effects are cumulative. These
effects must be analyzed in this EIS.
Long-term projections. Moreover, the long-term projections
of impacts to wildlife populations and habitat referred to above
have not been done. There have been no long-term projections made
in this DEIS regarding wildlife presence, or subsistence or other
hunter demand. These long-term impact projections must be done in
order to satisfy ANILCA requirements regarding effects on
subsistence. The EIS needs to delineate and analyze more clearly
potential reductions to both subsistence and non-subsistence
hunters .
Other lands and other alternatives. On p.4-75, the EIS
asserts that there are no other lands that could be considered for
the proposed action. Assuming the purpose of the action is that of
producing 6-8mmbf of timber per year, there would appear to be many
other areas in which this action could take place. Certain of the
lands considered here are too valuable for other purposes to devote
them to timber production. We find the argument that there is no
place else to satisfy the timber harvest goals of .this project
unsupported, and indeed far-fetched. The EIS ' s representation
concerning this point seems to be, "The project is taking place on
P.4-76:
13
these lands, so there are no other lands on which it could take
place." We don't think that this is the kind of reasoning ANILCA
had in mind, and we don't agree with the conclusion. We think
there are other lands where this action can take place.
Necessity, Consistent with Sound Management of Public Lands .
There is insufficient foundation given for the determination made
here (DEIS p.4-76). This must be more thoroughly explained. In
what sense are the long term impacts that will result from the
Forest Service's plan of operations in Shelter Cove consistent with
sound management of public lands — in light of the unusually high
value and importance of the non-commodity resources in this
particular area, and the mandate of TTRA to protect important non-
commodity resources? We believe that the plan of action proposed
here is not consistent with the sound management of public lands.
V. General Comments.
1 . Public participation.
Only one day's notice was provided for the 1-18-91 public
meeting. Although we are glad that the meeting was held, we do not
think that this is sufficient notice. The meeting was sparsely
attended, and at least two of our members who have devoted a great
deal of energy to this issue were unable to attend due to prior
commitments. We were relieved to hear that the prior informational
meeting, held 1-10-91, which was by invitation only was actually
intended to be a public meeting. Yet we note that the first
meeting was not advertised at all and the second was given only one
day's notice — not a design that is likely to generate much public
participation. On the positive side, since that time we have heard
frequent radio reminders of the deadline for comments on this DEIS
and where to submit them.
The 1-18-91 meeting was useful. However, contrary to its New
Perspectives outlook, along with the District Ranger, the only
resource personnel present from the Forest Service were foresters
and engineers. There were no biologists, and no recreation
specialists — although the two preferred alternatives were titled
Forest-Interior Species and Recreation/Visual Resources. As a
result, the basic rationale behind Alternative 5 was poorly
explained. Among the attendees was Ketchikan's Mayor, who will be
responding to the EIS in his official capacity. It will be very
difficult for him — or anyone else — to support any alternative
whose rationale and objectives he does not understand. The
relevant resource personnel should be present when an informational
meeting is held — so people's first impressions can be informed
and fair ones.
Within their areas of expertise, the presenters were expert
and informative. But we note that while maps of all the action
14
alternatives were supplied , no map of the no action alternative was
brought .
Because this EIS started as the Revilla Island project, all
pertinent public comments from that previous phase should be
included in the record and thoroughly considered. We incorporate
those comments by reference as an appendix to this response. Under
NEPA, the Forest Service should also mail notice of any further
public meetings on the project to all those who ask to receive such
notice (perhaps to all who sign in), and also to all those who
asked to be kept informed of developments in the Revilla Plan.
2 . Distribution of harvest by volume class.
Table 4-37 depicts scheduled harvest by volume class
occurrence and alternative. We understand that these figures may
change in light of TTRA. But we are concerned with the accuracy of
these figures, and ground truthing. Specifically, we are concerned
that previous ground-truthing of aerial photo-derived designations
of volume class have turned up significant discrepancies between
what is thought to be on the ground and what is actually there. We
understand that it is difficult to reliably designate homogenous
volume classes in heterogenous stands. Nonetheless, unless the
Forest Service knows where these high volume stands actually are,
it will be difficult if not impossible to harvest according to the
published schedule. The Forest Service needs to show that its
analysis is accurate, particularly with respect to volume class 6
and 7 stands, and publish maps that represent this.
We also have some concerns about the 70-year time frame for
this plan of operations. The EIS should make clear how this is
acceptable in light of the 100-year rotation standard.
3 . Recreation issues.
We believe that in this EIS, the treatment of recreational
values within the project area is grossly inadequate; once again,
we feel that contrary to congressional mandate, timber harvest is
still leading the way in the development of forest management
plans .
This is illustrated by the assumptions underlying the
recreational analysis (DEIS p.3-8):
(i) The project area offers recreation
opportunities usually found in a southeast Alaska primitive
environment.
(ii) Quality outdoor recreation is assured by the
provision of a diverse recreational opportunity spectrum (ROS).
15
(iii) Recreational opportunities are made available
by supplying this diverse ROS, and a diversity of levels of
recreational development.
Under these assumptions, the following logical path occurs:
(1) Quality equals diversity of ROS. (2) In a primitive
southeast Alaska environment, diversity of ROS is provided by the
development of roads. (3) Roads are made possible by timber
harvest. (4) Therefore, timber harvest provides recreational
opportunities. The more timber harvest, the more recreation.
This logic underlies recreational planning in this DEIS for
all alternatives except Alternative 5.
But the reality contradicts these assumptions — including
assumption (i), which holds that the recreational opportunities
present in the project area are typical, i.e., average. With a
minuscule amount of timber harvest to date, M.A. K-39 "contains
most of the heavily used recreation areas around Ketchikan." (TLMP ,
1985-86 Amendment.) An abundance of high-quality recreational
opportunities is presently available in the project area — without
timber harvest activities.
And the quality of this recreation would be significantly
degraded by timber harvest.
"The strongest deterrents for visiting a desirable
recreation area are new logging activities, new
buildings, and new roads. All these activities represent
a divergence from the natural environment."
( EIS p.3-10 (quoting a U. of Oregon survey).)
The problem with the assumptions is that they are too general
to have much meaning in a specific instance; the hidden assumption
of the ROS is that all recreational opportunities are of equal
quality. This is clearly not the case. It is possible to degrade
recreational quality as well as improve it.
This over-generality could have been somewhat mitigated by the
consideration the DEIS provides of specific opportunities for
recreational development. Yet key recreation area changes (p. 4-
20-21) are evaluated mainly by their general change in ROS rating
as a result of roading and timber harvest. Among the alternatives,
only a few differences in specific recreational development
opportunities are noted. Timber harvest and its associated roading
are improperly — and ineffectively — driving recreational
considerations.
There is little justification to call Alternative 3 a
16
Recreational/Visual Resources alternative. In the evaluation of
key recreation area changes (p.4-20-23), Alternative 3 is not
mentioned once in a context beneficial to recreation. Its timber
harvest units result in conspicuous impacts to the key viewsheds of
Salt Lagoon (whose older harvest areas are starting to lose their
visual dominance — p.4-17), Leask Cove, Salt Creek (maximum
modification) , and Leask Lakes (maximum modification) . There are
also significant impacts to North Saddle Lakes. Thus, the
alternative's claim to its title seems to rest primarily in the
notion that dispersing harvest units over a broad area and the
associated road building results in diversity of ROS and access to
more potential recreational areas (yet these specific opportunities
are no different from the ones available in most other
alternatives) .
In comparison, Alternative 5 has less visual impact to Salt
Lagoon, none in Leask Cove, none in Salt Lake and Salt Creek, none
in Leask Lake, and significantly less in the North Saddle Lakes
system. Its ROS class acreage diversity is very similar to that of
Alternative 3, it builds more roads and harvests more timber, yet
because its timber harvest areas avoid the heavily used upper
George Inlet-Salt Lagoon-Leask Cove areas, it preserves the most
important recreational values available in the project area. Thus,
Alternative 5 is far more a Recreational/Visual Resource
alternative than is Alternative 3.
b. There are several basic elements missing from the
recreational analysis:
(i) The baseline. There needs to be a thorough analysis
of recreational resource presence and current recreational use
within the project area. This baseline analysis ought to include
information specific to the project area and show the kinds of
activities undertaken, their relative frequency, their geographic
distribution, their rarity of opportunity for Ketchikan residents,
and their importance to Ketchikan residents.
(ii) Relationships between present recreation use,
wildlife presence and habitat, roading, increased access to the
area in general and to specific sites, timber harvest, future
recreational demand, and tourism should be discussed. For example,
presently high recreational values should not be degraded for the
purpose of accessing other recreational opportunities of lesser
value. New recreational opportunities should themselves not be
degraded through the impacts of accessing them. Recreation and
wildlife presence may be complementary or contradictory: greater
access through roading allows for recreational driving and wildlife
viewing, but also wildlife harvest and habitat degradation.
Tourism may be affected by management activities.. The DEIS
mentions that there is an ongoing increase in independent visitors
to the area, and that some increased use of the project area could
17
result, but this is not investigated. It should be.
(iii) The point of doing this analysis is to produce a
plan that draws distinctions among the values inherent within the
various sections of the project area and compares those values to
similar values present outside the project area — in order that
informed and supportable land use decisions can be made. One such
decision would be where timber harvest should and should not take
place. Some of this area-specific information is present in
various parts of the EIS — but it has not been well integrated.
Without such a picture of what values and potentials lie where
within the project area, and how valuable they are more generally,
other forest resource values will continue to trail timber
commodity value in Forest Service planning. This is the case with
all action alternatives except for Alternative 5. We note that in
the informational meeting, it was explained that the
Recreational/Visual Resources alternative was developed by
shrinking the size of the timber harvest units and dispersing them
not by independently analyzing recreational and visual
resources.
(iv) In connection with the assessment of recreational / ^ 0
resources, an economic analysis of their importance should be done. ?
We are confident that the above assessment will show that
within the project area, the highest recreational, wildlife, visual
resource, fisheries, cultural, and tourism values all lie in the
Upper George Inlet-Leask Cove-Salt Lagoon-Salt Creek area — and
that on a district-wide basis these values are not merely average,
but are very high. We believe that particularly in combination,
these values are so high that timber commodity value cannot
compete. Moreover, timber harvest would degrade, not improve, each
of these values. Thus, timber harvest should not occur in this
section of the project area. Roaded access to this area should be
carefully provided based on the ADOT/PF corridor study and a
carefully drawn plan that manages the impacts of access to retain
and optimize the high wildlife, recreation, visual, and tourist
resources present in this particular part of the project area.
Alternative 5, with some modification, is the only action
alternative currently drawn that can meet these needs.
4 . Economic evaluation.
In the financial analysis on p.4-41, the mid-market pond log
values are defined as including the end product of pulp. But then
utility-grade logs are not counted in the table 4-38 Financial
Analysis Summary. This discrepancy should be addressed. We would
like to see the socio-economic "5-year aggregate value" from p.4-42
listed by alternative and added to table 4-38 in order to give a
better and more complete idea of economic impact on the community .
The "Economic Impact in Terms of Jobs and Projected Income" (table
18
2-24) should also be displayed in the p.4-40-42 Financial Analysis
and Socio-Economic Effects" section.
We note that the only economic values that have been developed
for the project are those associated with timber harvest. However,
there are substantial economic values associated with recreation,
fisheries, and tourism. We think these should be modeled as well.
Economic value from non-consumptive uses of the project area has
the advantage of being continuous (as long as the resource is
conserved) , and not occurring only once every rotation. With a
constant positive economic flow, the resulting aggregate values may
be very high, and may surpass timber commodity value.
5 . Fisheries .
By far the most important fisheries values in the project area
lie in the Upper George Inlet-Leask Cove-Salt Lagoon-Salt Creek
area. The EIS recognizes this: Salt Creek's summer coho run is
termed "important" and receives considerable attention; in
addition, Leask Creek should be included as an important fish
producer and the location of an important personal use fishery and
included in the Major Watershed chart (p.20). Yet this relative
importance is recognized only by Alternative 5. All other
alternatives pursue their objectives in disregard of this
comparative importance.
