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THE LPK TIMBER SALE PLAN FOR 1979-84:
The final environmental statement of the 5-year operating plan,
part of the long-term sale of Tongass National Forest timber
to the Louisiana-Pacific Corporation, Ketchikan Division.
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: U.S. Department of Agricultura, Forest Service, Alaska Region, Tongass National Forest, Ketchikan Area
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THE LPK TIMBER SALE PLAN FOR 1979-84. U.S. Department of Agriculture,
Forest Service, Alaska Region, Tongass National Forest, Ketchikan Area.
December 1978, Series No. R10-59.
FINAL ENVIRONMENTAL STATEMENT
10-05-7904:
THE LOULSITANA-PACIFIC CORPORATION, KETCHIKAN DIVISION, TIMBER
SALE PLAN FOR THE 1979-84 OPERATING PERIOD
KETCHIKAN AREA, TONGASS NATIONAL FOREST, ALASKA
Responsible Federal agency: U.S. Department of Agriculture
Forest Service
Washington, D.C. 20250
Responsible official: John R. McGuire
Chief, Forest Service
U.S. Department of Agriculture
Washington, D.C. 20250
For further information,
contact: James S. Watson
Forest Supervisor, Ketchikan Area
Tongass National Forest
USDA Forest Service
Federal Building
Ketchikan, Alaska 99901
Tel. (907) 225-3101
Abstract:
This final environmental statement describes five alternatives for the
harvest of as much as 960 million boardfeet of timber in the Ketchikan
Area of the Tongass National Forest in Alaska. This statement relates
to the 1979-84 operating plan of the long-term sale of national forest
timber to the Louisiana-Pacific Corporation, Ketchikan Division. The
estimated effects of implementing each of the alternatives, including a
"no action" alternative, are discussed. The Forest Service preferred
alternative is identified, and the rational for this identification is
shown.
aM
Summary
FINAL ENVIRONMENTAL STATEMENT
THE LOUISIANA-PACTFIC CORPORATION, KETCHIKAN DIVISION,
TIMBER SALE PLAN FOR THE
1979-84 OPERATING PERIOD
10=05—7,9—010
Type of action: Administrative
Responsible Federal agency: U.S. Department of Agriculture
Forest Service
Washington, D.C. 20250
Date of transmission to the Environmental Protection Agency and the
public:
Draft: December 7, 1978
Final:
Responsible official: John R. McGuire
Chief Forest Service
U.S. Department of Agriculture
Washington, D. C. 20250
For further information, contact: James S. Watson
Forest Supervisor, Ketchikan Area
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
This is a final environmental statement published by the U.S. Department
of Agriculture, Forest Service. It describes an administrative type of
action.
The action proposed is the harvesting of as much as 960 million boardfeet
(MM bf) of timber on the north end of Prince of Wales Island and on
Revilla Island, which are part of the Tongass National Forest in Alaska.
Timber, fish, wildlife, water, and outdoor recreation opportunities are
all important resources on the sale area. The harvesting of timber and
associated activities is authorized by an existing 50-year Timber Sale
Agreement between the United States and Louisiana-Pacific Corporation,
Ketchikan Division.
ata lal
The five alternatives considered are:
al Harvest 960 MM bf of timber on the sale area in the units proposed
by the Louisiana—Pacific Corporation, Ketchikan Division (LPK).
Ze Harvest no timber.
2s Harvest 790 MM bf of timber on the sale area and emphasize forest
values other than timber resources.
4. Harvest 960 MM bf of timber on the sale area from units proposed by |
the Forest Service interdisciplinary team (IDT).
Dis Harvest 694 MM bf of timber on the sale area in currently roaded
areas and avoid entering all roadless areas larger than 5,000
acres.
Alternative 4 is preferred by the Forest Service. It meets the policies
of the "Southeast Alaska Area Guide" and Tongass Land Management Plan
for resource protection, avoids sensitive roadless areas, and satisfies
the contractual commitment for timber volume.
Timber harvesting in the sale area would convert old-growth stands to
young, faster growing stands. Naturalness and aesthetic qualities of
the area would decrease. Wildlife habitat would be modified by clearcut—
ting and roads. Wilderness characteristics would be lost in areas where |
timber harvesting and related activities are planned.
Comments on the draft environmental statement of this proposed action
have been received from the following Federal, State, and local agencies ©
and others: U.S. Department of Commerce; U.S. Department of Housing and —
Urban Development; U.S. Department of the Interior; U.S. Department of
Treasury; U.S. Department of Transportation, Federal Highway Administra-
tion; U.S. Environmental Protection Agency; U.S. Department of Energy,
Federal Energy Administration; U.S. Da ee neue of Commerce, National
State of Alaska, Office of the Governor, State-Federal Coordinator;
Others invited to comment include the Tongass Conservation Society, et
Southeast Alaska Conservation Council, South Tongass Land Review Commit- |
tee, Southern Southeast Regional Aquaculture Association, Point Baker {
Association, Petersburg Conservation Society, Louisiana-Pacific Corpora-
tion, Seine Boat Owners and Operators, Western Federation of Outdoor
Clubs, Alaska Trollers Association, Orvel and Carmen Holum, Constance
Griffith, Alan and Linda Deubner, Lloyd A. Jones, Elzie Isley, James A.
Wilson, M.D., Lewis K. McClendon.
iv
EB.
Contents
INTRODUCTION
AFFECTED ENVIRONMENT
A. Physical
Ik Geography
25 Climate
Sie Soil
Live Water
B. Biological
ve Flora
Des Fauna
(Ge Social Aspects
ibs Recreation
De Visual
Sie Wilderness
4. Cultural
BF Transportation
DE Economic Aspects
E. Land Status
Ide Issues
G. Management Concerns
- EVALUATION CRITERIA
ALTERNATIVES CONSIDERED
EFFECTS OF IMPLEMENTING ALTERNATIVES
A. Soil
Bie Water
‘Gre Fish
D. Wildlife
Ee Vegetation
F. Timber
G. Socioeconomic
H. Minerals
Page
VEE.
I. Recreation
J. Wilderness
Ko Visual
L. Cultural Resources
M. Atmosphere
EVALUATION OF ALTERNATIVES
IDENTIFICATION OF FOREST SERVICE PREFERRED ALTERNATIVE
MANAGEMENT REQUIREMENTS
CONSULTATION WITH OTHERS
REFERENCES
GLOSSARY
INDEX
APPENDIX
A. Timber Sale Contract Al0fs-1042
B. Operating Guidelines
vi
Page
68
72
72
74
76
76
79
80
81
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
TABLE
Tables
1--Recreation cabin use on sale area in 1976
2--Primary employment by sector and Area on the
Tongass National Forest, 1970-76
3--Average annual employment by industry in southeast
Alaska, 1970-76
4--Average employment by industry in the Ketchikan
Area, 1970-76
5--Estimated number of acres in areas planned for
timber harvest in the 1979-84 period by slope
class for each alternative
6--Extent of stream miles affected on the sale area
by timber harvesting alternative
7--Areas of habitat and potential numbers and values
of fish affected by road drainage structures by
alternative
8--New and reconstructed log transfer facilities by
alternative
9--Percentage of natural cover types believed
necessary to maintain wildlife populations
TABLE 10--Relative effects on individual species or species
groups by alternative
TABLE 11--Size of areas to be harvested on the sale area by
alternative
TABLE 12--Blowdown area, harvesting units, and deleted areas
by location, 1979
TABLE 13--Cutting units larger than 160 acres by alternative
TABLE 14--Locations which have high values for dispersed
primitive recreation and are proposed for entry
by alternative
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36
45
50
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Page
TABLE 15--Locations which have high values for dispersed 7fAL
semiprimitive recreation and are proposed for
entry by alternative
Table 16--Relationship of alternatives to evaluation criteria 719
viii
The LPK Timber Sale Plan
For 1979-84
I. Introduction
This final environmental statement (FES) evaluates alternatives for
the harvest of as much as 960 million boardfeet (MM bf) of timber
on Tongass National Forest lands in southern southeast Alaska. The
harvest will occur over a 5-year period starting July 1, 1979, and
ending June 30, 1984. The preferred alternative would have the
activities take place on the northern portions of Prince of Wales
and Revillagigedo Islands as part of the 50-year timber sale agree-
ment between the United States and Louisiana-Pacific Corporation,
Ketchikan Division (LPK). (See Alternative maps for the boundary
of ‘the sailes)
This environmental statement was considered necessary because some
previously unroaded and undeveloped areas of the sale area were
planned for timber harvest prior to completion of the Tongass Land
Management Plan (TLMP). The Tongass Land Management Plan, which
was fully coordinated with the nationwide Roadless Area Review and
Evaluation (RARE II) process, will assign various land use designa-
tions to the Forest ranging from Wilderness to development of the
natural resources on the Forest. ale
The interdisciplinary team (IDT) preparing the DES for the 50-year
sale coordinated their plan with TLMP and RARE II so as not to
contain any publicly expressed Wilderness proposals. This meant
leaving options open to TLMP by remaining on the primary sale area
and by deferring harvest in Karta, Salmon Bay Lake, and those
portions of Sarkar and Honker Divide roadless areas that are within
the long-term sale area.
1/ _‘TLMP and RARE II assessments were released in June 1978 through
draft environmental statements. The final TLMP and RARE II environmental
statements may be obtained by contacting the USDA Forest Service (OI),
P.O. Box 1628, Juneau, Alaska 99802.
Section 15(a) of the National Forest Management Act validated
existing timber sale contracts in Alaska. This section of the Act
also directed the Secretary of Agriculture to revise the long-term
sale contracts in Alaska to make them consistent with the guidelines
and standards provided in the Act and to reflect such revisions in
the contract price of timber. The Act further states, however,
that any such action shall not be inconsistent with valid contract
rights approved by the final judgment of a court of competent
jurisdiction. In conformance with this law, the Government is
making revisions in the contract which will affect activities after
July 1, 1979. The harvest unit selection process for the 1979-84
operating period is occurring according to existing contract require-
ments.
The 50-year term of the sale has been divided into a series of 5-
year operating periods for purposes of redetermining rates of
payment. Two years in advance of each 5-year operating period, the
purchaser selects logging units for cutting in the ensuing 5-year
period. The Forest Service then has 1 year to review the purchaser’
selections and request modifications necessary to prevent damage or
protect the national forest. There is, then, 1 year left to cruise
and appraise the selected units so that new rates for stumpage and
road construction can be established.
The timber sale was sold on July 26, 1951, and is scheduled to
terminate June 30, 2004. During this time the Forest Service must
make available 8,250,000,000 boardfeet of timber (see contract
section 1, Appendix A). The Forest Service SHALL make up to 960 MM
bf available in each 5-year period if the purchaser requests. If
this volume is not available on the primary sale area, it must be
made up from the remainder of pulpwood allotments E, F, and G,
which include essentially the remainder of Prince of Wales Island
and its associated islands, Revilla Island, Cleveland Peninsula,
and the Ketchikan Area mainland.