(i) Damage to Salt Creek. For example, in Alternative 3
"four harvest units are located on the sensitive soils above Salt
Creek." The projected loss to coho production — exclusive of road
building effects — is .07%. Yet Alternative 5, with no harvest
units in the sensitive parts of the Salt Creek drainage, has a loss
to coho spawning of .6% — over ten times higher. (Either this is
a mistake or the analysis is faulty, p.2-20.) Yet harvesting these
Salt Creek units will require road building apparently in the
stream buffer of what is recognized as the most important stream in
the project area. The stream will have to be bridged. Potentials
for stream buffer blowdown and siltation from roading are
recognized but not quantified in the analysis. Potential
overharvest of Salt Creek coho is noted due to this roading, camp
effects, and low summertime flows. Such unmeasured effects suggest
that impacts to Salt Creek may be underestimated at .07%. And
these effects result from activities taking place only in this
first entry. Nonetheless, all alternatives with the exception of
Alternative 5 propose these harvest units. This appears to be
overvaluing timber from those harvest units at the expense of
fisheries .
(ii) Integrity of buffer zones; blowdown. In connection
with the TTRA-mandated stream buffers, we urge that every attempt
be made to provide windfirm buffer zones. Blowdown. . and salvage
sales have in the past resulted in the deformation of management
plans. Although blowdown is a fact of life, Congress' intent with
19
respect to non-commodity values makes the integrity of buffer zones
even more important.
(iii) General impacts. We do not think that the
mitigation of a fishway at Salt Creek is adequate to the general
harm that will be done by timber harvest in this portion of the
project area. Unquantified impacts suggest that such harm may be
understated. Impacts to Leask Creek have not been considered, but
should be — as should impacts to the salt water sport and personal
use fishery.
The salt water fishery has considerable economic and
recreational value, which could be impacted by timber harvest
activities in the Upper George Inlet vicinity. This economic value
is likely to grow as commercial chartering continues to expand in
the Ketchikan area. In 1985 there were 50 charter licenses owned
by Ketchikanites ; in 1990 there were 75 — a growth of 50% in just
five years. As the tourist industry continues to expand — and
tensions in the Persian Gulf have already increased this expansion
— sport fishing in upper George Inlet will have an expanding
economic impact. If it is true that impacts to fisheries
productivity are understated, then there will be declining
productivity over the rotation. But also, recreational, personal
use, and charter sport fishing popularity may all be affected by
deteriorating visual quality associated with timber harvest, should
more harvest units become visible from Upper George Inlet.
Impacts such as this are not considered in the finding of "no
significant impact" to the fisheries resource. However, they are
real, have economic value, and should be considered.
We believe that the finding of "no significant impacts" to
fisheries resources is inaccurate. We think there have been
significant impacts in the past, and that significant impacts in
this area will continue in the future. We are prepared to live
with impacts to fisheries from management activities — but we
think that good management and the TTRA endorsement of fully
balanced multiple use would indicate that those impacts ought to be
directed to the less-sensitive or important fisheries resources.
In this case, we think that impacts to the sensitive, important,
and valuable Salt Creek-Salt Chuck-upper George Inlet area should
be avoided by avoiding management activities there. We are far
less concerned, for example, with impacts to Nigelius Creek and
mid-Carroll Inlet. The only alternative that accomplishes this
purpose is Alternative 5.
6 . Wildlife issues.
Earlier we discussed the high importance of this area, and
particularly the Upper George Inlet-Leask Cove-Salt „ Lagoon-Salt
Creek area, for wildlife. (See p.2, infra.) This area provides
extremely rich wildlife and fish habitats, a critical linkage
between the Salt Lagoon and the Naha, and is of great importance in
ensuring biological diversity in southern Revilla Island. This
evaluation is agreed to by both the Forest Service and ADFG. This
part of the project area is far more important for its wildlife
values than for its commodity timber values. Alternative 5 is the
only action alternative that responds adequately to this
importance .
(i) Old growth blocks. We are encouraged to see the
Forest Service embracing the concept of wildlife old growth blocks.
We feel that this concept belongs in the New Perspectives approach
— in that, by providing untouched set-asides of particularly
important forest habitat, and by strategically positioning those
reserves across the landscape, the habitat needs of forest-
dependent species and long-term biodiversity are much better
served. We support the second method of designing those blocks
listed in the DEIS, and congratulate the Forest Service in its
adoption .
In such an approach, the size of blocks and their
placement are critical. Old-growth blocks of small size do not
contain the variety and abundance of habitat resources to
accomplish their task of providing old-growth dependent species an
environment with sufficient range, free of edge effects, and
encroachment, competition or predation from displaced or more
adaptable species; and an old-growth block surrounded by timber
harvest does not well provide for the dispersion and in-migration
that is important in protecting against localized extinctions. We
agree with the EIS's assessment of the Alternative 5 old-growth
block quoted earlier (See p.2, infra.) We think that its size and
placement will enable it to actually do its job. It is of
substantial size, and strategically placed between Upper George
Inlet and particularly the Salt Lagoon, and the Naha roadless area.
We are far less confident about Alternative 3, which contains 14
harvest units cut out of the old growth area between Upper George
Inlet-Salt Lagoon and the Naha — in direct contradiction to the
connectivity that is one of the policy's major rationales. The
roading proposed in connection with these harvest units will, when
linked to the Ketchikan road system, further reduce this block's
value by facilitating human access and predation. If an old-growth
block policy is to be adopted, it should be implemented so that it
will actually accomplish its task.
(ii) Importance of the area due to cumulative effects.
The EIS notes that the cumulative effect of earlier timber harvest
in the area is to make the head of George Inlet and the Salt Chuck
even more important for wildlife. The old growth in this area "is
important because of the direct access to old-growth from the salt
water for Sitka black-tailed deer, raptors, Vancouver Canada geese,
and marbled murrelets (White River, Coon Cove, and areas of Salt
Lagoon have been logged.)" (EIS p.4-55.)
21
In our view, the Forest Service has done a good job of
describing the wildlife status quo and the mechanisms that operate
on it. But we see danger in the fact that no cumulative impacts
analysis has been done for wildlife beyond the next 10 years. This
analysis is insufficient.
The planned conversion over the next 70 years of all
operable Shelter Cove old growth to second-growth status (with the
exception of that old growth still in retention prescription) will
have a devastating effect on wildlife populations by devastating
their habitat. Most of these effects will be felt after the next
10 years, and will tend to increase at an accelerating rate as a
greater proportion of habitat is converted to second growth. The
nature and extent of these effects, which will be significantly
influenced by actions taken now and plans drawn in connection with
this first entry, have not been examined. As the cumulative
effects analysis has not gone beyond 10 years, it is not clear that
the old-growth prescription acreage contemplated by this EIS will
adequately conserve wildlife over the rotation, as all the rest of
the area is converted to second growth.
We believe that the effective old-growth block concept is
the basis for an effective multiple-use wildlife conservation
strategy. However, at the moment that seems to represent the
entire strategy. Moreover, the old-growth blocks are not assured
of existence in their proposed form beyond the next EIS. The
Forest Service needs to show how it will conserve the wildlife
resource over the rotation. It has not done so in this EIS.
Alternative 5 represents a New Perspectives approach. No
other alternative does. If an old-growth block policy is
established, it should not immediately be decimated for the sake of
timber commodity value. We agree with the EIS's assessment of the
advantages of Alternative 5: it is an advantage that timber harvest
stay out of the northern end of VCU 747, and instead take place in
an area which is not of such high habitat value.
This is not an extraordinary approach. It is simple,
logical, and represents good planning practice. In contrast,
planning timber harvests in areas that are extremely high in
wildlife values, while at the same time trying to maintain those
very high values, is convoluted, illogical, and may not be
consistent with multiple use as envisioned by TTRA.
7 . Cultural values.
We applaud the Forest Service's conscientious search for, and
protective posture towards, cultural sites in its management plans,
including Shelter Cove. We think that some of these sites may have
educational and tourism value; and we further suspect that the
Upper George Inlet area may be a particularly likely section of the
22
project area to find such cultural resources — another argument
for orienting management of this section around non-timber values.
The archeological sites at Leask Cove should figure into management
planning, and should probably be mentioned in this DEIS.
8 . Special areas.
The Salt Lagoon ought to be recognized as a special area.
Such lagoons are rare; the diversity and abundance of resources the
George Inlet lagoon supports makes it an ecological focal point;
and its tidal hydraulic gradient may have recreational and tourist
value. It may be valuable for research as well. Swans, a
designated sensitive species, winter in the Salt Lagoon and need
special management considerations.
A second area that should be considered for special area
status is that area of national forest bordering the eastern edge
of the state land north of Leask Cove, and running northward to the
point where that state border nearly touches the "boot" of the
Naha. This would encompass at least the northern two of the three
harvest units scheduled in that area by several alternatives. This
land, when combined with contiguous land on the state-owned side of
the boarder, constitutes what may be the largest contiguous stand
of volume class 7 timber remaining in the Ketchikan Ranger
District. The stand comprises roughly 250 acres, and is depicted
on a Forest Service timber type map. It would be unwise to dispose
of this stand through cutting before considering it for its other
values, for wildlife, recreation and tourism. If the Leask Lake
tract becomes a state park, it may be important to have preserved
this stand for its recreation and tourism values.
9 . ADOT/PF corridor study; roadinq in general. Because the j
Shelter Cove area, and particularly VCUs 748 and the north end of / \C
747 are so rich in wildlife and other environmental resources, )
roading through the area should be accomplished carefully, and with V
a particularly clear plan of objectives. Redundancy should be , )
avoided. No roading should take place in VCUs 748, the north end
of 747 or the north end of 746 until the ADOT/PF mainline corridor
study is completed. The reason for this is that (a) within this
part of the project area, roading will have a magnified impact due
to the high wildlife, visual and recreational values of the area,
(b) these values are important and must be conserved, and (c) any
plan for conserving them that is formulated or implemented before
the results of the roading study are known will likely be
confounded by the location of the road corridor, and valuable
resources will be lost. Once the location of the road corridor is
known, the utilization of all forest values — timber and non-
timber alike — can be planned for and can proceed efficiently and
without wastage. The location of the corridor should be known
before other utilization plans are drawn.
23
Cumulative impacts must be considered to meet NEPA
requirements, and failing to evaluate the transportation corridor
as an impact in a sensitive area is a major omission of
Alternatives 2,3,4, and 6. The placement of logging units in the
Leask and Salt Lagoon drainages is unacceptable without an EIS
covering the corridor.
10 . Conclusion .
We think that the Forest Service has achieved something
substantial in Alternative 5. We think that this represents a
useful model for other New Perspectives alternatives. We extend
praise for this accomplishment, for the effort that went into this
document, and for the presentation that resulted.
In the context of a plan of operations that ensured the long-
term viability of Alternative 5, that depicted long-term impacts to
all non-commodity resources and ensured their sustained yield, we
would support that alternative, with some provisos such as the
relocation of harvest units 747-23, 24, and 25. The cornerstone of
such a plan should be the commitment of the Upper George Inlet-
Leask Cove-Salt Lagoon-Salt Creek area to wildlife habitat and
careful recreational use, the maintenance of the Alternative 5 old-
growth block between Salt Lagoon and the Naha, and the road link to
Ketchikan based on the ADOT/PF study.
We urge the Forest Service to produce such a plan. As it
stands, this DEIS is inconsistent with NEPA regulations and must be
remedied .
We thank the Forest Service for considering these comments.
cc : SEACC
Letter from Tongass Conservation Society
Comment 1: (paraphrased)
We have concerns regarding the importance for non-commodity timber values in particular, the portion
of the project area encompassing lands around Upper George Inlet-Leask Cove-Salt Creek and espe-
cially the Salt Lagoon has been identified as one of the most important wildlife habitat areas on Revilla
Island.