The interdisciplinary process described in the "Southeast Alaska
Area Guide" was followed in preparing this FES. A study plan was
prepared and the IDT selected in June 1977.
In 1976 and throughout 1977, Forest Service and LPK crews reconnoi-
tered the sale area to determine specific areas feasible for develop
ment. Information was gathered by use of aerial photographs, maps,
and aerial and ground reconnaissance missions. Data were gathered
on the physical factors which affect the management of natural
resources primarily concerning vegetative and terrain features.
From these investigations, LPK proposed its selection of units
under the contract and submitted them for Forest Service approval.
This proposal ultimately became Alternative 1. The IDT team met
and reviewed the LPK proposal and developed Alternatives 3 and 4.
Additional field reconnaissance was conducted by team members to
investigate various aspects of Alternatives 1, 3, and 4. These
investigations supplemented previously gathered data.
Some of the proposed harvesting areas were subjected to high-speed
winds since the DES was published. The winds caused extensive
damage, which is described in the section "Effects."
Alternatives 2 and 5 were developed last by the core team. They
reflect national concerns for roadless recreation opportunities.
The IDT included the following individuals:
Edward Johnson Team Leader, Forest Service (FS)
Jim Rhodes Engineer, FS
Paul Harrington Wildlife Biologist, FS
Ed Blankenship Forester, FS
Dave Loggy Soil Scientist, FS
Additionally, the following specialists advised the team in the
development of Alternatives 3 and 4 as well as the analyses of
Alternatives 1, 2, and 5.
Mike Pease Fisheries Biologist, FS
John Short Landscape Architect, FS
Steve Haavig Alaska Dept. of Fish and Game
Bob Wood Alaska Dept. of Fish and Game
Chuck Osborne U.S. Fish and Wildlife Service
Others also provided professional advice and assistance throughout
the development of this statement, including:
Keith McGonagill Logging Systems, FS
Stan Davis Archeologist, FS
Chris Rabich Archeologist, FS
Doug Campbell Landscape Architect, FS
Duane Peterson National Marine Fisheries Service
Dana Young Soil Scientist, FS
Darl Enger Engineer, FS
Louis Bartos Hydrologist, FS
This was done basically at the prescriptive level of planning as
described in the "Southeast Alaska Area Guide." Prior to release
of any unit for timber narvesting or roading, an IDT review will be
required.
AFFECTED ENVIRONMENT
Following is a brief discussion of the environment of the sale
area. In many aspects, it is the same as much of the rest of.
southeast Alaska. A more detailed description, relative to each of
the following topics, can be found in the "Southeast Alaska Area
Guide," the "Tongass Land Management Plan," and the series "The
Forest Ecosystem of Southeast Alaska," numbers 1 through 10 (see
references).
Ae Physical
lS Geography
The geography of the sale area is characterized by com-
pletely glaciated islands within the Alexander Archipelago.)
Deep fiords and bays are prevalent through the many
intricate waterways. The primary sale area is bounded to
the west and south by the Pacific Ocean and by Sumner
Straits, Clarence Straits, and Behm Canal to the north
and east. The uplands consist of steep mountain ranges
dissected by glaciated valleys of varying widths. Eleva- =|
tions range from sealevel to about 4,000 feet. No glaciers |
are present within the area, but some perpetual snow
patches exist in some of the higher mountains.
Qi. Climate
All of southeast Alaska is in the humid maritime zone
(Miller). The sale area has over 1,000 miles of ocean
shoreline. A few offshore islands separate the western
coast of Prince of Wales Island from the open Pacific
Ocean.
Strong winds are frequent, especially from mid-September
to mid-May, but they may occur in any month. More than
80 percent of the total yearly precipitation falls during —
these months. The more severe storms are often accompanied
by winds in excess of 50 miles per hour. However,
precipitation intensities are not severe. The expected
maximum 1-hour precipitation is 1 inch for a 100-year
storm and 0.8 inch for a 25-year storm.
The average temperature for the coldest month is slightly
above 32° F, and the average temperature for the warmest
month is below 60° F. Rainfall is high, averaging over
100 inches per year at sealevel. The maximum summer day
length is 17.5 hours at nearby Ketchikan. Cloudiness is
the rule. For example, the percentage of possible sunshine
throughout the year is 27 percent at Annette near the
southern end of the forest and 23 percent at Juneau near
the north end.
The average length of the growing season at Hollis is 177
days, but the average air temperature during that time is
below 55° F. Evapotranspiration is estimated to be 23
inches at Craig and at Hollis.
Thus, the climate is mild with cool temperatures, high
humidity, and high precipitation. In winter, snowfall is
generally light along the beaches, but a deep snowpack
accumulates inland and at higher elevations.
ie Soil
Most mineral soils of southeast Alaska have several
characteristics common to northern coniferous forests.
These include thick organic mats, ranging from a few
inches to over a foot in thickness. These mats are
largely responsible for the soils being totally resistant
to sheet erosion and highly resistant to other types of
erosion so long as these mats are not removed. Other
common characteristics include very strong acidity, low
natural fertility, extremely rapid infiltration rates,
rapid permeability in their upper layers, perpetual
moistness, and very low bearing strength. They also are
thixotropic, meaning they tend to change state from a
solid to a gel when agitated. These last three charac-
teristics have a marked influence on excavation and use
of the soils for various engineering purposes, especially
roadbuilding. Nearly all road embankments have to be
built from rock blasted from quarries. Only a few soils
from fresh glacial and alluvial deposits are worthwhile
for embankment purposes.
Because of these soil characteristics, sheet erosion
problems are minor. However, soil mass movement resulting
from steep slopes or unstable soils or both is a major
soil management problem under natural and utilized condi-
tions. To date, this problem has been dealt with mainly
by avoiding or minimizing activities on such areas.
These areas are restricted to slope classes of 34 to 37
degrees and 37 degrees or more, except for two soil
series where drainage and soil texture can cause mass
movement to occur on slopes of less than 34 degrees. New
logging systems and advanced logging technologies will be
applied in the next 5 years so that some soils and slopes,
previously avoided because of potential mass movement
problems, will become available for the harvest of timber.
On oversteep slopes, nearly all mass movement is related
to exposure of the mineral soil with a subsequent intensive
storm. Mineral soil disturbance results from blowdown of
trees under natural conditions and by logging and road-
building in timber sale units. Some research indicates
that the decay of stump roots in logged areas causes loss
of binding in the soils, resulting in a weakening of the
soil strength which can result in mass movement on over-
steep slopes. These slides are also associated with
intense storms which may occur 3 to 5 years after logging.
Past slide history on some logged oversteep slopes supports
the theory of root decay causing soil changes.
Even though mass movement has been shown to increase on
oversteep logged slopes, it is generally a relatively
small amount of the total productive acreage in the
watershed. Mass movement on logged areas is a small
percentage of the total mass movement occurring. In
1976, an analysis was made of 345,920 acres, which included
the Maybeso Creek drainage near Hollis where slides
increased four times on logged oversteep slopes. The
analysis showed that slides associated with logged areas
amounted to only 11 percent of the total slides on this
sample area. A main concern is whether the slides occur
on the landscape where they can produce sediment to
spawning streams. The analysis showed that 81 percent of
the slides associated with the harvested areas directly
or indirectly affected fish streams. It is this effect
that has initiated requirements for better management
practices in timber harvesting discussed in section
"Water" under "Effects."
Water
The sale area has 30 major streams and many small,
largely unnamed streams. The watersheds are generally
small, ranging from a few hundred acres to a few thousand
acres. There are a few larger ones, such as Staney Creek
(46,000 acres) and Thorne River (96,000 acres), but most
are short with irregular characteristics of early stage
development.
Stream flow fluctuates widely. Peak flows occur in the
fall and spring, and low flows in the summer and winter.
Most stream patterns are dendritic or rectangular.
Streams usually originate in the alpine or high muskegs
and flow down steep bedrock control V-notches. Along
valley floors, they may cut through deep, compact till
deposits or follow faults and joints in the bedrock.
Despite the abundant amount of precipitation in this
region, groundwater is generally scarce. Through rapid
soil percolation and drainage and high water tables in
some soils, the majority of the precipitation is rapidly
returned to the ocean by the large number of streams in
the area.
Any land use activity that might reduce water quality
must be carefully controlled. Many watershed problems
are associated with landforms or slopes where geologic
erosion and sediment production are naturally high.
These areas are frequently sensitive to such activities
as logging and road construction. Water temperature and
flow may also be affected by land management practices.
The Forest Service is conducting an extensive water
quality monitoring program. The State of Alaska, Depart-
ment of Environmental Conservation, is revising its water
quality standards and developing best management practices
(BMPs) for control of nonpoint source pollution. Admini-
strative control and implementation of watershed protec-
tion measures are increasing through hydrologic and
fisheries input to the planning process.
On May 24, 1977, the President issued Executive Order
11988 directing that development on flood plains be
avoided where there is a practical alternative. Executive
Order 11990 provides similar direction for protection of
wetlands.
Some stream crossings in the sale area have abutments and
fill material on land that meets the Flood Plan Definition
in the Executive Order. Other than this, there are no
B. Biological
ie
facilities planned on flood plains. Under the selected
alternative, the number of stream crossings have been
minimized to the extent practical.
It is not surprising that southeast Alaska with its high
rainfall (100-200 inches per year), impervious substrata,
and frequent rainfall (30-40 percent) has an abundance of
wetlands. Technically, wetlands as defined in Executive
Order 11990 constitute about 30 percent of the landscape
within the bulk of the sale area.
Peat bogs (muskegs) commonly occur on slopes up to 30
percent and are defined as wetlands. Road construction
has a negligible effect on these bogs. The sensitive
wetlands of southeast Alaska are the tide influenced
meadows in the estuarine zone. No development is planned
in the selected alternative on these lands.
Flora
The major floral associations of the sale area are true
forest grass-sedge meadows, muskegs, and alpine tundra.
The true forest is part of the cool, very moist rain
forest that extends from northern California to Cook
Inlet. It extends from sealevel to an altitude of 2,000
to 3,000 feet. This forest is comprised primarily of
western hemlock and Sitka spruce, with a scattering of
mountain hemlock, western redcedar, and Alaska cedar.
Red alder is common along streams, beach fringes, and on
recently disturbed soils. Blueberries, huckleberries,
copperbrush, devilsclub, and salal are the most important
shrubs on the forest floor. Mosses grow in great profusion
on the ground, on fallen logs, and on lower tree branches.
Grass-sedge meadows are usually small areas around streams
at low elevations and on the upper intertidal areas. .
Vegetation consists mainly of grasses, sedges, and other
herbaceous plants.
Openings occupied by muskegs, or bog plant communities
dominated by sphagnum mosses and sedges are dispersed
throughout the forest. These openings also support low
shrubs, forbs, and a few scattered hemlock and lodgepole
pine. Muskegs vary greatly in size from small pockets,
where drainage has been retarded, to relatively broad
expanses, such as portions of the Thorne River Valley.