Response 1:
We agree, and have developed standards and guidelines to mitigate the environmental impacts and a
monitoring plan which will give us feed back" information regarding impacts to these non-commodity
values. The selection of Alternative 5 minimizes harvest in high value habitat areas, establishes large
contiguous blocks of old growth, and protects potential recreation sites.
Comment 2: (paraphrased)
We feel the DEIS has inconsistencies with NEPA in that it: 1 ) Fails to consider connected and cumulative
actions, 2) fails to adequately depict cumulative impacts from Native Corporation harvest and harvest
of remaining operable Forest Service land, 3) fails to state a need for the project.
Response 2:
Connective actions are defined in 40 C.F.R. 1508.25 (a)(1) (1984)., as actions that:
(0 automatically trigger other actions which may require environmental impact statements.
(ii) cannot or will not proceed unless other actions are taken previously or simultaneously.
(iii) are interdependent parts of a larger action and depend on the larger action for their justification.
Shelter Cove passes all these texts. The project does not automatically trigger any other action by the
Forest Service. The project stands on its own, and requires no previous or simultaneous action for it to
proceed. It is not part of or subordinate to any other larger action.
Thomas v Peterson is cited in support of the contention that the Forest Service must address the road
link with Ketchikan. In this case plaintiffs prevailed on their contention that the Forest Service could not
separate the analysis of the construction of a timber access road from the impacts of the timber harvest
tributary to the road. This case would apply to Shelter Cove if the Forest Service had split the analysis
of the project by assessing only the impacts of road construction in one EIS, and the impacts of timber
harvest in a subsequent EIS. The Shelter Cove project in no way triggers the construction of a link with
Ketchikan. That action is dependent on a variety of factors including other agencies, land disposition,
availability of State funding etc., all of which are beyond the control of the Forest Service.
The Forest Service agrees that the cumulative effects analysis in the DEIS could be strengthened and
has done so in the FEIS. The cumulative analysis in the FEIS assumes harvest of all operable Forest
Service lands within the project area and the impact such harvest would have on all resources.
The Forest Service agrees that connection of the project to Ketchikan via a road link will alter the
cumulative effects analysis effect on subsistence use in particular. Effects on subsistence and other
resources will have to be addressed when such a link is contemplated.
The FEIS contains the analysis of the cumulative impacts from Native Corporation harvest and harvest
of remaining operable Forest Service land.
All the impacts described in Chapter 4 portray the expected impacts of the proposed harvest in
combination with past harvest or any other development activity within these selected viewsheds. For
example, in Alternative 2 and 3, the impacts described for the Leask Cove area displays the impact (or
proposed harvest), how it adds to the impact from the harvest that occurredin the 1960’s plus the
transmission line, and then describes the overall impact. As is noted, Chapter 3 mentions the significant
impact of Native harvest in the overall upper George Inlet area However, the specific viewshed analyzed
in this area (Leask Cove) the Native harvest does not come directly into play when analyzing the overall
impacts.
In the ROD, no harvest is proposed on the slopes above Leask Cove.
The estimated visual impacts in the year 2060 are described in the FEIS. This is based on the amount
of the viewshed proposed for this first planning period, an estimate of harvest levels in subsequent
periods and the amount of acres in wildlife old-growth prescription in these viewsheds.
TTRA requires the Forest Service to provide for sustained yield of all renewable resources. The Multiple-
Use Sustained Yield Act of 1960 (16 U.S.C. 528) Section 4, establishes that ‘some land will be used for
less than all of the resources.' Clearly, this must be so as timber harvest must result in some diminish-
ment of species dependant on old-growth. The Tongass Land Management Plan, as amended in 1 986,
evaluates and prescribes various activities (via land-use designations) for the forest as a whole that
ensure the requirements of Multiple-Use Sustained Yield Act are met over the Forest as a whole.
Congress clearly intended in TTFIA that sustainable levels of timber harvest are to continue on the
Tongass National Forest.
The Tongass Land Management Plan established Land Use Designations. The Shelter Cove project
area is comprised of two such areas, LUD III and LUD IV. LUD III lands will be managed for a variety of
uses. The emphasis is on managing for uses and activities in a compatible and complementary manner
to provide the greatest combination of benefits. The LUD IV provides for intensive resource use and
development where emphasis is primarily on commodity or market resources.
The Shelter Cove project is needed to maintain an independent timber sale program and is located
outside of the Long Term Sale contract area. This project will provide 14% of the expected market
demand for the next 5 years within the Ketchikan and Stikine Area of the Tongass National Forest.
Comment 3: (paraphrased)
The Forest Service failed to explore all reasonable alternatives. In the near term, “with the exception of
Alternative 5, all the action alternatives are defined by various aspects of timber harvest.' lu the long term
•there is really only 1 alternative presented in the long-term - the plan of operations by the Forest
Service.'
Response 3:
Short term: The Forest Service selection of Alternative 5 addresses this point. Long-term: Effects of
harvest subsequent to that authorized in the Shelter Cove FEIS will be fully subject to NEPA require-
ments. Nothing in the FEIS 'automatically' triggers future harvest nor obviates the requirement to
address its impact. Any subsequent entry for timber harvest within the Shelter Cove Project Area will
be subject to all the laws and regulations which regulate Forest Service Management activities.
Comment 4: (paraphrased)
We feel the DEIS has inconsistencies with TTRA with regards to: 1 ) roading in the Naha, and 2) sustained
yield of all renewable resources.
Response 4:
The selection of Alternative 5 which does not authorize road construction in the Naha LUD II area
addresses this point.
See response to comment number 2 regarding the issue of sustained yield.
Comment 5: (paraphrased)
We feel the DEIS is insufficient of ANILCA finding, and it appears to contradict itself.
Response 5:
This discrepancy has been remedied.
Your concerns reagarding long-term projections have been addressed in the FEIS in the wildlife section
of the FEIS.
The Tongass Land Management Plan authorizes harvest of timber from LUD III and LUD IV lands. The
LUD III harvest levels displayed in the ROD are well within this direction to manage for a variety of uses.
Your concern regarding sound management of public land has been addressed in the FEIS.
Comment 6: (paraphrased)
We feel that sufficient notice was not given regarding public participation.
Response 6:
A complete analysis of the public participation process is given in length in the FEIS, Chapter 1 , under
the Public Involvement section. The public comment period was extended beyond what is required by
law. Many, many public meetings were held between the DEIS and the FEIS. Again, a listing of these
can be found in the FEIS.
Comment 7: (paraphrased)
We have concerns regarding the distribution of harvest by volume class, and the 100-year rotation
standard.
Response 7:
The volume class information was used together with stand exam data to give us reliable estimates for
each volume class. Where the volume class stands are located can be found in the administrative record
in the GIS information system. The first harvest for this area was in the 1960's and was located along
the beach fringe and the head of George Inlet. This date is used as the starting point for the rotation.
Comment 8: (paraphrased)
We believe the treatment of recreational values are grossly inadequate. Several basic elements are
missing from the analysis these are: 1) Baseline data, 2) Relationships between present recreation use,
wildlife presence and habitat, roading, increased access to the recreational demand, and tourism
should be discussed and 3) an economic analysis of recreational importance should be done.
Response 8:
The Recreation Opportunity Spectrum (ROS) has been used by the Forest Service and other agencies,
for years, to inventory outdoor recreation environments and experience opportunities. The ROS is not
designed to rate the quality of an individuals experience, since the quality of an experience varies greatly
from person to person. The ROS assumes that a quality outdoor recreation experience is best assured
through providing a diverse set of recreational opportunities.
Recreation opportunities can be expressed in terms of three basic parts: the activities, the setting, and
the experience. As stated in the DEIS, the project area offers recreation opportunities usually found in
southeast Alaska primitive environment. Those recreation activities currently provided for include pic-
nicking, camping, hunting, salt and freshwater fishing, hiking, boating, nature study, photography, and
many others. By providing different kinds of recreational settings and accommodating different types
and styles of recreational use, we hope to provide people the opportunity for various kinds of experi-
ences.
The added recreation opportunities referred to in the DEIS are potential opportunities. Currently, the
project area is accessible by boat or air travel which may not change with the completion of the project.
The consequences of increased access to the project area should be evaluated at the time the access
is made available.
We agree that the area of highest recreational, wildlife, etc. values probably are found in the Upper
George Inlet-Leask Cove-Salt Lagoon Salt Creek area These areas have values associated with them
from salt water access and roaded access. The preferred alternative preserves any potential recreation
site and sets aside large blocks of timber for wildlife. Stream protection reflects the current TTRA
mandate. We do not have base line data with which to do an economic comparison with the timber
resource, however, we feel that protection of these areas is important and our selection of Alternative
5 as the preferred alternative reflects this.
Comment 9:
In the financial analysis, the mid-market pond log values are defined as including the end product of
pulp. But utility-grade logs are not counted in the financial analysis summary. This discrepancy should
be addressed.
Response 9: (paraphrased)
These values include utility-grade logs. The final products in this analysis are not confined to pulp, but
include lumber and cants of hemlock and spruce.
Comment 10: (paraphrased)
We feel that the Leask Creek watershed should be included in the table on page 30, chapter 3 as an
important fish producer. Only Alternative 5 recognizes the importance.
Response 10:
You are correct. We have included this stream on the above mentioned table. Leask Creek was
recognized for its importance in Alternative 5 which is the alternative selected in the ROD. The informa-
tion on Leask Creek was not included as no direct impact from land management on National Forest
Service land occurs with any of the action alternatives. For comparison purposes, the amount of habitat
contained in Leask Creek has been included in the above mentioned Table. At this time, no changes
in Leask Creek habitat or anadromous fish populations are expected.
Comment 11:(paraphrased)
We are concerned with the sensitive soils above Salt Creek and the projected loss to coho production.
There appears to be a mistake or problems with the analysis on page 2-20. There appears to be
overvaluing timber from those harvest units at the expense of fisheries.
Response 1 1 :
The reduction in coho habitat is projected for the whole planning area rather than just the Salt Creek
drainage. The reduction of long term coho habitat capability was based on removing some trees within
the large organic debris (an important factor in the formation of juvenile coho over winter habitat) in some
of the less critical stream reaches. Examples of this would be 25 wide buffer zones on small streams
(less than 1 5 feet wide) that are not highly dependent on adjacent trees to form ponds the juvenile
coho’s use during the winter. Our modeling showed a small reduction in the habitat capability in these
streams. Also, the figures listed for Alternative 3 on page xxi is in error. It should have been 0.9% (DEIS
Chapter 4, page 51). The relative difference between the two alternatives is nill (0.9 for Alternative 3 and
0.7 for Alternative 5).
Finally, since the implementation of TTRRA, anadromous stream buffer requirements will apply to
Shelter Cove units, the buffers are expanded to include all the large organic debris recruitment area,
and thus the modeling effects no longer apply. There is a 1 00 feet minimum on all anadromous streams.
Comment 12: (paraphrased)
We urge that every attempt be made to provide windfirm buffer zones.
Response 12:
Your concern is well founded and we will do our upmost to insure windfirm buffer zones.
Comment 13: (paraphrased)
We do not think the mitigation of a fishway at Salt Creek is adequate to the general harm that will be
done by timber harvest in this portion of the project area. Impacts of Leask Creek have not been
considered, but should be.
Response 13:
We feel the mitigation will be effective. See response 9 and 10 regarding impacts to Leask Creek.
Comment 14: (paraphrased)
We feel the area of Upper George Inlet-Leask Cove-Salt Salt-Creek are of high importance. Alternative
5 is the only action alternative that responds adequately to this importance.
Response 14:
Alternative 5 is the alternative selected in the ROD.
Comment 15: (paraphrased)
We are encouraged to see the Forest Service embracing the concept of old growth blocks. We are
confident about Alternative 5, but less so with Alternative 3. The roading proposed in Alternative 3 will,
when linked to Ketchikan, further reduce this block’s value by facilitating human access and predation.
If an old-growth block policy is to be adopted, it should be implemented so that it will actually accomplish
its task.
Response 15:
Our task in developing and EIS is to offer a reasonable range of alternatives. Roading through the
old-growth block as displayed in Alternative 3 does just this. The Forest Service manages multiple
resources, not just wildlife. The road as displayed in Alternative 3 accesses other resources, in this case
timber and potential recreation access to Salt Lakes.
Comment 16: (paraphrased)
We see danger in the fact that no cumulative impacts have been done for wildlife beyond the next 1 0
years. This analysis is insufficient.
Response 16:
We agree. This has been corrected in the FEIS.
Comment 17: (paraphrased)
We applaud the Forest Service’s conscientious search for, and protective posture towards, cultural
sites.
Response 17:
Thank you.
Comment 18: (paraphrased)
The Salt Lagoon ought to be recognized as a special area as well as that portion of national forest
bordering the eastern edge of the state land north of Leask Cove, and running northward to the Naha.
Response 18:
This is a subject that must be addressed in the TLMP revision. Make your views known to the TLMP team.
Comment 19: (paraphrased)
Any reading in VCU’s 748 and the north end of 747, because of their rich wildlife values, should not be
implemented before the results of the reading study are know so valuable resources will not be lost.
Response 19:
Shelter Cove precludes no road option. Roads that access timber near Naha would be needed in any
case to access suitable and operable commercial forest land.
Comment 20: (paraphrased)
In the context of a plan of operation that ensured the long-term viability of Alternative 5, that depicted
long-term impacts to all non-commodity resources and ensured their sustained yield, we would support
that alternative, with some provisions such as the relocation of harvest units 747-23, 24, and 25 and road
link to Ketchikan based on the ADOT/PF study.
Response 20:
Thank you. We selected Alternative 5.
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
re: Shelter Cove DEIS
Steve Ambrose:
Bill Rotecki ■ .
Box 7738 i Rb ^ 1
Ketchikan, Alaska \ 1 ^ '
February 1, 1991 : •
7 • 8 rn^rr;; \ ,f' \
After attending a public informational meeting and reviewing the?
Shelter Cove DEIS I would like to make these comments:
I am extremely pleased to see the preparation of Alternative 5,
which looks to me like it could actually accomplish sustained
yield of ALL the forest resources without dominance of any one
over another. Unfortunately, since the plan does not extend its~N
analysis of impacts through the rotation it is not possible to ( 2.
say whether any alternative, even alternative' 5, will be
successful at accomplishing this goal at the end of the rotation.
1 am disappointed by the lack of a true recreational alternative.
This is especially disappointing for an area that has already
been identified as having extremely high recreational value and
potential. Alternative 3 is not. a "recreational alternative".
It is a moderate timber harvest alternative with a couple of
added design parameters which do not maximize, and may even harm
recreational uses. The public was told at the informational
meeting on the 17th of January that the design parameters to make
it a recreational alternative were: less visible clearcuts, and
maximize roaded access. Given the economics of forestry (that
road construction is a major cost of harvesting timber), and
looking at past forest plans, AS LONG AS WE LACK THE EXTENSION OF
THIS PLAN THROUGH THE ROTATION, we can only assume that this
"recreational " alternative will look the same as any "timber
alternative" by the end of the rotation. I strongly disagree
with the idea that what the public wants for "recreation" are
more roads to drive on, when all those roads do is go through
clearcuts and end in clearcuts. Roads in and of themselves are
not recreation. Recreation is having a place to go to, and roads
are simply a means to get there. Without seeing the end of
rotation consequences, a road could just as easily DESTROY the
recreational opportunities as access them.
Roading into the Naha in inexcusable for timber harvest. Even if
it were determined that the best mainland link is through the
Naha and that arterial road was already built, those little haul
roads through the Naha would still be inexcusable.
Removing the reading alternatives to Ketchikan from the plan has
done no one any great service, and has possibly hidden numerous
impacts of the proposed action. It is probably the largest
single item on the minds of the borough assembly and the city
council in their support of any alternative, and likely so for a
large number of the public. Yet, the removal of that part of the
plan removes our tools to analyze the DEIS in that light.
I am extremely disappointed in the effort that was taken to
communicate this plan to a select section of the public (public
meeting with telephone invitations only to a select group on Jan
17th 1991). At the time of that meeting the deadline for
comments on the plan were the 21st of January, so clearly there
was no intention of having an informational meeting with the
general public. Ignoring people who have dedicated their
personal time to comment on this plan in the past, and then
inviting a new set of people for a personal briefing sends a very
bad message to the public. It sends the message that you do not
want to tell them what you know, and you do not want to hear what
they have to say. I cannot believe that is anyone's intent, yet
as long as you fail to communicate with people who have
previously expressed interest, that is the message? that you are
sendi ng .
It is with great regret that I have included so many negative
comments about this plan. Actually I am very excited about the
positive aspects of this plan. I DG believe that there is an
acceptable multiple use plan here which considers ALL renewable
resources in the shelter cove planning area. This DEIS contains
the basis, with some serious additions, for a plan that: includes
the road up the island, that indicates impacts through the whole
alternative, that protects fish and wildlife resources, enhances
recreational opportunities for Ketchikan residents and visitors,
and supports a long term sustainable timber harvest. I am sure
that it can be done, I will do all I can to help make it happen,
and I hope that the USES feels the same.
Sincerely yours,
Bill Rotecki
Letter from Bill Rotecki
Comment 1: (paraphrased)
I am extremely pleased to see the preparation of Alternative 5, it looks like it accomplishes all the forest
resource yields without dominance of any one resource over another.
Response 1:
Thank you.
Comment 2: (paraphrased)
Unfortunately, since the plan does not extend its analysis of impacts through the rotation it is not
possible to say whether any alternative, even Alternative 5, will be successful at accomplishing this goal
at the end of the rotation.
Response 2:
The FEIS displays the cumulative effects through the rotation.
Comment 3: (paraphrased)
I am disappointed by the lack of a true recreational alternative. This is especially disappointing for an
area that has already been identified as having extremely high recreational value and potential.
Response 3:
You are not alone on this point. The need for recreational opportunity is essential. During the public
comment, a road off of Hariet Hunt was proposed for access to the Leask Lakes area. We feel this has
merit, and hope to do the analysis under a separate NEPA document. As for Shelter Cove, potential
recreation sites are protected in the preferred alternative.
Comment 4: (paraphrased)
I strongly disagree with the idea that the public wants for •recreation* are more roads to drive on, when
all those roads do is go through clearcuts and end in clearcuts. A road could just as easily DESTROY
the recreational opportunities as access them.
Response 4:
The main routes in the preferred alternative (from Shelter Cove and around Saddle Lakes to Salt Lagoon)
are not exclusively associated with timber harvest, though harvest of timber will pay for the construction
of the majority of roads within the project area. Care was taken during planning that potential recreation-
al sites be protected.
Commnet 5: (parpahrased)
Roading into the Naha is inexcusable for timber harvest.
Response 5:
This roading is not reflected in the FEIS.
Comment 6: (paraphrased)
Removing the roading alternatives has done no one any great service, and has possibly hidden
numerous impacts. Roading is probably the largest single item on the minds of the borough assembly
and the city council in their support of any alternative, and likely so for a large number of the public.
Response 6:
We agree. These issues will be addressed after the corridor study is completed.
Comment 7: (paraphrased)
Meetings were made by telephone invitations only to a select group on January 1 7th.
Response 7:
This was not our intent, and we know not to try this again. We wanted a representative ■sample’ of
opinion in the community. Additional meetings were scheduled and the comment period was extended
to deal with this concern
Comment 8: (paraphrased)
I do believe that there is an acceptable multiple use plan here which considers ALL renewable resources
in the Shelter Cove planning area.
Response 8:
We believe Alternative 5 does this.
1/31/91
Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan ttk 99901
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Pis the comment deadline aproaches on the Shelter
wish to submit comments for your cons i derat i on as you
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Cove DEIS, T
p r e p a r e t h e
1. The Shelter Cove arid Georgs inlet areas are
areas f o r the citizens o f K e t c h i k an. With o u r
extremely valuable
s 1 and e >; i st ence ,
this area is the logical area for development of future high
quality forest recreation. I am not referring to driving to or
through clearcurs. I am referring to recreating in actual forests
which have trees which have bean allowed to grow bo an elderiv ace.
I am referring to camp inn, berry picking, fish inn. hi kino,
picknicing, bird and wildlife viewing, boating- enjoying silence
ana clean air-, cross country ski inq. and enjoying t t o? visual
b e a u t ies o f ex:- a n s as c f u n c u t f o r e s t .
3. I object to a recent public survey being misused
Ketchikan residents want to recreate in legged areas
Lurin’ s letter to reviewers of the DEI 9, ha mentions
connection with a discussion of the alleged "Rscreat
h
imply that
n kfr.
survey ir
~ 1 1 ewr.-at i ve " . On the survey- there was a quest ion about if oeocl s
would like to he able to recreate i.n loused areas-,. The maiority of
•. -• a s r o n n e nor. s r> a j d yes. N c o n e a s k a c i f p e o p i e w o u 1 d p v '• a f e r t o
retreat a in nor it-cgeci areas or i r c i . e v wouic . i i<e to have at -.ease
one non— logged area to drive to. The Question was like asking ,
"If the Plaza Port West Mall were destroyed by an earthquake, would
you like to be aoie to park in the open space remaining?"
Undoubtedly, that question would get yes answers also. It
certainly would not logically follow that people in any way
approved of providing parking by destroying the Mall,
Please consider managing the Shelter Cove /George Inlet area in
a manner which provides for high quality forest recreation and not
low quality Sunday drives through logged areas.
Last summer our family carnped our way through Canada and tns
western U. S. It is almost impossible to find places to drive to
and camp that haven’t been severely altered by logging. The
businesses in this area could really capitalize on the tourist
dollars from oeople who could drive just a short distance out of
Ketchikan and see uncut forest. The DEIS does not adequately
address the long term recreational and economic needs of the
Ketchikan area.
3. Page v (and others) :
Alternative 1 is vastly under— represent ed in this document.
There is no map of (Alternate 1 and no real consideration of the
high values present in this alternative. (At the public meeting,
was extremely difficult to ask questions or make sense of the
effects of (Alternatives £—6 without seeing Alternative 1 (what
exists now and what would exist in 5 years) . The forest service
presenter indicated that there was no need for a map of Alternat ive
1 (alongside the huge maps of the other alternatives) because it
would just be sort of blank aand show lakes and rivers and that
kind of stuff. It appears that the forest service is viewing
what’s out there now as a blank slate which really doesn’t have
much of interest or value to the public until we "spend" part of
the resource to produce some cash flow.
Alternative 1 should be seriously considered. At the end of
years, under this option, we the people of the U. S. would have
1. valuable timber.
3. valuable wildlife habitat.
3. valuable forest (helping to cleanse the air, etc. )
4. a rare tourist attraction.
Alternative 1 is like having a high interest savings account
which can be used while if appreciates in value.
Page v— — Regarding planning for forest use:
After attending a public information meeting. 1 was left with
t hi e c o n c 1 usion thac no long ter rn rn a n a g e m e n c p 1 a n h as been d e v e 1 o p s d
for this area. It is inconceivable to me that the forest service
could plan harvests during the coming 5 year period without having
a larger picture of the next 100 to 500 years. It is almost
impossible for the public to figure out the env i rcnment a 1
consequences because there appears to be no plan past 5 years.
0 p t i o n s be i n ti c c* n side r ed see m t o i n c .1 u d e s
1, cut most of the operable timber in this area during the
next 5 years. (If chat’s the case, then the proposed economic
benefit of 35—73 jobs annually for 5 years (pg. 43) works out to
about 5 jobs a year if this area oft he forest were managed as a
renewable resource) .
5. cut lots of the harvest able timber in the next 5 years but
.1 s a v a s o rn a o .1 d q r o v* ; t h r e t a n t i on a r e a s but ho p s c o h a r v s s t t h e rn
a f t e > "• t In e 5 y e a r s .