Muskegs may even occur on fairly steep slopes. The
underlying substrate is highly organic and ranges from
about 1.5-feet to 40-feet thick. These openings create
variety in the unbroken coastal forest and add to its
value as wildlife habitat. Shrubs growing at the edge
between the forest and muskeg provide further habitat
variety.
The alpine tundra usually lies above 2,500 to 3,000 feet.
.Thus, it occupies the region above the coastal forest and
is separated from the forest by a subalpine or transition
zone. Soils are generally thin, but gravelly and stony
organic soils may form locally in depressions. Snow
remains in some glacial basins year-round, particularly
on north-facing slopes. Resident plants have adapted to
snowpack and wind abrasion by evolving low-growth forms.
Low, mat-forming vegetation covers most of the tundra,
and cushion-like plants occupy crevices on exposed rock
outcrops and talus slopes.
None of the plant species threatened or endangered in
Alaska are known to occur within the sale area.
Die Fauna
Fish and wildlife resources of the sale area are major
commercial, subsistence, recreational, and aesthetic
assets. The commercial and sport fisheries depend upon
the forest ecosystem to provide spawning and rearing
habitats as well as a quality source of freshwater entering
the estuarine environment.
Salmon, char, and trout are the fish species most dependent
on the forest environment. Salmon are also the mainstay
of the southeast Alaska fishing industry. In terms of
wholesale value, canned and frozen salmon accounted for
72 percent of the value of all fish products for 1970-76.
Seven species of anadromous salmonids occur on the sale
area. Of these, four species are of commercial value.
These are the pink, chum, coho, and sockeye salmon. The
coho and pink salmon are also of major recreational
importance.
Three sport fish species, in addition to the coho salmon,
occur within the sale area. These are steelhead or
rainbow trout, cutthroat trout, and Dolly Varden char.
Both resident and anadromous forms of these species occur
in the area. Several of the major stream systems on the
sale area are known for their recreational steelhead
fishing. Also, many lake systems contain suitable sport
fish populations of cutthroat trout. Cutthroat trout and
Dolly Varden also occur as resident populations in small
isolated stream reaches.
Detailed field development of the Fish Habitat Management
Units (FHMU) will not be made at this time. However,
they will be identified during implementation planning
prior to release of units. There are six sub-FHMUs that
are descriptive of typical habitat situations encountered
in the southeast Alaska forest and stream environments.
These sub-FHMU overlap in many instances; therefore,
prescriptions will be tailored to each situation encoun-
tered.
These typical sub-FHMUs are:
*Pink and chum salmon spawning streams.
*Coho salmon and steelhead trout spawning and rearing
streams.
*Dolly Varden and cutthroat trout spawning and
rearing streams.
*Potential fish habitat for commercial and sport
fisheries populations.
*Nonfish habitat.
*Temperature sensitive streams.
Esturine areas also provide significant contributions to
the fisheries resources of the sale area. Emergent pink
and chum salmon fry depend entirely upon esturine food
supplies for growth and survival. Estuaries also are
important nursery areas for several commercial species of
crab and shrimp.
The long-term sale area furnishes the necessary habitats
and niches for over 250 vertebrate wildlife species.
Some of the major land types or wildlife habitats include
10
Ge
alpine areas, muskeg forests, muskegs, spruce-hemlock
forests, estuarine grassflats, rock outcroppings, fresh-
water lakes, saltwater lagoons, and intertidal areas.
The spruce-hemlock forest is the largest, making up over
56 percent of the land area, of which 85 percent is in
the climax old-growth type. This old-growth climax
forest represents an essential component of the habitat
requirements of many of the wildlife species or species
groups. The existing habitats include a mixture of
uneven-age timber stands in mixed volume classes, giving
varying degrees of crown closure, tree species composition,
opening size, varying composition of dead trees (snags),
and understory vegetation, thus providing varied habitats
and niches.
Each of the more than 250 species of wildlife have varying
social significance. Populations of wolves and bald
eagles create a national awareness or concern for wildlife.
Game species, primarily the Sitka black-tailed deer,
contribute to a regional and local sport and subsistence
hunting need which, in turn, contributes to the socio-
economic well-being and lifestyle of many residents. The
attraction of wildlife also adds to a successful tourism
industry equally valuable to the region.
None of the animals listed on the U.S. Department of the
Interior's U.S. Fish and Wildlife Service list of endan-
gered and threatened species are known to exist on the
sale area.
Several sources provide a more complete discussion of the
fish and wildlife resources and related management problems.
These include the "Fish and Wildlife Specialists Reports,"
"Wildlife Task Force Report," "Fisheries Task Force
Report," and "Socioeconomic Overview" that were previously
issued by the Forest Service.
Social Aspects
The social situation on the sale area is constantly changing.
Examples of this change in the last 5 years are the Ketchikan-
Hollis ferry connection; road connections from Hollis to
Craig, Thorne Bay, and Naukati Bay; a new logging camp at
Labouchere Bay; and establishment of a sawmill in Klawock.
Each of these changes has, in some way, changed the lives and
lifestyles of many residents of the sale area and vicinity.
1a
Since Thorne Bay and Naukati have been connected to the public
road system, Craig has become a shopping area for these com-
munities. The people are forming intercommunity social ties,
and the communities have began cooperating to achieve mutually
beneficial projects, such as State highways, power facilities,
and community fairs. Similar development is expected as Whale
Pass, Coffman Cove, and Labouchere Bay are connected in the
future.
a Recreation
In the long-term sale area, recreation use is concentrated
in the Barnes Lake-Sweetwater Lake area, Karta River-
Salmon Lake area, Thorne Bay-Staney Creek road system,
Salmon Bay Lake, Sarkar Lakes, Port Protection area,
Hollis, Red Bay, Traitors Cove, and Behm Canal area. A
list of recreation cabins in the sale area and their use
for 1976 is displayed in table l.
TABLE 1--Recreation cabin use on the sale area in 1976
Recreation cabin $ Visitor days of use
Red Bay Lake : 30
Salmon Bay : 160
Shipley Bay : 78
Barnes Lake : 96
Sweetwater : 242
Sarkar Lake : 60
Staney Creek : 182
Salmon Lake : 320
Karta Lake : 790
Karta River : 660
McGilvery Creek : 266
Blind Pass a 240
Plenty Cutthroat : 234
Marguerita Bay : 542
For inventory purposes, recreational opportunities were
divided into three broad categories: Dispersed primitive,
dispersed semiprimitive, and concentrated.
Dispersed Primitive--Recreational pursuits involving
isolation and an appreciation of the natural environment.
They provide a high degree of challenge and risk, and
they require a high degree of self-reliance and outdoor
skills. Major activities include fishing, hunting,
12
backpacking, and watching or photographing wildlife.
Nature is met on its own terms without convenience facili-
ties, except for access by water or air.
Opportunities for dispersed primitive recreation are
abundant because of the large amount of roadless area and
the small number of users. According to inventories of
the recreation opportunity done for TLMP, several areas
on the sale area rated high and moderate in quality for
dispersed primative recreation.
Dispersed Semiprimitive--Recreational pursuits require a
moderate to high degree of self-reliance and basic
outdoor skills. Activities are often oriented toward the
taking of fish, wildlife, and edible plants. The natural
environment dominates, but some modifications for human
conveniences are allowed. Rudimentary roads or trails,
as well as airplane and small boat access, may be available.
Opportunities for dispersed semiprimitive recreation are
abundant because of the large amount of relatively undevel-
oped forest land, air and water access, primitive trails,
both public and special-use cabins, and old logging
roads. In TLMP inventories, several areas on the sale
area rated high and moderate in quality for dispersed
semiprimitive recreation.
Concentrated--Recreational pursuits include group learn-
ing and structured activities, such as downhill skiing
and organized sports. (A moderate to high level of sport
skills is required.) Although the natural environment is
important, modifications for comfort, convenience, and
participation are emphasized.
National forest lands surrounding communities are often
highly suitable settings for concentrated recreation and
provide good potential for facility development. However,
opportunities for concentrated recreation are the least
abundant of the three major types, primarily because
large numbers of users are necessary to justify the
expense of development. Consequently, those developments
that do exist are found near urban centers, such as
Ketchikan. In TLMP inventories, most of the sale area
rated low in quality for concentrated recreation.
Further details concerning recreation are in the ''Recrea-
tion and Visual Resource Specialists Report" and the
"Recreation/Wilderness Task Force Working Report."
13
Visual
The sale area encompasses two of the characteristic
landscape types of southeast Alaska--the Kupreanof Lowland
and the Coastal Hills.
The northern half of Prince of Wales Island is almost
entirely in the Kupreanof Lowland character type. Much
of the landscape is characterized by a low, rolling
terrain, except for the blocky mountains between Luck
Lake and Thorne Bay and the range of more angular peaks
around Shakan Bay, El Capitan Pass, Shipley Bay, and
Devilfish Bay.
The major water feature in this part of the sale area is
the West Coast Waterway extending from Shakan Bay in the
north to Tonowek Bay in the south. Included within this
main channel are many bays, narrow channels, and island
groups. Other major water features are such bays as Port
Protection, Red Bay, Salmon Bay, Whale Pass, and Thorne
Bay; the Sarkar Lakes and Sweetwater-Barnes Lake systems;
and three major stream systems--Thorne River, Karta
River, and Staney Creek.
Intricate channels and island groups and extensive tidal
flats are generally the features that make up the most
diverse landscapes on this portion of Prince of Wales
Island. The highest rated landscapes in terms of variety
of features in this area of Prince of Wales Island are
the Salmon Bay and Calder Mountain areas. Most of the
remainder of the sale area on Prince of Wales Island is a
more common landscape with respect to the Kupreanof
Lowland character type.
The portion of the sale area on the northwest corner of
Revilla Island is part of the Coastal Hills character
type. The landscape is primarily characterized by very
steep slopes and moderately rugged terrain surrounding
Traitors Cove, Neets Bay, Gedney Pass, and Shrimp Bay.
Past logging and roading activities changed the character
of the landscape to differing degrees in various areas of
the sale area. In the Sarkar Lakes, Salmon Bay, Salmon
Bay Lake, Honker Divide, and Karta River areas, there has
been virtually no change in the character of the natural
landscape. But, in the areas around Thorne Bay, Coffman
Cove, Staney Creek, and Whale Pass, the natural landscape
14
as seen from recreation use areas has been extensively
altered by large clearcuts.
Between these two extremes are areas where the natural
landscape, as seen from key viewing areas, has been only
slightly altered by management activity. These would
include areas as seen from portions of the West Coast
Waterway, Sumner Straits, Red Bay, and Sweetwater Lake.
In other areas, such as Traitors Cove and Neets Bay, the
natural landscape has been extensively altered in the
past. However, 20 to 25 years of regrowth have partly
restored the forested texture and green color to the
landscape.