If no long term (minimum 100 year) management a.< >d harvest p 1 an
has been developed, then no harvest i ng should occur. ‘ ' 'w e ’ 11 cut
this stuff now and go somewhere else later" is too general. It’s
time to say specifically whars and when harvest will occur or else
stop harvesting and figure out what there is and how to manage it
on a sustainable yaiid basis.
4.
Ait ernat i ve
should not De called a Recreat ion/Visual
alt ernat i ve .
A o r ci p a r recreat i o r
ernat i ve should be added — one
in which the high value of the uncut forest is ac k now 1 ed g ed .
Ideally, reads would be put to limited recreational areas with no
logging at all occuring. Rea 1 i st i ca 1 1 y , roads would be put in
with the specific purpose of getting to high value recreation areas
(uncut) and these roads might be paid for by limited timber
harvest s.
Chapter 4, pg. 43:
Socio-economic benefits of A 1 t ernat i ves £—6 are vastly overstated.
Could you have an objective person look at those figures again in
relation to other figures in the document? There’s some things
that don’t match up. Start with the wages and
federal tax amounts (total of approx. 17, 000, 000, ) . Add in profits
and expenses (other than wages) — some amount of mi 11 ions (10 to
30??). All that money’s coming from somewhere — presumably
from selling off the trees. Does that mean the trees harvested in
the next 5 years from this area are worth upwards of$ 30,000,000 ?-
Also, the statement, "Alternative 1, which does not schedule
harvest activity, would not provide the benefits described above"
should be changed to indicate that while the economic benefit may
not occur during the 5 yr. period, at the end of the 5 yr. period
the economic value of the area would be millions of dollars higher
than in Alternative £—6. Plus add the economic benefits from
people actually being able to drive to an uncut area of the
National Forest (if the-? road from Ketchikan goes in).
Pg . AS — The words "forest users" should be changed to tree farmers.
Japanese timber executives, or loggers. The idea that cutting old
growth in this area close to Ketchikan is socially or economically
beneficial to "forest users" in the long term is not true. Turning
the area into a tree farm certainly is the economic choice for
tree— farmers , pulp investors, etc. but not the socio— economical ly
beneficial choice of all forest users.
Please maintain all ex
r eoarri i n ci t h e e x t r e m e v a 1 u e
Fisheries, wildlife, cultur
Salt La g o o n , U p p e r Geor q a I n 1 e
Protect d lease.
w h o w o r i-c a d o n t h i s d o c u rn a n t
o i ncers i y ,
Mar q a r ec Li a d o y
P. G. E-ox 373S
K e t c h i k a n h K 3 r
H j
■
Letter from Margaret Clabby
Comment 1: (paraphrased)
The Shelter Cove and George Inlet areas are extremely valuable areas for the citizens of Ketchikan.
Response 1:
We agree.
Comment 2: (paraphrased)
I object to a recent public survey being misused to imply that Ketchikan residents want to recreate in
logging areas. Please consider managing the Shelter Cove/George Inlet area in a manner which
provides for high quality forest recreation and not low quality Sunday drives through logged areas.
Response 2:
We do not feel we misused the study you refer to. We feel that the preferred alternative retains potential
recreation sites. There is logging associated, yes, but logging provides the roads for access to recre-
ation areas.
Comment 3: (paraphrased)
Alternative 1 is vastly under-represented in this document. It is extremely difficult to make sense of the
effects of Alternative 2-6 without seeing Alternative 1 .
Response 3:
Alternative 1 is displayed throughout Chapter 4 of the document. Chapter 3 displays what the affected
environment is and gives an indepth analysis of what exists now. Your point regarding a map showing
the project site as is, is a fine idea. This map was displayed at numerous public meetings and we
appreciate you bringing it to our attention.
Comment 4: (paraphrased)
Regarding planning for forest use: I was left with the conclusion that no long term management plan
has been developed for this area. It is almost impossible for the public to figure out the environmental
consequences because there appears to be no plan past 5 years.
Response 4:
The Shelter Cove FEIS has a life of about 5 years, this is because management if an area is not static.
For example, the resource inventory of area may be improved, management direction may change and
public interest may change. Because of these types of changes we feel that planning site specific
activities should not be carried out too far into the future. However, the cumulative effect of an individual
project is projected out. In the Shelter Cove project area, the cumulative effects were carried out to the
year 2060. Any future project will require public involvement and a new NEPA document so management
will reflect the concerns of the public and reflect current management direction.
Comment 5: (paraphrased)
Alternative 3 should not be called a Recreation/Visual alternative.
Also, the statement, 'Alternative 1, which does not schedule harvest activity would not provide the
benefits described above' should be changed to indicate what the economic benefits may not occur
during the 5 yr. etc.
Response 5:
The ID Team felt the Alternative 3 offered many recreational opportunities. Because of the smaller, widely
dispersed harvest units, the visual resources are emphasized.
The economic benefits you refer to are benefits from the harvest of trees and those benefits associated
with the forest industry.
Comment 6: (paraphrased)
The words forest users’ should be changed to tree farmers, Japanese timber executives, or loggers.
Response 6:
There are many users of the forest. The ones you mentioned are but a few. The Forest Service manages
for multiple resource use. This being the case, not all resources or activities can always use the same
portion of land. What we do is to develop our plans using an interdisciplinary approach, so we can
protect areas of concern and direct our management activities to do so.
Comment 7: (paraphrased)
Fisheries, wildlife, cultural, subsistence: Please maintain all existing language in the document regard-
ing the extreme value of these resources.
Response 7:
Thank you. We will.
Steve Ambrose, Forest Supervisor
Shelter Cover- Sale EIS Team
Tong ass National Forest
Dear Steve,
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have heard
Shelter Cove DEIS
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for the record.
, though, I think that the team that worked on this EIS has
made very commendable progress in making document that is
understandable and offers a much wider range of perspective than
the U3FS has entertained in the past. Alternative 5 as presented J
, i n d e e d , sh o w s t h e Peg i n n i n g s o f a "Me w
I am pleased to see it taken seriously and hope to
i n the doc u m e n t-
Perspective" i
see future DEIS’ s present even wider perspectives.
My first and most important criticism of this DEIS is that it
is being presented before studies of the reading alternatives for
and the
is plainly
Area, and
I
2
Revilla Island have been completed by the Borough, State
Forest Service. The DEIS makes no claim to this, but it
at the forefront of public concerns for the Shelter Cove
you will be getting a large amount of comment from this
perspective. In order to do a legal EIS on this project i sugges
that you go back and address the road as thoroughly as you have
done other issues. The Forest Service should revive something like
the Revilla plan to address this issue and other issues that fall
between the cracks in TLMP and sale EIS’s. The Two step process is
not adequate for the public involvement in planning forest land use
policies. It is two giant steps backwards, as far as I can see.
Another objection is that the DEIS makes no mention of long
term plans and effects. In the public meetings, the planners
indicated that this is only the first of several entries into the
Shelter Cove Area. This is not mentioned in the DEIS and it is
very important to me to see what will happen to the Shelter Cove
area throughout the rotation. Since your foresters made this plan
based on the assumption that you would enter the area again,
according to NEPP this must be addressed in the EIS along with
cumulative impacts.
Ps for the various alternatives; I find the alts. £, 4 and 6 to
be the same old single— use management of the forest for' the
extraction of timber. These are only alternatives that vary the
amount of effort going into hiding and disguising the fact that you
are ignoring all other resource values. Alternative 3 is the
Reading Plternat ive. It is designed to please those who want a
road as soon as possible and as long as possible. This is not a
recreation alternative. It makes no pretense of offering people
recreation opportunity. The presentation of this option is very
misleading and does not conform to NEPP guidelines. The basic
underlying assumption that this road system will be connected to
Ketchikan’s, is skirted. Pnd the issues of that connection and how
different options fit into it, were talked about to. the small
groups at the informational meetings but are not available in the
DEIS. It is plain that the road crossing through the LUD II lands
of the Naha watershed is just a dangling carrot to interest people
in a connection. The amount of acreage accessed by that leg of the f
road is quite small, yet because of the failure of the DEIS to
provide an analysis of the road options, you will be getting lots
of input based on speculation and not on any data. I strongly "N
object to building that section of road now. The timber value is
M
not sufficient to warrant the road. The wildlife and habitat
values are high enough to make that road have a significant impact
and there is no .justification to build that section of road to
connect to the Ketchikan road system until such time as the reading
alternatives have been thoroughly explored.
There is no explanation of why this area must be cut, nor of
why the old— growth retention blocks as laid out in Alternative 5
are cut in every other alternative except 1. If the plan is to
come in with several more entries during the rotation, and the
retention is to stay retention, why must this retention be cut now
in any of the alternatives? The same question needs to be
addressed for alternative 5. Further, in talking with you and
District Ranger, Segovia last night, it was obvious that you did
not want these retention blocks or any other areas designated as
non— harvest areas. Yet these blocks must come out of the timber
base if they are actually to be retained. I find it very
disturbing that you are still arguing for the flexability to cut
retention, despite USFS abuses of the past. I want to see these
areas retained as old growth, not just saved until the next entry.
I also would like to see the units #£3, £4 and £5 removed from
Alternative 5. These are objectionably placed and will detract
from future recreational value and use of the area.
For me this area is very important. As a boater, hiker and
camper in the Ketchikan area, I visit Upper George Inlet
regularly. We often see bear, deer, otter and waterfowl there. I
Salt Lagoon and
my wife and I
not cornpatable
I shudder at
You have a
all resources.
care very strongly about the wildlife values of the
that watershed. As caretakers at Harriet Hunt Lake
frequently saw wolves. These are values which are
with logging the old growth areas in that watershed
the damage already done by the native corporations,
mandate to manage the forest for sustained yield of
I think that few would brag about the great management of the
Tongass up to this point. Please put things into a "Totally New
Perspective" and do what congress asked you to do.
Thank you for listening. I eagerly await you responses to my
concerns.
Sincerely
Eric Hummel
PO Box 5736
Ketchikan, AK
99901
Letter from Eric Hummel
Comment 1: (paraphrased)
Alternative 5 as presented indeed shows the beginnings of a ‘New Perspective'. I am pleased to see
it taken seriously and hope to see future DEIS’s presented even wider perspectives.
Response 1:
Thank you.
Comment 2: (paraphrased)
My first and most important criticism of this DEIS is that it is being presented before studies of the
roading alternatives for Revilla Island have been completed by the Borough. In order to do a legal EIS
on this project I suggest that you go back and address the road.
Response 2:
No options are precluded in the ROD.
Comment 3: (paraphrased)
Another objection is that the DEIS makes no mention of long term plans and effects. According to NEPA
this must be addressed in the EIS along with cumulative impacts.
Response 3:
This concern is reflected in the FEIS.
Comment 4: (paraphrased)
I strongly object to building the section of road now. The timber value is not sufficient to warrant the road.
The wildlife values are high enough to make the road have a significant impact.
Response 4:
The road in the ROD does not preclude any options currently under study. Impact to wildlife, fish and
visual resources are minimized by unit placement.
Comment 5: (paraphrased)
There is no explanation of why this area must be cut, nor of why the old-growth retention blocks as laid
out in Alternative 5 are cut in every other alternative except 1 .
Response 5;
This is done in the FEIS.
Comment 6. (paraphrased)
I want to see these areas retained as old growth, not just saved until the next entry. I also would like
to see the units #23, 24 and 25 removed from Alternative 5.
Response 6:
The cumulative effects displayed in Chapter 4 retain the old growth blocks through the rotation. Any
change in retention will require public involvement and a new NEPA document.
We feel that units 23, 24 and 25 will be protected by the mitigation measures prescribed.
.
.
.
-
.