Wilderness
No portion of the sale area is classified as Wilderness.
The Karta River drainage area is currently included in
several bills before the U.S. Congress.
RARE II and TLMP studies have evaluated the wilderness
potential on all roadless areas on the sale area. Some
public interest has been expressed for Wilderness for
Karta, Salmon Bay Lake, Honker Divide, and Sarkar.
Therefore, alternatives have been developed to satisfy
contractual volumes for the 1979-84 operating period
without entering these areas. This was done so as to not
constrain the RARE II and TLMP processes.
Cultural
No cultural resources are listed as being on or eligible
for the National Register for Historic Places in the
Federal Register, Volume 43, Number 26 (Tuesday, February
7, 1978), or in any of the monthly updates through
Volume 43, Number 243 (Tuesday, December 5, 1978).
However, the sale area was traditionally occupied by the
Tlingit Indians with the exception of southern Prince of
Wales Island, which was inhabited by the Haida Indians.
Although detailed studies have not been undertaken to
find all sites of past Indian occupancy, more than 50
known cultural resources are on the sale area. These
include villages, canoe landings, middens, fish weirs,
forts, petroglyphys, and burial sites. Many more sites
are likely to exist, but most of them are covered with a
dense growth of vegetation.
15
5
Since late in the 1700's, Euro-Americans have had contact |
with Natives in southeast Alaska. Evidence of early
activites on the sale area is primarily from mining and
prospecting activities late in the 1800's and early in
the 1900's. Also, early in the 1900's, salteries and
later canneries were built to utilize the fishery resource.
Remains of these can be found in many bays on the sale
area. Logging also started in the 1900's, and evidence
of this early occupation can also be found scattered
throughout the sale area.
Transportation
The present transportation system in the sale area
involves air, land, and water travel. The main waterways
are Sumner Strait, Clarence Strait, Behm Canal, and El .
Capitan Pass. Land access routes are confined to localized
systems on the individual islands, and in most cases the
individual island systems cannot be linked by land.
Thus, transportation of goods and people generally requires]
combined land and water or air transportation means. |
Prince of Wales and Revillagigedo Islands contain the
greatest population centers. The other islands contain
temporary logging camps with localized road systems
primarily for timber harvest.
Revillagigedo Island is occupied by Ketchikan, Saxman,
Loring, and three small floating logging camps. Revilla- |}
gigedo Island has an extremely difficult terrain that
limits the integration of the existing road systems.
Continued development will generally expand existing
systems, with expansion directed toward local intraconnec— |
tion only where feasible.
Prince of Wales Island contains six small communities and |
numerous logging camps with a population of about 2,300
people. A large portion of these are isolated with only
local road systems. Continued development has generally
trended toward linking these systems. The terrain on
Prince of Wales Island is favorable for development of an
intraisland road system. Figure 1 shows the main road
system (arterials and major collectors), existing and
planned, on Prince of Wales Island. Past development has
been accomplished by public works contracts, cooperative
agreements, and timber sale developments.
16
Pt. Baker Legend
Port
protection . @ Permanent Communities
: @ Log Transfer Points
@ Lobouche } p ——— Planned Roads
Bay Exchang nee
Cove : —— Existing Roads
A *—-:— State Ferry Route
|
Ya \
Whale Pass 4
a. \
a Coffrhan Cove
‘ \
Control \
Lake Qi ‘J horne Bay
Owock
G
d Ty) =
: Hollis
Craig mF
(d)
Goer a
ce
Att
wr,
Figure | - Basic Transportation System
) 12 24 36miles OF
mera rer gl PRINCE of WALES ISLAND
SCALE
y/
A major purpose of linking the existing parts of the
Prince of Wales Road System is to improve management of
national forest resources. An integrated road system
will reduce the need for new logging camps and eventually
allow for a reduction in the total number of logging
camps. Similarly, the need for new log transfer sites is
reduced by joining road segments to existing sites instead
of creating new sites to serve a new isolated road system.
Integrating the road system allows the transfer of special-—
ized logging equipment to readily take place between
camps instead of making costly equipment investments at
each camp. These savings reduce costs for the purchaser
and increase the stumpage value to the United States.
Another benefit is reduced occupancy of the land by camps
and log transfer sites with, as a result, a restricted
extent of environmental impacts from human activities.
An integrated road system within the sale area provides
reliable surface access on a daily basis, 8 to 9 months a
year. This reduces time lost because of inclement flying
weather. It also reduces the number of hours Forest
Service and industry employees and their families are
exposed to hazardous airplane and helicopter travel.
Over the past 5 years, 12 Forest Service employees have
been killed in aircraft accidents. All of these people
were engaged in duties relating to the long-term timber
sale on Prince of Wales Island. Although there is no
assurance that they would be alive today if the roads had
been connected before their deaths, enough of a possibility
exists to make road construction highly desirable. Motor
vehicle accidents undoubtedly will occur on the connected
road system, but the consequences of motor vehicle acci-
dents on low-speed roads with a normal speed limit of 25
miles per hour (mph) are not expected to be so severe as
aircraft accidents.
Forest Service roads and State roads connect Craig,
Klawock, Thorne Bay, and Naukati to each other and to
Hollis on Prince of Wales Island. There are approximately
210 miles of main Forest Service road and 20 miles of
State road terminating at these population centers. One
objective of transportation planning has been to connect
the isolated road segments radiating from Coffman Cove,
Whale Pass, El Capitan, and Labouchere Bay to the other
population centers to better facilitate National Forest
management.
18
All roads on Prince of Wales Island, with the exception
of the State roads, have been constructed primarily for
timber harvest. The rate of construction and the time
table for interconnecting segments depended heavily on
the location of timber to be harvested and the location
of log transfer terminals.
Forest Service policy by regulation is to construct roads
to standards appropriate for the intended use, consider-
ing safety, cost of transportation, and impacts on lands
and resources. Locally, the main roads (arterials and
major traffic collectors) have been constructed to a
single lane width with turnouts and with a rough shot
rock surface but built wide enough to accomodate future
crushed gravel surfacing. Bridges have generally been of
temporary log stringer construction. All roads are
designed for heavy off-highway loads, but only the main
roads are intended to receive future surfacing for effi-
cient log hauling and to accomodate low-clearance vehicles.
This type of construction is the result of economic
limitations and a conservative approach to accomodating
an unknown amount of future public traffic when there
were very few connecting routes and mostly industrial
traffic. The recent connections, however, of main roads
between some of the communities and logging camps, plus
the establishment of ferry service at Hollis in 1974,
have expanded public use on the main roads beyond the
predictions of 5 years ago for the 1974-79 operating
period.
Approximately 55 temporary log stringer bridges are in
use on the Prince of Wales Island main road system. A111
but four of the temporary log stringer bridges on the
Hollis-to-Thorne Bay route have been replaced by permanent
bridges with public works funds. If the temporary bridges
(8- to 10-year service life for loaded log trucks) are
not replaced through the next 5-year period, load limit
restrictions will be required and will close some routes
to log hauling.
Currently, public use is restricted in the southern
Staney Creek area during periods of log hauling, which
include most of the daylight hours from Monday through
Saturday. The restrictions are applied because of inad-
equate width or numbers of passing turnouts and because
logging traffic is on the roads during these times.
19
Future management for the forest development roads will
continue to emphasize connection of main logging camps
and log transfer sites by construction of the remaining
planned segments of the Prince of Wales Island main road
system. Reconstruction of sections of existing main road
systems, including temporary bridge replacements, will be
required to accommodate log hauling or unrestricted
public traffic. The construction schedule, road restric-
tions or closures, and road standards are affected by
national policies, local needs, and the ability to finance.
To the extent that financing is available, the following
direction will be applied to the development of the
transportation system:
*Main road new construction will be limited to a
single-lane width with a 25-mph design speed and
constructed wide enough to accommodate crushed
gravel surfacing. Permanent bridges on the main
routes will be constructed initially to a two lane
standard.
*Main roads will be surfaced for log hauling savings
and public traffic.
*Public traffic will be restricted on isolated portions |
of the main roads under Forest Service jurisdiction
as necessary for safety or other management needs.
*Permanent bridges will be constructed initially on
all main roads, as determined by available funds,
environmental impacts on fisheries and water quality,
and the need to maintain continuous traffic. Applying]
the same considerations on the local temporary road |
systems, permanent or portable bridges with permanent
abutments will be constructed on some major stream
crossings and, temporary log stringer or portable
bridges will be built on the rest.
*The local road systems will be constructed and
managed for only industrial or administrative use,
unless there is a need for other uses, such as
hunting or fishing. These routes will be closed to
public use during log haul periods and will be
either closed to all traffic or posted as "not
maintained for public travel" when not needed for
log hauling. Closures or restrictions may be applied
for a variety of other reasons, for example, to
limit the effect of access on wildlife.
20
1D) Economic Aspects
The relative structure of the primary sectors of the Ketchikan
Area is shown in table 2. Data and discussion on nearby areas
of southeast Alaska are included for comparison.
TABLE 2--Primary employment by sector and Area on the
Tongass National Forest, 1970-76
:Percentage of primary employment by Area
Type of employment : : : Chatham
:Ketchikan : Stikine:Excluding : Only
: : : Juneau : Juneau
Commercial fishing : 17.1 64.2 3i..0 3}
and fish processing.:
Logging and forest : 53.4 PANT 56.5 =---
products :
State and Federal 3 Sboac aes, 4.8 sie s!
Government 3
The socioeconomic situation in southeastern Alaska is described
at length in the "Socioeconomic Overview" published by the
Alaska Region, Forest Service, USDA, in 1978 as part of the
Tongass National Forest Land Management Plan. Tables 3 and 4
illustrate the recent average annual employment by industry
both for the Ketchikan Area and for southeastern Alaska as a
whole.
Timber-related activities are clearly of primary importance in
the Ketchikan Area and the Chatham Area, excluding Juneau,
accounting for more than half the primary employment in each.
Commercial fishing and fish processing is significant in the
Ketchikan area, and it accounts for approximately two-thirds
of the primary employment in the Stikine Area. The percentage
of the 12-month average fisheries-related employment in the
Stikine Area is probably accounted for by the labor-intensive
shellfish production at Petersburg, the resident fleet's
greater capabilities of participating in the Gulf halibut and
groundfish fisheries, and the almost year-round activities of
both harvesting and processing as compared with the more
narrowly limited seasonal operations elsewhere.
21
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E.
Land Status
The land status situation on the sale area is constantly
changing. Since the Tongass National Forest was created,
scattered areas have been removed for private homesites,
townsites, and so forth. Mining claims have been patented to
remove more areas. Currently, lands are being withdrawn and
transferred to the KAVILCO and to SEALASKA under the Alaska
Native Claims Settlement Act of 1971. The State of Alaska,
under the Statehood Act of 1958, is in the process of selecting
land on the sale area. This is primarily at existing logging
camps, but some selections are scattered and are for purposes
other than community development. The Forest Service has
approved the Thorne Bay and Port Protection selections that
include units to be cut during the 1979-84 operating period,
with the condition that these units will be cut under the
contract. Details on these selections are shown on a map
accompanying the "Tongass Land Management Plan Final Environ-
mental Statement."
Issues
Most of the issues relative to the long-term timber sale are
thoroughly described in the TLMP and in the "Southeast Alaska
Area Guide." One additional issue relative to this timber
sale is the large timber volume and long-term duration of the
contract between LPK and the Forest Service. The concern is
that this contract is a constraint on the Forest Service in
applying measures to manage other resources. It is felt the
large volume committment becomes a constraint which forces the
Forest Service to give less attention to other values. However,
the other side to this issue is that if the job level is to beg
maintained, the same volume commitment would still be needed
regardless of the kind of contract. The National Forest
Management Act of 1976 validated the existing long-term timber
sales in Alaska, but the issue is still disputed by some.
Those issues which are pertinent to the 1979-84 operating
period of LPK and covered in more detail in the TLMP are as
follows:
Economic Issue--The Ketchikan Area greatly relies on the
existance of the pulp mill, sawmills, and related logging for
its economic well-being. The issue is whether or not the
Tongass National Forest will continue to supply the timber
volume needed to maintain this reliance at its present level.
24
Wilderness/Backcountry Issue--The areas on the LPK sale where
wilderness is an issue are Salmon Bay Lake, Karta, and parts
of Sarkar and Honker Divide. The concern is that all or some
of these should be preserved as wildands for future generations.
G. Management Concerns
The timber that is selected for harvest must "appraise out."
This means that it must be economically viable. It must give
a return, including capital investment in road construction,
greater than the costs associated with harvesting and allow a
reasonable opportunity for profit. The degree to which the
marginal component will be included and the way in which other
resources are protected are factors that are balanced against
selling values to indicate a viable sale.
Another management concern is that the harvest should be
planned so as to allow road connections desirable for National
Forest management. This is to enhance recreation access on
the island, provide safer and cheaper transportation between
administrative sites, and access for future management activi-
ties.
The LPK contract provides that the Regional Forester may not
deny permission to export western redcedar logs harvested from
the sale area unless a competitive market for those logs
exists in Alaska. No competitive market now exists. Therefore,
western redcedar logs harvested from this sale area may be
exported outside Alaska without primary manufacture. The
Regional Forester intends to implement alternate pricing
systems for western redcedar logs that may permit a competitive
market to develop. While no competitive market has been
demonstrated, the Regional Forester intends to monitor market
conditions. If a market develops during the 5-year period,
export of unprocessed western redcedar logs may be restricted.
Iii. EVALGATION CRITERIA
The evaluation criteria used to weigh the alternatives are a combina-
tion of contractual, social, economic, and resource management
requirements. The long-term timber sale agreement specifies several
conditions relating to the selection of harvest units. The entire
agreement is printed as Appendix A. The following criteria were
developed from this agreement.
Zs
Other noncontractual criteria are as follows:
IV. ALTERNATIVES CONSIDERED
Alternative maps are enclosed showing proposed timber harvesting
and roading activities for each alternative. These are small-scale
maps; for those wanting to review detailed maps, they are available
for review at the Ketchikan Area Office of the Forest Service.
LSA The volume of timber selected should equal 960 MM bf
and be located on the primary sale area.
Ze Timber selected for harvesting shall include rapidly
deteriorating timber killed or damaged by fire, insects,
or windthrow or selections made in order to protect other
important national forest interests.
3. Timber selected for harvest will result in an econom
ically viable operation as described in Section ld. of
the long-term contract.
4. Refrain from selecting units in roadless areas
nationally identified as having potential for wilderness
or roadless recreation. Within the primary sale area,
these are Karta, Salmon Bay lake, and parts of Sarkar
Lakes and Honker Divide.
5- Design harvest units and logging systems so that
leave strips and deferred areas will be economically
available in the future.
6 Complete the forest multipurpose intraisland road
system to connect all land-based logging camps on the
Prince of Wales Island portion of the sale area to better |
facilitate National Forest management.
Te Maintain social and economic stability in the
Ketchikan Area of the Tongass National Forest.
8. Conform to policies established by the "Southeast
Alaska Area Guide," published by USDA Forest Service,
Alaska Region, in April 1977.
9. Conform to "Operating Guides for Timber Sale Layout'
when not in conflict with other criteria. These guides
are printed in Appendix B.
26
Alternative 1 is the LPK selection of harvest units presented to
the Forest Service. The alternative would harvest 960 MM bf
from the primary sale area in 380 units averaging 82 acres in size.
Twenty-two of these units are 160 acres or larger. The size range
is from 9 to 546 acres. The unit boundaries when overlaid with
timber type boundaries generally coincide with the highest volume
timber types available in the area and emphasize harvest economy.
The logging systems proposed include hi-lead, hi-lead with cold
deck swing, A-frame with cold deck swing, helicopter, and skyline.
Road construction under this alternative would extend the existing
network and tie Coffman Cove camp to Naukati. Ratz Harbor would be
connected to Coffman through Baird Peak. Log transfer sites would
have to be constructed or rebuilt as shown on the alternative map.
Under this alternative most roadless and undeveloped areas over
5,000 acres in size and remaining on the primary sale area would be
entered by 1984.
Alternative 2 is a plan to take no action. Under this alternative
the Forest Service would not allow the harvest of any other timber
or the construction of any roads on the sale area in 1979-84. Lack
of maintenance would require closure of all roads to the public.
Alternative 3 has 400 units averaging 60 acres in size for harvesting
790 MM bf from the primary sale area. Eight of these units are 160
acres or larger. The size range is from 1 to 700 acres. This
alternative places emphasis on the forest's amenity values, such as
wildlife habitat and scenic beauty. Areas were selected for harvest
only if no adverse, or only minor adverse, activities would affect
amenity values. Exceptions were made to harvest major blowdown
areas as a result of the late-October storm in 1978.
Logging proposed under this alternative would include hi-lead, hi-
lead cold deck, A-frame cold deck, and several skyline variations.
Favorable factors of timber operability are used to protect amenity
values.
Road construction would extend the existing network from Naukati to
Labouchere Bay through Coffman Cove, Whale Pass, El Capitan, and
Turn Creek. Ratz Harbor would be tied to Coffman Cove through Luck
Lake. Except for Karta, Salmon Bay Lake, Sarkar Lakes, and Honker
Divide, most roadless and undeveloped areas would be entered this
period.
Alternative 4 has 480 units averaging 70 acres in size for harvesting
960 MM bf from the primary sale area. Fifteen of these units are
160 acres or larger. The size range is from 1 to 700 acres. These
Zi
Alternative 5 would exclude from harvest all areas over 5,000 acres
EFFECTS OF IMPLEMENTING ALTERNATIVES
units would not necessarily provide the highest timber volume per
acre, but instead they would develop areas so as to salvage blowdown
timber and prevent loss of residual timber because of windthrow or
lack of access.
The logging systems proposed include hi-lead, hi-lead with cold
deck, A-frame with cold deck, and several skyline variations.
Road construction under this alternative would extend the existing
network of roads and connect Coffman Cove to Naukati. El Capitan,
Whale Pass, and Labouchere Bay would be connected to Naukati through |
Sarkar Rapids. To facilitate the completion of the intraisland
road system, it is necessary to leave the primary sale area between
Naukati and Whale Pass, thus including the "Clam Chance" timber in
the long-term sale. Additionally, a road connection from Coffman
Cove to Ratz Harbor through Luck Lake would be built. With the
exception of Karta, Salmon Bay Lake, Sarkar Lakes, Honker Divide,
most of the roadless and undeveloped portion of the sale area would
be entered during 1979-84. 1
on the sale area which are now roadless and undeveloped. These
areas were identified in the RARE II planning process. Within the
sale area, this alternative is the same as Alternative 4 minus
development in roadless areas. It has 350 units averaging 70 acres
in size for harvesting 694 MM bf on the primary sale area. Twelve
of these units are 160 acres or larger. The size range is from 1
to 700 acres. The only arterial road connection would be from
Coffman Cove to Naukati and Ratz Harbor through Luck Lake.
This section describes the effects of implementation that each
alternative would have on the sale area. The types of effects are ©
described, based on experience with previous logging on the sale
area. The degree of effect is based on an estimate of various
data, such as acres to be cut, miles of roads to be built, and
steepness of slopes involved. These and other similar data are
estimated, because the fieldwork, such as road design and sale unit
layout, will be done during the next 5 years. Thus, this information
cannot yet be quantified. But, all available information was used
to develop the effects discussed in this section, including aerial |
photographs and on-the-ground assessments by specialists.
28
Soils
Some soil disturbance, with resulting consequences, is unavoid-
able when natural systems are disturbed. Soil erosion as a
mass land failure on slide-prone slopes may be accelerated
where mineral soils are exposed, overland drainages are altered,
and roads concentrate runoff. The first step in reducing or
preventing erosion is to minimize the occurrence of factors
leading to accelerated rates. Yarding of suspended or partially
suspended logs disturbs less area than tractor logging or high
leading with little or no lift. Also, suspended logs disturb
less area than partially suspended logs when yarding downhill
on steep slopes. Surface runoff materials will be less likely
to reach the streams if the proximities of landings, roads,
and sale units to streams are properly designed and regulated.
Where mineral soils are bared and pose a threat of lower
productivity or high stream sedimentation, grass seeding with
fertilization will be done to minimize surface erosion.
Canopy removal increases solar radiation reaching the forest
organic layer. This results in surface warming (Gregory 1956)
and increased decomposition rates. By increasing decomposition,
more available nutrients are released. The long-term effects
from this are not yet known.
Youthful alluvial soils are subject to extensive erosion from
periodic flooding and stream abraiding, depending on the
degree of hazard. Activities on these soils must be done
carefully or avoided to prevent stream damage.
Timber harvest units and roads could accelerate streambank
cutting and surface erosion on V-notch drainages. These
impacts can be largely controlled when properly managed.
Yarding across or down V-notch drainages generally requires
total suspension of logs. V-notches are high hazard areas,
that require a detailed investigation by an interdisciplinary
team before proposed activities begin.
Alternative 1--More soil erosion and loss of productivity
would occur in this alternative than any of the others. The
unfavorable impact in this alternative would result from not
meeting many required guidelines during logging and roading.
Timber productivity would be temporarily impaired over a
greater number of units and acres through organic layer removal.
This disturbance would result from using high-lead yarding on
areas where partial or full suspension should be used. Organic
layer removal and mineral soil disturbance in these units
29
would result in unacceptable accelerated soil erosion through
mass failures and sheet erosion, especially where associated
with V-notch drainages, slopes in excess of 68 percent, and
soils with unstable characteristics.