'
■
OFFICE OF THE MAYOR
K ETCH IK A X GATEWAY HOROUGII
January 18, 1991
Mr. Steven T. Segovia
Ketchikan District Ranger
3031 Tongass Ave
Ketchikan, AK 99901
Re: Shelter Cove DEIS
Dear Steve:
;I44 FHOXT ST It FET
KETCIIIKAX. ALASKA 9990 1
(907) 229-0605
With reference to our conversation the other evening concerning the
preferred alternative of a road and transmission line corridor In this DEIS, I
am enclosing a letter from the Ketchikan Public Utilities where they justify
a wide corridor for access and maintenance.
In line with your past Revilla road studies, it is absolutely essential that f I
you reserve the corridor all the way through to the access point of the Tyee j
Lake power.
Even if we could start construction on the proposed intertie
immediately, Ketchikan will be pushing to the limit the Swan Lake
production by the time we could draw the surplus power from Tyee
Thank you for your consideration.
5incepeV/T~?
Ralph M. Bartholomew, Mayor
xc: Forest Service Supervisor, Ketchikan
Mike Barton, Regional Director USFS
Office/Borough Clerk TEL:907-225-7282
Jan 16,91
14 : 13 No .003 P .01,
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TELEPHONE 807-22(
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January 16, 1991
MUNICIPALLY OWNED
ELECTRIC TELEPHONE WATER
Mayor Ralph Bartholomew and the Borough Assembly
c/o Borough Manager David Crow
344 Front Street
Ketchikan, Alaska 99901
•>
The Honorable Ralph Bartholomew: , ;
>
Late last year the Assembly authorized the expenditure of $100,000 to fund the feasibility
of constructing a road access from central Ketchikan to transverse the island to the east
toward Behm Canal to coincide with the development of an electrical intertie between the
Swan Lake Hydroelectric facility to the Lake Tyee Hydroelectric Facility operated by the
Thomas Bay Power Authority belonging to Petersburg and Wrangell. J 1
The Alaska Energy Authority has commissioned the engineering firm of R.W. Beck to
prepare an economic feasibility study for this potential intertie. I am enclosing a copy of
that report for your review. To assist you in your review, I am also enclosing my ■
comments as a result of my review of the document. |j
YOUR ASSISTANCE IS NEEDED NOW, EITHER IN THE FORM OF A JOINT i
RESOLUTION WITH THE KETCHIKAN CITY COUNCIL OR IN A MANNER YOU DEEM |
APPROPRIATE TO ACCOMPLISH THE FOLLOWING:
1 . Reroute the transmission line to an area most engaging to facilitate a road corridor
that would coincide with the transmission line. This would allow access to the
transmission line and provide the right-of-way for a future road to be built in the
same right-of-way. 1
2. Provide for a right of way that is at least 200-500 feet in width. |J
3. Allow or authorize AEA to restudy the projected transmission line to provide data
on rerouting the transmission line to include a transportation corridor and the cost
of such a route, which would be most advantageous to allow for a transportation/
utility corridor. ' .
I cannot offer to fund this Rerouting Study insomuch that the funds pledged to do that
work would come from the $100,000 authorized by the Borough Assembly, and therefore «
it would be appropriate to have that offer come from the Borough Assembly. |
ice/Borough Clerk
TEL: 907-225-7282
Jan 16,91
14:14 No .003 P .02
Honorable Ralph Bartholomew and Borough Assembly
January 16, 1991
PagB 2
Thank you for your consideration in this matter.
Best regards,
KETCHIKAN PUBLIC UTILITIES
Thomas W. Stevenson
General Manager
TWS:LLH
Enclosures
cc: Mayor & City Council
Brent Petrie, AEA
007-D5.2
Letter from Ralph M. Bartholomew, Mayor of Ketchikan Gateway Borough
Comment: (paraphrased)
In line with your past Revilla road studies, it is absolutely essential that you reserve the corridor all the
way through to the access point of the Tyee Lake power.
Response:
In reviewing your concerns relating to power transmission corridors, I am assuming you are referring
to areas outside the Shelter Cove project area The transmission corridor is already in place and requires
no additional right-of-way. From your statement, I believe you are relating to the Tyee intertie which runs
from Swan Lake northward. This is not in the project area.
KETCHIKAN GATEWA Y BOROUGH
344 Front Street
Ketcl
February 15, 1991
Stephen Ambrose
Acting Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, AK 99901
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Subject: 1950 Shelter Cove Draft Environmental Impact Statement
(Alternative 7)
Dear Mr. Ambrose:
The Ketchikan Gateway Borough has previously commented on the
Shelter Cove Draft Environmental Impact Statement, and has
supported the alternative described as Alternative 3 . We believed
that alternative provided the best match between the objectives
expressed in the Environmental Impact Statement and the community
values that were listed in our correspondence of January 14, 1991.
In that letter we stipulated that the primary objectives of the
Borough, as related to this Environmental Impact Statement
included:
* The retention and continued viability of a principal
economic base — the timber industry.
* Access to and use of significant recreation areas.
* The ability to create a road system that can eventually
be upgraded to an acceptable public access standard for
an inter/intra island road.
* The minimization of impact upon habitat resources, but
within the context of meeting the previously stated
objectives .
Based upon these objectives, the Borough determined that
Alternative 3, the "Recreation/Visual Resource Emphasis
Alternative" was the most reasonable, viable alternative to meet
the aforementioned objectives.
Stephen Ambrose
Page 2
February 15, 1991
Since that time, staff of the Forest Service have developed a new
alternative described as "Alternative 7 " . In this alternative wood
gathering areas, involving areas of timber sale and harvest, were
stipulated for Lake Harriet Hunt and the Brown Mountain area. In
addition, within the study area of the Environmental Impact
Statement proper, this alternative provided for the retention of
old growth forest in the area immediately east of the LUD 2 area.
The effect of the retention of the old growth timber is, as
described by the Forest Service personnel, to essentially eliminate
about two miles of access road that would be developed to main line
public access standards, and to eliminate access to certain lakes
that were considered by the Borough to be important for
recreational purposes. As you are aware, the Borough, as well as
the City of Ketchikan, strongly support the need for an inter/intra
island road, and particularly the concept of the inclusion for the
eventual development of such a facility, to the extent practical,
within the context of the Shelter Cove timber sale area.
The borough objects to the inclusion of the two areas outside the J
Shelter Cove EIS boundary. Specifically, we believe that the /
inclusion of the Harriet Hunt area at this time would be \
inappropriate since there is insufficient data with which to )
evaluate the environmental effects of this area in the
Environmental Impact Statement, because the process to this date
has not carefully considered these areas, and because the
development of a road to the north of Lake Harriet Hunt would be
inappropriate given the possibility of a state park in that area
and the ongoing negotiations between the State and the Cape Fox
Corporation regarding a land exchange.
The Borough believes, and we were assured that the option described
as Alternative 3 , was a viable approach to timber sale/harvest
within the Shelter Cove area. We continue to support this
alternative. This alternative most effectively meets the needs of
roaded access, recreational opportunity, and the creation of a more
comprehensive roaded system than would be provided under the other
alternatives .
The Ketchikan Gateway Borough believes that the U.S. Forest Service
decision regarding these timber sales within the Shelter Cove area
are absolutely essential in their configuration and function to the
creation of roaded access and to the establishment of access to
recreational areas. We have hoped, and continue to hope, that the
Forest Service will support widely held community objectives
related to recreation and roaded access and would work in a
cooperative fashion to support those community objectives in its
timber sale program through the selection of Alternative 3.
The Borough is not opposed to the minimization or reduction of
harvest areas in the road corridor accessing the western part of
the timber sale area, but feels that the roaded system created in
this area is important to the development of access to recreational
Stephen Ambrose
Page 3
February 15, 1991
facilities and to other important uses of this area. We trust that
the Forest Service will continue to support community objectives in
its timber sale program.
Sincerely,
David G . Crow
Borough Manager
DGC/BGP/b js
Letter From David G. Crow Borough Manager, Ketchikan Gateway Borough
Comment: (paraphrased)
The borough objects to the inclusion of the two areas outside the Shelter Cove EIS boundary. Specifical-
ly, we believe that the inclusion of Harriet Hunt area at this time would be inappropriate since there is
insufficient data with which to evaluate the environmental effects of this area in the EIS.
Response:
The area you mention is within the Shelter Cove project area. However, the harvest units were not
displayed in the DEIS and as a result, will not appear in the FEIS. The project we feel is a valid one and
we are considering it. This project would be handled under a separate NEPA document to allow for
public input.
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OFFICE OF THE GOVERNOR
OFFICE OF MANAGEMENT AND BUDGET /
DIVISION OF GOVERNMENTAL COORDINATION
SOUTHEAST REGIONAL OFFICE
431 NORTH FRANKUN
RO. BOX AW, SUITE 101
JUNEAU, ALASKA mil-0165
PHONE; (907) 405-3562
Mr. Steve Ambrose
Acting Forest Supervisor
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Dear Mr. Ambrose:
SUBJECT:
SOUTHCENTRAL REGIONAL OFFICE
3601 O' STREET
SUITE 370
ANCHORAGE, ALASKA 99603-6930
PHONE: (907) 6 61-6131
March 12, 1991
WALTER J. HICKEL, GOVERNOR
CENTRAL OFFICE
RO. BOX AW
JUNEAU, ALASKA 99811-0165
PHONE: (907) 465-3562
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Shelter Cove- Draft Environmental Impact Statement
State I.D. No. AK901218-05J
The State appreciates this opportunity to review and comment on the
Draft Environmental Impact Statement (DEIS) for the Shelter Cove
project area and offer a consolidated response. Since a preferred
alternative was not identified, these comments are presented under
NEPA authorities and address a broad range of issues associated
with the various alternatives. We will process the Final
Management Area Plan, as identified in the FEIS preferred
alternative, for consistency with the standards of the Alaska
Coastal Management Program (ACMP) pursuant to 6 AAC 80. We
appreciate the efforts undertaken by your staff to provide
additional detailed briefing to the State, and your willingness to
allow the additional time necessary to develop this consolidated
response.
The DEIS proposes alternative ways of harvesting between 61.8 and
95.6 million board feet (mmbf) of timber during the next five years
in the Shelter Cove/George Inlet area for the independent sale
program on the Ketchikan Ranger District. The DEIS describes five
alternatives which provide different combinations of resource
outputs and spatial locations of harvest units and associated road
requirements. A no-action alternative is also presented. An
additional alternative (alternative 7) , not described in the DEIS,
emphasizes a management alternative integrating some of the public
comments received to date.
The State appreciates the additional analysis efforts undertaken
and many of the concerns that the Forest Service has considered in
the development of Alternative 7. It is clear that several
Mr. Steve Ambrose
2
March 12, 1591
alternatives have been favored by different interests in both the
State and the Ketchikan area. We^generaiiy^support^ali^iTfavorTinany-
of-the-.concepts ^puttforth 'in;_al^ir native J7 ^lnclud'i^Ta^T^^rTTKT,^
- ensuring an economically viable timber sale;
deferring all timber harvest road construction requirements
through the Naha LUD II management arsa;
maintenance of important old-growth wildlife habitat
maintaining a range of management options over the rotation;
- efforts to incorporate public comment into the DEIS.
However we have some concerns regarding other aspects of
Alternative 7 if it were designated the preferred alternative. We
suggest AXternative^T^Tform—the-rbasis^of^a^modlf led'tprefermed
alternative analysis and strongly ^urge" your consideration of
additional specific elements to this alternative.
Importantly, the State recommends that Alternative 7 be~mod±f ied~to / j
emphasize , roaded recreational opportunities jin~the;SarltrLake~~area^ )
Thl^^ecommendatipn^s ^ieari^suppbrted-by^the^i^of-imporAnt "
fish and wildlife habitat values, high recreational values and
strong community support for roaded recreational access to the Salt
lake area, proximity to Ketchikan, well planned access
opportunities to adjacent State lands at George Inlet, and moderate
timber values. To accomplish a roaded recreational emphasis in
this area we encourage the Forest Service to consider at a minimum;
1) additional analysis to provide roaded recreational access
to this area, amortizing road costs, either wholly or in part,
by increasing timber harvest in other locations within the
project area; ^
2) / more closely approximate harvest unit access to units 41,
42, 43, and 44 as displayed in Alternative 3, while minimizing
timber harvest objectives in this area to fully compliment the
roaded recreational emphasis.
Alternative 7 lacks sufficient access alternatives analysis to
defer harvest units 44, 45, 46, 47, 48, 49, 50 and 51 as displayed
in Alternative 3. The State understands that decisions to defer
these units in the Alternative 7 analysis reflect, in large part,
specific restrictions for timber harvest related road development
in designated LUD II areas and expressed fish and wildlife habitat
concerns in the upper George Inlet area. The State recommends that
additional access analysis be undertaken to reliably assess non LUD
II road access requirements to the above named harvest units or to
a substitute viable harvest regime in this area. Tft i't^a
shOUTd^adc , ,
Kei^ch^ansyoadSsvs’tem^ Such ""'ah' eastward alignment, although"
comprrircatea Ey on-going land exchange considerations, would
compliment the community of Ketchikan's support for immediate
roaded recreational access. The objective of the recommended
additional analysis should be to emphasize eventual roaded
Mr. Steve Ambrose
3
March 12, 1991
recreation opportunities for the Ketchikan area supported by a
dispersed harvest regime that compliments this objective.
The State has identified the following principal concerns/ issues in
the review of the DEIS and each of the alternatives presented,
including alternative 7. Our comments here will attempt to
identify the potential problem areas and recommend improvements to
the alternatives analysis in the development of a preferred
alternative and FEIS;
* support timber industry needs by providing an economically
viable timber supply to the independent timber sale program. At a
minimum, the State supports timber harvest objectives which derive
a positive "mid-market 11 conversion rate and a sustainable,
economically viable timber supply to the independent timber sale
program over the life of the planning cycle. Our review of the
DEIS concludes that the timber sale economics show a positive
conversion rate for all management alternatives except Alternative
4. A comparative conversion rate should be displayed for
Alternative 7 when it is finalized.
* Defer alternative timber harvest road access requirements in the
Naha Land Use Designation II (LUD II) Management Area. Road access
requirements for harvest units displayed in Alternatives 2, 3, 4,
and 6 encroach on the Naha LUD II management area. The Naha LUD II
area is one of twelve LUD II areas recently authorized in Title II
of the Tongass Timber Reform Act. The State has raised the issue
of management activities in legislatively enacted LUD II areas to
the Forest Service (Grogan to Barton, Jan. 3, 1991) and the need
for the development of Standards and Guidelines governing
management of these protected areas to augment the relatively
limited administrative guidance of the original TLMP. ffie^state
g&gpgmendssdeferra irofTro adTa c c e s s zt ojharyest^units «whi ch^equii^a
£tfPgEIg access 'ft As stated previously, in Vupport of *mod'ffi cations
to Alternative 7, additional analysis is recommended for non LUD II
road access to harvest_unLts_dlsplavedMin, Alternative 3. THflgatatgV^
furth^^recommendsitha^lh-the^vent^the^analvsls^dict!ates^def:err£l )
0 f3^S®sfeunits L-in^this.ar ea ^.additional-Palternatives;analysis?b&^ /
und ertak^rTto^i deritif y ’equival e ntTr epT'acemeht^ tfdTtime ^approximately \
^gmmfrg) within the planning area. This volume could be derived |
through additional dispersed units or, where achievable, increased J
average unit size over the project area.
The State’s recommendation to defer road construction activities to
support timber harvest alternatives is a clearly separable issue
from other authorized management activities within LUD II
management areas. LUD II management areas as described in the
Tongass National Forest Land Management Plan, completed March 1979,
and amended Winter 1985-1986, provide that these areas be managed
Mr. Steve Ambrose
4
March 12, 1991
primarily in a roadless condition except that roads may be built to
serve authorized activities and provide forest transportation
linkages. Water and power developments, mining, mineral leasing,
and motorized and non-motorized recreation activities would be
permitted. No commercial timber hairvesting would be permitted.
The State wholly supports transportation concepts which require LUD
II access where regional transportation planning objectives and
sound engineering analysis dictate such alignments and all feasible
and prudent alternatives have been taken into consideration.
* The state recommends an alternative analysis with community'") -
roaded recreational emphasis for the Upper George Inlet, Saddle [ n"
Lakes and the Salt Lake area* The preferred alternative should
compliment the community of _ Ketchikans 1 strong support and
expressed need for additional road access, enhanced opportunities
for future roaded access to major recreational features ( Salt
Lakes, N. Saddle Lakes) in the project area, and the protection of
important fish and wildlife habitat. A community values and needs
survey of Ketchikan residents (Ketchikan Community Survey, McDowell
Group, September 1990) supports this recommendation.
* Management objectives of the preferred alternative should be
designed to emphasize roaded recreational access, while minimizing
adverse habitat effects in the Upper George Inlet, Saddle Lakes,
and the Salt Lake area. While we agree that localized habitat
values for these areas (Blocks A, C and D, respectively) rank
relatively high as displayed in the project area analysis ( Old-
Growth Areas Ranked by Wildlife species, Table 4-45) , •CHB^DEIS
qrowthTretentxonTas^presentiy^QispiayeQrinrAlternatiVQSib;ands7^are^^
necegsitrj^oTmeetttheTNEPATandrNFMA’gob j ectives ^ In certain cases
suchTHlocks may be sign if i caht^irTthe^ ma fntenance and enhancement
of deer populations and to achieve wildlife management goals.
Howeyerg^thi's^conclusion^is^not^supported^bv^the^alternatlves
analysis ft^«n^flt^^^^Ei^and?fu^her?anaiysi8^s^^gmmehded^
The recent legislative designation of the adjacent Naha LUD II area
signifies heightened public support for the maintenance of the Naha
area in protective status. The State is on record in support of
this permanent designation. The newly authorized management area
comprises approximately 31,794 acres of national forest system
lands protected in perpetuity from timber harvest. Our review
concludes that the Naha LUD II designation permanently removes
approximately 19,329 acres of commercial forest land and an
estimated 436 million board feet ( inventory volume) of timber from
the operable timber base. The Naha LUD II management area
designation should be clearly displayed on all maps accompanying
the FEIS.
Mr. Stave Ambrose
5
March 8, 1991
* Additional analysis is recommended to enhance immediate roaded
recreational opportunities within the projeot area. The DEIS and
many of the State’s recommendations describe management
alternatives which provide future roaded recreational
opportunities# as a result of project road construction originating
at Shelter Cove. *Aggnbte&^ni>aqe-2~^additionaIxanalyslaT.shauld ^
consider»extensiohi^of^the^existing Ketchikan ~ road~system-wi'tfiln > £
the^proj ect^arVa^td^support^iiMediatst^well^^anneS—^oadg'd \
re^reatfYonal^e'e'dS:.
* ^Tha^Eis^and^-pref erred ^alternative. .analy8la_should_inoorporate ? c\
the 'fisheryprotact ion-provis“ions~as‘per ^Section -103 3of-the^TongasB y
Timber Reform Act. Stream buffer requirements presented in
Appendix B do not meet the fishery protection provisions of the
Tongass Timber Reform Act. Recent TLMP amendments authorizing
forest-wide implementation of this specific provision became
effective February 4, 1991.
Thank you for this extended comment opportunity. If you have any
questions feel free to contact me^or Steve Jacoby at 465-3562.
Sincerely,
/W/c ^
Paul C. Rusanowski, PhD.
Director
cc: Jim McAllister, DNR
Daryl McRoberts , DNR
Rick Reed , DFG
Jack Gustafson, DFG
Dick Stokes, DEC
Jim Ferguson, DEC
Mike McKinnon, DOT
Charles Gasparek, DOT
Andy Peckovich, DNR
Judith Bittner, DNR
Steve Segovia, Ketchikan Ranger District
Bruce Phelps, Ketchikan Gateway Borough
The Honorable Lloyd Jones
The Honorable Robin L. Taylor
Lorraine Marshall, DGC
Steve Jacoby, DGC
Letter from Paul C. Rusanowski, Director, Division of Governmental Coordination
State of Alaska
Comment 1: (paraphrased)
The State recommends that Alternative 7 be modified to emphasize roaded recreation opportunities in
the Salt Lake area
Response 1:
This has been reflected in the ROD.
Comment 2: (paraphrased)
The State recommends that additional access analysis be undertaken to reliably access non LUD II road
access requirements to the above named harvest units or to a substitute viable harvest regime in this
area. This analysis should additionally include access opportunities from the existing Ketchikan road
system.
Response 2:
Access analysis has been undertaken for this area. We feel some roading can be reduced, but not all.
The environmentally preferred location still requires some encroachment into the LUD II.
We feel additional access from the existing Ketchikan road system is important. We feel such an
undertaking should allow for ample public input and a separate NEPA document to address the issues
and concerns.
Comment 3: (paraphrased)
The State recommends deferral of road access to harvest units which require LUD II access to harvest
units and that analysis be undertaken to identify equivalent replacement volume.
Response 3:
The ROD does not harvest units which require LUD II access. We have identified replacement volume
outside old-growth prescription areas by increasing unit size.
Comment 4: (paraphrased)
The State recommends an alternative analysis with community roaded recreation emphasis for the
Upper George Inlet, Saddle Lakes and the Salt Lake area.
Response 4:
These comments have been reflected in the ROD.
Comment 5: (paraphrased)
Management objectives of the preferred alternative should be designed to emphasize roaded recre-
ational access, while minimizing adverse habitat effects in the Upper George Inlet, Saddle Lakes, and
the Salt Lake area.
Response 5:
This has been done in the ROD.
Comment 6: (paraphrased)
The DEIS lacks justification that the extensive blocks of contiguous old growth retention as presently
displayed are necessary to meet the NEPA and NFMA objectives. In certain cases such blocks may be
significant in the maintenance and enhancement of deer populations and to achieve wildlife manage-
ment goals. However, this conclusion is not supported by the alternatives analysis presented in the DEIS
and further analysis is recommended.
Response 6:
NEPA requires that we display a reasonable range of alternatives, we feel we have done this. You are
correct in stating that additional analysis is required and we have attempted to do so in the FEIS. We
will be monitoring the old growth blocks during implementation and through time. This teed back"
information will give us additional insight into the effectiveness for future projects.
Comment 7: (paraphrased)
The Naha LUD II management area designation should be clearly displayed on all maps accompanying
the FEIS.
Response 7:
We agree.
Comment 8: (paraphrased)
As noted on page 2, additional analysis should consider extensions of the existing Ketchikan road
system within the project area to support immediate, well-planned roaded recreation needs.
Response 8:
See response 2.
Comment 9: (paraphrases)
The FEIS and preferred alternative analysis should incorporate the fishery protection provisions as per
Section 103 of the Tongass Timber Reform Act.
Response 9:
This has been done.
2^
KETCHIKAN GATEWAY BOROUGH
a'
■ ST^*-
Planning Department
344 Front Street
Ketchikan, Alaska 99901
(907) 228-6610
March 20, 1991
Stephen Ambrose
Acting Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Subjects 1950 Shelter Cove Draft Environmental Impact Statement
(Alternatives 3 and 7)
Dear Mr. Ambrose:
This correspondence is meant to update the Ketchikan Gateway
Borough position regarding the Draft Environmental Impact Statement
for Shelter Cove, and specifically to further amplify on our
support for Alternative 3. Again, we believe that this alternative
provides the best match between the objectives expressed in the
Environmental Impact Statement and the community values that were
listed in our correspondence of January 14, 1991. However, since
that time we have had the opportunity to listen to discussions
involving Alternative 7 at the local, state, and federal levels.
We believe there are certain advantages that are presented in
Alternative 7 that can be included within a modified Alternative 3,
and there are certain issued raised in Alternative 7 regarding
habitat that may also be incorporated within Alternative 3 .