Ordinarily, duff layer disturbance (raw mineral soil exposure)
from high-lead logging amounts to about 5 to 15 percent, but
under this alternative up to 50 percent can be expected. Soil
productivity for conifers will be reduced (on a 100-year
cutting cycle) about 15 to 20 percent on soils not scoured to
bedrock if they go through an alder stage. Without an alder
stage, the setback is usually much higher, perhaps 50 percent.
Where the soils are scoured to bedrock, productivity will be
greatly impaired for the duration of the cutting cycle.
Several sections of roads are on soils and slopes where erosion
would result in unacceptable sedimentation to streams and
lakes. Other adverse effects on water quality because of
sedimentation from road construction would be short-termed and
perhaps significant or measurable only during major rainstorms. |
Alternative 2--Soils would be affected minimally under this
alternative. The Forest Service would be required to take 1
some immediate actions for closing unneeded roads and stabiliz= ]}|
ing exposed soil areas. Some soil disturbance and sedimentation,
although minimal and short-termed, will result from removing
nonessential bridges and culverts and ending road maintenance
for permanent roads on Prince of Wales Island.
Alternatives 3 and 4--These two alternatives from the soil
aspect would be equivalent in environmental impacts, even
though Alternative 4 has more units and acres. The increase ©
of units and acres in Alternative 4 over Alternative 3 are
units and acres that would not need special mitigating action
from the soil aspect. Mitigating actions in the form of
partial suspension or full suspension over nearly the entire
length of the yarding distance would be required for 40 units
to decrease adverse soil disturbance effects. Despite all
mitigating actions that could be applied in these two alter-
natives, some adverse impacts would result; however, these
impacts would be less than under Alternative l.
Timber productivity can be expected to be temporarily impaired
wherever the organic layer is removed. This disturbance would
amount to about 5 to 15 percent under these alternatives. The
effect would be the same as stated in Alternative 1 for conifer
regeneration and the cutting cycle.
30
Surface erosion would be accelerated in some areas, and some
sediment production to streams could be expected when roadbuild-
ing across streams or logging on stream edges.
Alternative 5--This alternative is nearly the same as Alter-
natives 3 and 4, except only 19 of the 40 units needing
special mitigating action would be logged. The other 21 units
are dropped in this alternative, since they are in roadless
areas. The adverse and beneficial effects for the units in
the roaded portion will be the same as stated in Alternatives
3 and 4. Short-term adverse impacts would result despite
mitigating actions.
A more complete discussion of the effects on soils may be
obtained on request in the "Soils Specialist's Report." See
also the soils guidelines in Appendix B for soil management
practices used in this plan.
B. Water
The following analyses are presented to highlight the key
impacts. Timber harvests can affect both water quality and
quantity. In southeast Alaska, the primary impact would be a
slight increase in sedimentation over natural levels. Many
stream systems are susceptible to increased sediment loads
caused by harvesting activities. The most sensitive streams
are those which naturally produce the greatest amount of
sediment, namely V-notch drainages, alluvial fans, and abraided
stream systems. Roads pose the greatest threat for increased
sedimentation from road pioneering work, culvert and bridge
construction, cut and fill slopes, road surfaces, and borrow
pits.
Although the increase in sediment is the main effect from
logging and road construction, increases are relatively low
compared with other regions of the United States. One of the
main reasons for the low recorded increase in sediment in
Alaska is the type of roads most frequently constructed.
Roads are, for example, generally of overlay construction,
built with rock blasted from quarries. When properly graded
material is used, there is little source of sediment available,
and the coarser material also provides an effective trap for
what does exist. Stream crossings then become the key location
and control point from the standpoint of sediment production.
31
In general, southeast Alaska streams are not considered to be
highly sensitive to temperature changes resulting from timber
harvest. Frequent cloudiness, low air temperatures, steep
channel gradients, and frequent precipitation tend to keep
stream temperatures below the range considered harmful to
fish. However, stream temperatures may be increased if long
strips of shade-producing vegetation are removed from along
south, southwest, west, and northwest banks of temperature-
sensitive streams. The streams most likely to be temperature-
sensitive usually contain lakes and muskegs and organically-
stained water, have low channel gradients, and southeast to
southwest exposures.
The same natural characteristics that keep stream temperatures
low also act to maintain high concentrations of dissolved
oxygen (D.0.). Dissolved oxygen levels and biochemical
oxygen demand may be affected if logging slash is allowed to
accumulate in streams. There are requirements to remove
logging debris from streams and to mitigate reduction in water
quality, mainly D.O. and tannins and lignin's. But, generally,
southeast Alaska streams are not considered highly sensitive
to D.O. depletion from timber harvesting activities.
Temporary changes in water quality can be expected from timber
harvesting. But, all anticipated changes could be reduced to
acceptable levels and returned to natural levels through
proper planning and enforcement of watershed protection
measures during and after logging activities.
Changes in streamflow would probably be negligible. Normally,
restrictions on cutting design eliminate the potential for a
measurably increased streamflow.
Sewage effluent from logging camps would have an impact on the
marine environment in the form of nutrients. In all alter-
natives, onsite investigations and development of specific
watershed protection measures would be required whenever
sensitive landforms and channel systems are encountered.
At present, an active program for monitoring water quality is
being conducted to help quantify the effects under various
natural and manmade conditions. To develop some insight into
the effects of hydrologic responses resulting from timber
harvesting, other accounts were reviewed and documented.
a2
In western Oregon, streamflow changed, annual yields and
summer low flows were changed significantly on very small
headwater basins. These changes have only onsite importance,
since water flowing from uncut areas overshadow the increases.
Changes in yields in larger basins were indicated as being
very small (Harr 1975). Also in western Oregon (Rothacher
1973), the report states, "Under these conditions there are
indications that the highest peak flows from logged watersheds
are rarely greater than they would have been if no logging
occurred." In Canada, the time to the streamflow peak and to
increased and peak flow magnitude both decreased significantly
(Cheng, Black, de Vries, Willington, and Goodell 1975). Under
certain circumstances, the potential water-yield increase on a
northern Idaho watershed may be high; but, under other condi-
tions, the increase can range from negligible to moderate
(Cline, Haupt, and Campbell 1977). Though these increases or
decreases occur to varying degrees, their significance depends
on the size of drainage, orientation, wind exposure, forest
stand density, and soils. The Harris River study examplifies
this in that a large drainage was harvested with insignificant
affect to the streamflow when compared to unlogged Indian
Creek (Meehan, Farr, Bishop, and Patric 1969). The logging in
Harris River was 20 percent of the drainage area, the study
conclusions were drawn at the mouth of its 31.8-square-mile
area which dampened a great percentage of the response to
timber harvest.
A more recent investigation on streamflow response after
timber harvesting (Bartos 1978), showed that responses were
detectable when 30-35 percent of the watershed was harvested,
and a substantial increase in water yield began to be evident
in the analysis.
The investigation on the Staney Creek on Prince of Wales
Island drainage shows that the increased discharge is primarily
included in the mean to lower flows. The peak flows show
little to no significant affect from timber harvest. So, is
presumable that harvesting less than 20 percent of a drainage
area would have little to no detectable affect on streamflow.
At the present time, there are studies proposed to investigate
sediment production from road construction, mainly at or near
culverts and bridges on Prince of Wales Island. Data thus far
obtained from bridge site construction show insignificant
increases in suspended sediments for very short durations (5-
15 minutes) during a stream contact period.
33
The Water Resource Inventory Program (beginning in the 1979
field season) will determine landform-streamchannel sensitivity
relationships which, in turn, will be related to other hydrolo
gic data... dm all: alicerna tee but Alternative 1, either the
"best management practices" developed by the Alaska Department
of Environmental Conservation or equivalent measures develo
by the Forest Service would be implemented to control nonpoint
pollution from timber harvest activities. The effectiveness
of these measures would be evaluated through the monitoring
program, and results would be used to determine compliance |
with existing State water quality standards.
Water quality monitoring at baseline or project gaging stations
has and will obtain the following data:
*Temperature.
*Dissolved oxygen.
*Alkalinity.
*Ph.
*Suspended sediment (with a DH-48 integrating sampler).
*Bedioad transport volume.*
*Bed gravel to a 4 inch depth.*
*Conductance turbidity in NTU's.
*Water quantity in cubic feet per second and (discharge)
and measured in percentages by weight.
Water samples obtained in the field will be analyzed in a
laboratory for the following:
*Total nitrogen.
*Total phosphorous.
*Calcium.
*Magnesium.
*Potassium.
*Sodiun.
*Tannins and lignins.
Baseline and project stations are:
*Bonnie Creek at Shaheen.
*Alpha I Creek at Sweetwater.
*Perkins Creek at Moria Sound.
*Big Creek at Whale Pass.
*Old Tom Creek at Skowl Arm.
*Indian Creek near Hollis.
The time frame of sampling is once every 2 weeks between
April/May to November/December and every 2 months during
34
winter. At project sites, such as culvert or bridge construction
or any other environmental alteration, the following items are
measured (Sampling at these sites is done above and below the
project site):
*Suspended sediment with a DH-48 integrating sampler or
ISCO pumping sampler. Duration of sampling 15 minutes to
1 hour between sampling for the period of operation in or
near a stream.
*Discharge in cubic feet per second.
*Bedload, if possible.
*Turbidity in NTU's.
*Conductance.
If, at any time before construction of roads or timber harvest,
an IDT anticipates a violation of the State water quality
standards, a short-term variance from the D.E.C. will be
requested. All other timber harvest activities will be
initiated with the full intent of following Forest Service
"best management practices."' For other specific analyses of
effects that would also apply to water, see "Effects on Fish"
and "Effects on Soil."
Table 5 shows the extent of harvest areas by slope class.
Table 6 lists the miles of water courses adjacent to timber
harvest units. The table shows Alternative 1 as having signifi-
cantly more miles of water course affected by timber harvest
than the other alternatives.
TABLE 5--Estimated number of acres in areas
planned for timber harvest in the
1979-84 period by slope class
for each alternative
Alternatives g Slope class
: 34-37 degrees —: 37 degrees or more
$ Acres
1 : 5,800 2,000
A 0 )
3 3,900 900
4 4,650 1,100
5 2 3,300 800
315)
TABLE 6--Extent of stream miles affected on the
sale area by timber harvesting alternative 1/
Stream location or : Extent of streams affected by Alternative--
description adjacent: : 3 ‘ g
to harvest units : 1 : 2 : 3 : 4 ira)
g Miles
Watercourses Ripeo 1s IS Wo 0 VOY, 260 1555.
Waters inaccessible : 13.30 0 elo 9.00 4.95
to anadromous fish:
Intertidal areas > 8450 0 - 80 i 520 0
Lakeshores 2 355 0) - 30 -40 Piles)
Streams accessible : 34.20 0 11.45 550 10.45
to anadromous fish:
Temperature-sensi- : 17.50 0 3.30 3.00 1535
tive streams :
accessible to
anadromous fish
1/ Distances scaled from 2-inch-per-mile forest maps.