Specifically, the timber harvest areas identified on the
southeastern part of the peninsula, generally including harvest
units 9 through 13 and units 39 through 49 can be effectively
included, we believe, in Alternative 3. The effect of this action
would be to increase the timber harvest levels of this Alternative,
thereby meeting the economic development goal of the community as
well as providing compensating areas of timber harvest for areas of
timber harvest that may be eliminated or reduced in other areas of
the proposed sale area.
The Alaska Department of Fish and Game has emphasized the need for
continuous, large blocks of old growth timber within the area of
Salt Lakes and Salt Creek. The Borough does not find support
within the Environmental Impact Statement for this extent of
"necessary" retention of old growth forest within VCU747.
c<
A
^/£y4/
BJS/B3/SA
Stephen Ambrose
March 20, 1991
Page 2
Nonetheless, partly to accommodate their stated concerns, and as a
means of providing a compromise to our position, the Borough would
agree to the elimination of timber harvest areas 24, 25, and 26 in
VCU747 and the reduction and reconfiguration of timber harvest
areas 42, 43, 44, and 45 in VCU747 of Alternative 3. The latter
areas are generally adjacent to Salt Lakes and to Salt Creek. We
believe that the elimination of these areas , combined with the
inclusion of other areas in the southeastern portion of the
peninsula, will provide requisite timber harvest levels and ensure
adequate habitat protection.
Nonetheless, it is critical that the mainline road which is part of
Alternative 3 that accesses the area immediately north of the Salt
Chuck and the areas adjacent to Salt Lakes and Salt Creek be
retained, as envisioned in Alternative 3. Access to these areas is
critical in terms of meeting the Borough's roaded recreational
objectives .
Finally, the Borough recognized the apparent need for the Forest
Service to eliminate timber harvest areas 46, 47, and 48 within
VCU742, which is within portions of the Naha primitive area.
We believe that these comments should help the Forest Service to
develop a "mixed alternative" that combines the best features of
Alternatives 3 and Alternative 7 . We feel that these comments are
generally consistent with the recommendations expressed in the
State position as described in the Department of Community and
Regional Affairs correspondence dated March 11, 1991.
The opportunity to comment on the Environmental Impact Statement is
appreciated, and we hope that this most recent statement by the
Borough on this matter will help clarify both our position as well
as provide some flexibility to the Forest Service in its crafting
of the final alternative. Although our previous correspondence on
this matter remains valid, the information provided herein will
both retain our previous position as well as provide opportunities
for Forest Service refinements that reflect timber harvest, roaded
recreation, and habitat protection concerns raised by community
residents, the Borough, as well as by agencies of the State.
Ralph-M\ Bartholomew, Mayor
RMB/BGP/bjs
BJS/B3/SA
Letter from Ralph M. Bartholomew, Mayor, Ketchikan Gateway Borough
Comment: (paraphrased)
We believe that these comments should help the Forest Service to develop a 'mixed alternative' that
combines the best features of Alternative 3 and Alternative 7.
Response:
Your comments have been reflected in the ROD.
A
A
iaw. £
r
5 bo
V-/<-^jc\a.Aix-v'
A^^<v
(LlV
KETCHIKAN GATEWAY BOROUGH
^ Planning Department
i^Jk. 344 Front Street
Ketchikan, Alaska 99901
(907) 228-6610
March
Stephen Ambrose
Acting Forest Supervisor
Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Subject: 1950 Shelter Cove Draft Environmental Impact Statement
(Alternatives 3 and 7)
Dear Mr. Ambrose:
This correspondence is meant to update the Ketchikan Gateway
Borough position regarding the Draft Environmental Impact Statement
for Shelter Cove, and specifically to further amplify on our
support for Alternative 3. Again, we believe that this alternative
provides the best match between the objectives expressed in the
Environmental Impact Statement and the community values that were
listed in our correspondence of January 14, 1991. However, since
that time we have had the opportunity to listen to discussions
involving Alternative 7 at the local, state, and federal levels.
We believe there are certain advantages that are presented in
Alternative 7 that can be included within a modified Alternative 3,
and there are certain issued raised in Alternative 7 regarding
habitat that may also be incorporated within Alternative 3 .
Specifically, the timber harvest areas identified on the
southeastern part of the peninsula, generally including harvest
units 9 through 13 and units 39 through 49 can be effectively
included, we believe, in Alternative 3. The effect of this action
would be to increase the timber harvest levels of this Alternative,
thereby meeting the economic development goal of the community as
well as providing compensating areas of timber harvest for areas of
timber harvest that may be eliminated or reduced in other areas of
the proposed sale area.
The Alaska Department of Fish and Game has emphasized the need for
continuous, large blocks of old growth timber within the area of
Salt Lakes and Salt Creek. The Borough does not find support
within the Environmental Impact Statement for this extent of
"necessary" retention of old growth forest within VCU747.
BJS/B3/SA2
Stephen Ambrose
March 20, 1991
Page 2
Nonetheless, partly to accommodate their stated concerns, and as a
means of providing a compromise to our position, the Borough would
agree to the elimination of timber harvest areas 24, 25, and 26 in
VCU747 and the reduction and reconfiguration of timber harvest
areas 42, 43, 44, and 45 in VCU747 of Alternative 3. The latter
areas are generally adjacent to Salt Lakes and to Salt Creek. We
believe that the elimination of these areas, combined with the
inclusion of other areas in the southeastern portion of the
peninsula, will provide requisite timber harvest levels and ensure
adequate habitat protection.
Nonetheless, it is critical that the mainline road which is part of
Alternative 3 that accesses the area immediately north of the Salt
Chuck and the areas adjacent to Salt Lakes and Salt Creek be
retained, as envisioned in Alternative 3. Access to these areas is
critical in terms of meeting the Borough's roaded recreational
objectives .
Finally, the Borough recognized the apparent need for the Forest
Service to eliminate timber harvest areas 46, 47, and 48 within
VCU742, which is within portions of the Naha primitive area.
We believe that these comments should help the Forest Service to
develop a "mixed alternative" that combines the best features of
Alternatives 3 and Alternative 7 . We feel that these comments are
generally consistent with the recommendations expressed in the
State position as described in the Department of Community and
Regional Affairs correspondence dated March 11, 1991.
The opportunity to comment on the Environmental Impact Statement is
appreciated, and we hope that this most recent statement by the
Borough on this matter will help clarify both our position as well
as provide some flexibility to the Forest Service in its crafting
of the final alternative. Although our previous correspondence on
this matter remains valid, the information provided herein will
both retain our previous position as well as provide opportunities
for Forest Service refinements that reflect timber harvest, roaded
recreation, and habitat protection concerns raised by community
residents, the Borough, as well as by agencies of the State.
Correspondence from the Borough Mayor on this matter will be
forthcoming this Friday; however, this correspondence is provided
to ensure the Forest Services' understanding of our position in the
event that there are immediate discussions on the selection of a
referred alternative. Mr. Bartholomew's letter will reflect the
issues raised in this correspondence.
Sincerely,
Bruce Phelps , AICP
Planning Director
BGP/bjs
BJS/B3/SA2
Letter from Bruce Phelps, Planning Director, Ketchikan Gateway Borough
Comment: (paraphrased)
We believe that these comments should help the Forest Sen/ice to develop a ‘mixed alternative" that
combines the best featrues of Alternative 3 and Alternative 7.
Response:
Your comments have been reflected in the ROD.
.
c o
KETCHIKAN PUBLIC UTILITIES
2930 TONGASS AVENUE
KETCHIKAN, ALASKA 99901
February 22, 1991
.MUNICIPALLY OWNED
ELECTRIC TELEPHONE WATER
\ U ^ irl~r° * -TSLEPHONEfS 0u525^j000
j ASEpAx 907 226-^888
i RECEIVED f
l f -I ( I
I ' I
I -£QE£SI, 30Rs or":^'_|
i3Ei^P;X: id
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Attention: Mr. Stephen Ambrose
Acting Forest Supervisor
Ketchikan Area
Subject: 1950 Shelter Cove Draft Environmental Impact Statement, Alaska Region,
Ketchikan Area
Dear Mr. Ambrose:
Ketchikan Public Utilities would like to express its support for Alternative 3 of the Shelter
Cove Draft Environmental Impact Statement. This alternative offers the most acceptable
balance necessary to meet the objectives of the Environmental Impact Statement and
community goals of recreational opportunity, a more developed road system and better
access than provided under other alternatives.
We are acutely aware that the Environmental Impact Statement will impact to a large
degree the proposed electric transmission line from Lake Tyee to Swan Lake and the
adjacent road corridor. We support a major road corridor that would allow for easy
access to the proposed transmission line, enhance access to and use of recreation areas
and the continuing viability of the timber industry.
Ketchikan Public Utilities agrees with the City of Ketchikan and the Ketchikan Gateway
Borough that Alternative 3, the Recreation/Visual Resource Emphasis alternative is the
best and we hereby lend our support to it. We would like to thank you for this
opportunity to comment on the Shelter Cove Draft Environmental Impact Statement. If
you desire any further comments or input, please contact me.
Best regards,
KETCHIKAN PUBLIC UTILITIES
Thomas W. Stevenson
General Manager
/
RJC:TWS:LLH
007-S5.1
Letter from Thomas W. Stevenson, General Manager, KPU
Comment (parapharased)
We support a major road corridor that would allow easy access to the proposed transmission line from
Lake Tyee to Swan Lake.
Response:
Roads planned in the Shelter Cove DEIS indicate several crossing of the KPU power transmission lines.
Such crossings will be coordinated with KPU during the design and construction phases.
In reviewing your concerns relating to power transmission corridors, I am assuming you are referring
to areas outside the Shelter Cove project area. The transmission corridor is already in place and requires
no additional right-of-way. From your statements, I believe you are relating to the Tyee intertie which runs
from Swan Lake northward. This is not in the project area.
1UNICIPALLY OWNED
LECTRIC TELEPHONE WATER
27
i'H1
KETCHIKAN PUBLIC UTILITIES
KETCHIKAN, ALASKA 99901 TELEPHONE 907-226-1000
FAX 907 226-1888
February 22, 1991
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Attention: Mr. Stephen Ambrose
Acting Forest Supervisor
Ketchikan Area
Subject: 1950 Shelter Cove Draft Environmental Impact Statement, Alaska Region,
Ketchikan Area
Dear Mr. Ambrose:
The City of Ketchikan wishes to express its continued support of Alternative 3 as the best ) j
alternative to the 1950 Shelter Cove Draft Environmental Impact Statement. Our )
comments and recommendations to the U.S. Forest Service request for such regarding }
this follow the community objectives that have been previously identified.
1. The importance of a sound economic base of which the timber industry is a
principal entity. We consider alternatives that provide jobs and community income
impact the quality of life that we are constantly trying to improve.
2. The creation of a road system that will be or can be upgraded to an acceptable
public access standard for an inter/intra island road. Alternatives that provided for
such access and that could be integrated with an eventual inter-island road were
judged more valuable than other alternatives.
3. The Community Attitude Survey (for outdoor recreation) found a great need for
additional roaded recreational opportunities and access to them makes this
j alternative more valuable than those that do not provide for such.
4. An environmental awareness of the pristine wilderness that we live and work in and
Ithe minimization of the impact upon habitat resources while accomplishing other
previously stated objectives.
if /
)The Ketchikan City Council and I would like to thank you for this opportunity to comment
on the Shelter Cove Draft Environmental Impact Statement. We continue to follow the
I
I
007-S5.2
Mr. Stephen Ambrose
February 22, 1991 ’ ‘
Page 2
progress of this project and with great interest. If there is anything further that we can
provide you with, please contact me.
Sincerely,
CITY OF KETCHIKAN d/b/a
KETCHIKAN PUBLIC UTILITIES
TWS:LLH
007-S5.3
Letter from Ted Ferry, Mayor, City of Ketchikan
Comment:
The City of Ketchikan wishes to express its continued support of Alternative 3 as the best alternative to
the Shelter Cove DEIS.
Response:
Your comments are appreciated.
IV ATE LAND
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