Alternative 1--This alternative would have the highest potential
effect on water quality because of the excessive ground distur-
bance as a result of high-lead logging mainly on planned
harvest acres in the slope classes of 34 to 37 degrees and 37
degrees or more. Some acreages on these slopes were not
accepted in the other alternatives, even with use of best
available management practices.
Several sections of roads are on critical soils and slopes
where soil erosion will result in unacceptable sedimentation
to streams and lakes. These sections of roads are on slopes
greater than 34 degrees and are close to water bodies. Other
adverse effects on water quality because of sedimentation from
road construction will be short-termed and may be significant
or measurable only during major rainstorms.
Alternative 2--The only effects foreseeable under this alter-
native would arise from sedimentation resulting from removal
of bridges and culverts following closure of no-longer-needed
roads in the sale area.
36
C.
Alternatives 3, 4, and 5--These would affect water quality in
similar ways. These alternatives call for less timber harvest-
ing on steep slopes than would Alternative 1, and they provide
for appropriate logging systems to mitigate impacts that would
otherwise occur if high-lead logging took place on 34- to 37-
degree and 37-degree or more slope classes selected for harvest
in these three alternatives. The appropriate logging systems
planned for these alternatives will supply partial and full
suspension on slopes greater than 34 degrees. These logging
systems will reduce the potential for short- and long-term
mass movements by minimizing ground disturbances during yarding
of logs. Partial and full suspension on sensitive landforms
protects other ground cover and usually does not uncover and
expose mineral soil. Protection of other ground-cover plants
and the organic duff do much to help stabilize steep slopes,
especially when stump roots are no longer effective in holding
the soil. The soil guidelines in Appendix B for soils manage-
ment practices gives the specific guidelines for logging on
these slopes and soils. Considerably fewer miles of streams
would be affected by timber harvesting adjacent to streams
under these alternatives than would Alternative 1. But,
temporary stream sedimentation will occur where roads cross
streams or where harvest units are adjacent to streams.
All alternatives, except Alternative 1, are believed by the
IDT to be within the guidelines established for the long-term
sale (Appendix B) and the "Southeast Alaska Area Guide." Even
so, some adverse but acceptable effects will result, despite
whatever mitigating actions are applied.
A more complete discussion of the effects on water may be
obtained on request from the Forest Service in the "Hydrologist
Specialist's Report."
Fish
Reviews of literature on the effects of logging indicate that
many environmental variables simultaneously operate in the
forest/stream ecosystem. Complex variable interactions occur
when development activities are being initiated, are underway,
or have ceased. Research efforts over the past 25 years have
identified many parameters and interactions that result when
timber harvest developments and fisheries resources occur
together. Numerous studies have shown that indiscriminate
logging practices do have measurable adverse consequences upon
the aquatic environment at site-specific locations. However,
many detailed research efforts to determine long-term effects
37
have resulted in inconclusive results. To date, research has
not shown that timber harvesting as conducted in southeast
Alaska has significantly affected fisheries resources on a
long-term basis.
Anyone familiar with research efforts must be continually
aware of all the essential data related to the stream environ-
ment. Likewise, the extreme difficulty in isolating or control-
ling these interacting factors must be carefully scrutenized
so that the selected factor may be clearly assessed. The
problem of factor isolation is especially evident in the
controversy between timber harvest and protection of the
fisheries resource of southeast Alaska. Many researchers, in
their efforts to relate the effects of logging to salmon
populations and harvest, believe that fisheries stock management
(regulation of fishing) is a significant factor that overshadows
environmental influences. Conversely, other researchers feel
that habitat modification is the major factor to consider.
Until more definative research is completed in southeast
Alaska, and these interactions are defined, conjecture will
continue and managers of both fish stocks and habitats will
continue to be criticized.
|
|
Both critics and managers have acknowledged the nonexistence
of valid research data that statistically and conclusively
demonstrate that forest practices in southeast Alaska have
affected long-term fisheries production. However, all parties
concerned do recognize the results obtained from laboratory
and field research regarding short-term effects from specific
manipulations. This is especially true when timber harvest is
conducted without regard for the aquatic environment.
Optimum management directions of both timber and fisheries
resources are often in direct conflict. It is not realistic
to expect or allow total development or protection of one
resource at the expense of another.
PO ee eee
To achieve the necessary interaction required for multiple use
management, resource management and protection guidelines and
policies were developed (See Appendix B and the "Southeast
Alaska Area Guide"). All available information, techniques,
and research data regarding the effects of logging on aquatic
resources were reviewed in an effort to formulate effective
resource guidelines. Biologists and land managers from State
and Federal agencies, working together, have developed the
policies of the "Southeast Alaska Area Guide" and the timber
harvest guidelines for the LPK long-term sale. These efforts
38
were intended to relate and thus, control environmental factors
that are critical and may be damaging during timber harvest.
When attempting to describe and document the effects of forest
development on fisheries resources, several aspects must be
considered. These relate to the frequency, distribution, and
magnitude of a given effect or set of effects. These three
aspects that describe an effect must be related to a time
frame in which an effective description and evaluation may
result.
For the purpose of evaluating the 5-year harvest plan and its
effects on fisheries resources, effects are grouped into
short-term and long-term impacts. For discussion purposes,
short-term impacts are considered to be those that persist up
to 5 years from their initial occurrence; long-term impacts
are those lasting for more than 5 years.
To adequately emphasize and distinguish long- and short-term
impacts, certain assumptions must be made; the present state
of the art in research leaves little choice. These assumptions
have a rational foundation in available research information.
Using the basic assumptions stated in the fisheries specialist
report, predictions can and must be made regarding effects on
the fisheries resource and its habitats. Little evidence
indicates that resource protection prescriptions will be
totally adequate. They need testing. However, there is also
little evidence to indicate their failure.
Current Forest Service policies and guidelines represent the
best effort of specialists to incorporate the knowledge of
environmental variable interactions into management proposals
for resource protection. It is assumed that adoption of these
procedures will minimize or prevent disruption of all important
environmental variables that influence fish habitats and that
it will minimize or prevent adverse impacts. Adequate admini-
stration of policies and guidelines is necessary and assumed.
Until such time as more definitive data show the guidelines to
be in error, the best action is to use what has been developed.
Few measurable values were available to the IDT preparing this
plan. Prescriptions were developed (see Appendix B and the
"Southeast Alaska Area Guide") to protect fish habitat.
Current monitoring programs are testing these prescriptions
for adequacy. With this background and for the purposes of
this operating plan, a basic assumption will be made. That
is, if all forest development activities conform to accepted
39
policies and guidelines, completed as through site-specific
prescriptions, then unfavorable effects on fish and fish
habitat will be minimized to an acceptable level.
Alternative 2 will result in no adverse environmental impact
to fisheries resources resulting from the long-term sale.
Opportunities to conduct direct fish habitat improvement
projects using income from timber harvest would not be available.
Future impacts would depend upon what activities were eventually
undertaken.
Implementation of the timber-harvesting alternatives (Alter-
natives 1 3 4 and 5) will result in these general impacts:
*Increased stream sedimentation.
*Altered stream temperature regime.
*Loss and alteration of fish habitat.
*Altered estuarine habitat productivity.
*Increased access by people to productive fish habitats.
*Increased opportunities to conduct fish habitat improve-
ment projects.
ge
Increases in stream sedimentation--These increases are normally
short-term, lasting from 1 to 5 years. Most sediment is
introduced during rainstorms from areas where the ground is
disturbed during logging and road construction,.
Acta reli tn
——
Blowdown of streamside timber and mass wasting are also sources
of sediment. Intensive studies in the Hollis area on Prince
of Wales Island between 1956 and 1964 have shown that instream
sedimentation increased temporarily following timber harvest.
Subsequent sediment contents returned to prelogged levels
within 5 years. The natural hydraulic characteristics of
southeast Alaska streams (frequent flooding) are considered to
be responsible for reductions in sediment levels. The digging
activities of spawning salmon also contribute to gravel cleans-
ing.
ae
ee
Sedimentation inhibits intragravel flow and interrupts the
necessary gas exchange between deposited fish eggs and alevins
and the aquatic environment. Emergence of fry is also inhibited
by sediment filling the intragravel voids. Sediment also
contributes to physical, physiological, and thermal stress of
juvenile and adult salmon. Additional impacts of sedimentation
may be alterations in the biomass and species composition of
aquatic insects.
40
Adverse impacts of sedimentation may be expected to occur if
timber harvest and road construction coincide with areas of
unstable soils or steep slopes or if an unexpected mass wasting
event should occur that would affect fish habitat. Such
impacts would be cumulative when associated with similar
naturally occurring events in the same watershed.
Altered stream temperature regime--Fish streams in southeast
Alaska receive a substantial amount of shade from the stream-
side forest canopy. This canopy, in addition to the streamside
riparian vegetation, acts as a temperature moderator for
summer and winter temperature extremes.
Removal of the forest canopy by timber harvest directly
increases the input of solar radiation into the stream environ-
ment. Increased absorption of solar radiation results in an
increase in ambient stream temperature. This is especially
true for temperature-sensitive streams. Metabolic rates for
cold-blooded animals which inhabit this environment, primarily
rearing fish and aquatic insects, vary directly with the
ambient stream temperature. As an average stream temperature
increases, a relatively greater portion of the energy ingested
by a fish is required for bodily maintenance functions rather
than for growth. If demands for maintenance energy continue
to increase, eventually metabolic stress and death will
result. Dissolved oxygen levels also decrease.
It has been theorized that temperature sensitivity is not
confined strictly to summer warming. The forest canopy acts
as a temperature moderator during certain types of winter
extremes. Removal of the forest canopy followed by relatively
dry, cold winters will contribute to expanding the winter
extremes into the stream environment, resulting in mortality
of eggs, alevins, and juvenile fish. Thus, the overall effect
of altering the temperature regime of the stream environment
could reduce the potential productivity of the system to
produce fish.
The time span over which these temperature effects operate may
be several years. Where the shade-producing streamside
canopy is removed, ambient stream temperatures will not return
to normal until new forest regeneration and riparian vegetation
have attained sufficient height to provide adequate shade.
The time required for streamside vegetation to provide adequate
shade varies directly with the width of a stream. For the
latitudes of the Ketchikan Area, a stream 4 feet in width will
require streamside cover about 6 feet in height for effective
41
shade production. Coniferous regeneration will require 8 to
10 years to attain such heights. However, riparian vegetation
consisting of alder, salmonberry, and Devils' Club, will reach
the desired shade-producing heights considerably before the
coniferous trees.
Sufficient data are not available to quantify the loss in
potential fish production resulting from stream temperature
changes. It is estimated that, through proper streamside
management practices and application of the streamside cutting
restrictions for temperature-sensitive streams, the potential
reduction in fish productivity will be minimized to an accept-
able level and approach normal 10 years after harvest, depending
on the width and aspect of the stream.
Loss and alteration of fish habitat--Corrugated metal culverts
and log stringer bridges are the primary stream crossing
structures used by design engineers for forest roads in the
sale area. Stream crossing structures generally result in
habitat loss or alteration. This is especially true for coho
salmon, since many small streams are affected. Habitat loss
occurs from the installation of structures with artificial
bottoms directly over suitable fish habitat. The prime example
of this is where corrugated metal culverts are installed in
streams. Here, the stream bottom is replaced by metal and is
no longer suitable as spawning habitat.
There are however, recognized exceptions to the above situation.
Present-day culvert design guides require that, where natural
conditions provide suitable stream gradient and substrate,
culverts must be designed to pass both juvenile and adult fish
and encourage use of bottom materials for spawning. A design
concept that incorporated oversizing and burying of the culvert
has been tested and found to be very adequate for passing
fish. This concept further assumes that the natural streambed
will become reestablished inside the culvert following the
installation through deposition from upstream areas. A neces-
sary part of this design is a plunge pool built as an energy
dissipator at the outlet of the culvert. This pool is intended
to insure the maintenance of the deposited streambed inside
the pipe and also prevents formation of an out-fall drop.
Periodic storm events will wash this material from within the
culvert. Redeposition will occur from subsequent normal
flows.
The suitability of habitat inside culverts for spawning and
rearing is uncertain. Except for culverts on the gentlest of
42
gradients, the repeated flushing and shifting of substrate
inside the culvert will contribute to such unsuitability.
Observations of many culverts using this design have shown
that the resulting plunge pools provide very suitable rearing
habitat for juvenile coho salmon and adult and juvenile cut-
throat trout and Dolly Varden char. Umnobstructed fish passage
is also insured.
Additional habitat alteration results from natural undercut
streambanks being broken or removed or both during structual
installation. When log stringer bridges are constructed,
every effort is made to maintain the natural character of the
stream under the bridge. However, portions of the undercut
streambanks are often broken or lost by machine activity.
Reestablishment of these undercut banks requires extensive
periods of natural processes. Habitat from undercut banks is
lost completely when culverts are installed. It should be
noted, however, that undercut banks are dynamic in nature, new
ones being formed and old ones being lost through natural
stream cutting processes.
A further habitat alteration results when bridges create
channel restrictions. Restrictions cause stream velocities to
increase, and, in so doing, the scourability of the stream
increases. Shifting and redeposition of streambed substrate
downstream of a bridge will result. Eventually, a natural
equilibrium will be established between flow and substrate
deposition. The net result can be creation of major pools and
redistribution of spawning habitat. Such pools are often
beneficial to sport fisheries, because fish congregate in the
deeper water.
In an effort to quantify the loss or alteration or both of
fish habitat resulting from stream crossing structures, the
following analysis was conducted for this operating plan.
This analysis considers only corrugated metal culverts and log
stringer bridges. For each alternative, the number of miles
of new specified forest roads required were measured from
maps. For Alternatives 1, 3, 4, and 5, some of the existing
forest roads will require reconstruction. Replacement of many
road drainage structures will be required to meet new standards.
The numbers of such structures requiring replacement with
subsequent related fisheries impacts is unknown.
The necessary criteria and assumptions used to conduct this
analysis are listed as follows:
43
Pink salmon are dependent on the amount and quality
of spawning habitat available. They have no depen-
dence on stream rearing areas.
Coho salmon production in streams affected by road
structures is limited by the available rearing
rather than spawning habitat.
Using information derived from the appraisal package
for the 1974-79 operating period, an average of
seven culverts per mile of specified road was found.
It is estimated that of these, 15 percent occur on
fish streams where fish habitat will be affected.
Average stream areas affected by culverts are 40
feet in length by 4 feet in width for an average
area of 17.78 square yards of altered habitat.
Few culvert installations on fish streams affect
pink salmon spawning habitat. Since culverts are
primarily confined to smaller streams, pink salmon
spawning habitats are adversely affected only on an
estimated 1 percent of all culverts installed.
Rearing habitat is not totally adversely affected by
culvert installation. On streams of gentle gradient,
the redeposition of substrate materials inside the
culvert will continue to function as rearing area.
Outlet plunge pools create a very suitable rearing
habitat that helps to mitigate effects on habitat
altered because of the structures. Thus, it is
assumed that for all culverts installed on fish
streams, 50 percent of the coho salmon spawning and
rearing habitat is adversely affected.
Past appraisal data indicate an average of one
bridge per 2.8 miles of road.
Log stringer bridges, if correctly designed and
constructed, do not contribute to the loss of spawning
habitat and only somewhat to the disruption of
rearing habitat.
An estimate of the habitat altered by log stringer
bridges uses the length of each streambank affected
by the bridge. It is estimated that 15 yards of
streambank is affected by each bridge. Of this, it
is further estimated that only 50 percent of this
44
streamside distance is significantly disturbed. An
estimated width of 2 feet is applied to this distance
to calculate the habitat area affected.
10. It is assumed that spawning habitat will support two
spawners per square yard for pink salmon.
11. Coho smolt production is estimated by multiplying
the total habitat area in square feet by 0.031.
This value represents a summary of past research
information on habitat productivity for coho salmon.
An estimated 10 percent of the smolts will survive
to return as adults.
12. It is assumed that 60 percent of total annual pink
and coho salmon production is available for harvest;
the remaining 40 percent is necessary for spawner
escapement.
13. Current average commercial fish values were obtained
from the Alaska Department of Fish and Game. These
are $1.12 per fish for pink salmon, and $8.00 per
fish for coho salmon.
Using the above information and assumptions, the calculations
in table 7 estimate the areas of habitat and the potential
numbers and value of fish affected by road structures during
the 1979-84 operating period for each alternative. The numbers
presented in parentheses in table 7 refer to the criteria and
assumptions previously stated.
TABLE 7--Areas of habitat and potential numbers and values of
fish affected by road drainage structures by alternative
1/ Alternative--
Item — 2 Leas Z : ) : 4 : 5
Miles of road 260 0 250 235 25
Number of culverts (3) 1ee20 0) Os eet, 045 875
Number of bridges (7) 93 0 89 84 45
--Continued
45
TABLE 7--Areas of habitat and potential numbers and values of
fish affected by road drainage structures by alternative-—-Continued
iy : Alternative--
Item — : kes 2 : 3} : 4 : 5
Number of structures
affecting fish habitat :
Culverts (3) 3 213 0 263 247 13a
Bridges : 93 0 89 84 45
Total habitat affected by:
Culverts (sq. yds) (4): 4,850 0 4,675 4,390 25330
Bridges (sq. yds.) (9): 465 @) 445 420 225
Pink salmon spawning
habitat affected by
culverts (sq. yds.)
(5) (8 (3) (4) : 325 0 310 290 155
Coho salmon rearing
habitat affected
Culverts (sq. yds)
(6) 2 2,425 0 2,340 2,200) E65
Bridges (sq. yds.)
(8) (9) ¢ 465 0 445 420 225
Total (sq. yds) : 2,890 0 2,735 25620 -. -25390
Estimated loss in annual :
pink salmon escapement:
(no. of fish) (10) : 650 ) 620 585 310
Estimated loss in annual :
pink salmon harvest-
able surplus (no. of :
fish) (12) $ 970 0 935 875 470
Estimated loss in annual :
coho smolt production :
(no. of fish) (11) : 810 0 TAS) 730 390
Estimated annual loss in :
surviving coho smolt
(nos Of fish) (11) ‘ 80 0 80 7 40
--Continued
46
TABLE 7--Areas of habitat and potential numbers and values of
fish affected by road drainage structures by alternative--Continued
ily) : Alternative--
Estimated annual loss in :
harvestable surplus
for coho salmon (no.
of Lash) <Cl2) : 50 0) 50 45 25
Estimated annual monetary:
loss, an dollars, from:
Pink salmon (13) 2 LOO 0) 1,045 980 BAD)
Coho salmon (13) : 385 10) 373 350 185
0) Sie e200, si. 5350 $710
Total BSL ATS)
Estimated monetary loss,
in dollars, from
affected fish habitat
during 1979-84 opera-
ting period 2 7 375 0) TOO 6,650 35900
Aly Numbers in parentheses refer to the criteria and assumptions
outlined in this section.
Evaluation of the results of the analysis in table 8 must be
tempered by the following conditions:
*Estimated annual monetary losses from affected fish
habitats are maximum figures.
*This analysis is confined to specified roads only.
*Not all specified roads will remain open.
*Not all stream crossing structures are installed at the
beginning of the operating period.
*Some stream crossing structures are removed before the
end of the operating period.
From the data previously presented, it may be concluded that
Alternative 1 will result in the greatest adverse impact on
fish habitat from road construction. Except for Alternative
2, Alternative 5 has the least impact.
47
Impacts on estuarine habitat productivity--Because the geographi-
cal nature of southeast Alaska restricts heavy hauling to
water transportation, marine log transfer and storage sites
are a necessary aspect of timber harvest. Log transfer sites
physically require road access to the saltwater with a rela-
tively steep intertidal and subtidal terrain to insure ready
access of logs to deep water. Protection from severe weather
and rough water conditions is required. Specific guidelines
are available for selecting log transfer and storage sites.
These are listed in Appendix B of this document. Acceptable
log transfer and storage sites are locations away from the
mouths of fish streams, bay heads, shallow intertidal areas,
and other areas of highly productive esturine habitat.
Definite conflicts exist between current fisheries guidelines
and the aspects of site suitability for log transfer and
storage. From an economic standpoint, storage areas consist
of shallow estuarine areas with sufficient freshwater contribu-
tions and periodic exposure to air by grounding at low tide.
Such conditions inhibit log deterioration from marine boring
animals. However, such sites have undesirable environmental
impacts.
An estuary is defined as "all or part of the mouth of navigable
or interstate river or stream or other body of water having
unimpaired natural connection with the open sea and within
which the sea water is measurably diluted with freshwater
derived from land runoff."
Considerable research efforts have been conducted to establish
the commercial significance of estuarine resources. Efforts
have also been made to describe and quantify the environmental
consequences of log transfer sites and log storage on estuaries
and estuarine resources.
Estuarine resources of commercial significance consist of
Dungeness crab, King crab, shrimp, sablefish, halibut, herring,
and clams. All species of salmon depend on estuaries and
nearshore waters, especially post-emergent and rearing pink
and chum salmon. Commercial populations of crab and shrimp
commonly exist in bays where log transfer activities occur.
Diverse and abundant populations of other organisms provide
important food sources for commercially important species.
These organisms contribute to the productivity or "richness"
of the estuary.
48
During the process of transferring logs from the upland to
saltwater, several impacts occur. First, productive estuarine
habitat is covered by rockfill during construction of the
facility. Second, physical abrasion during handling dislodges
bark from logs. Bark accumulates in areas immediately below
and adjacent to the site. Investigations of existing and past
transfer sites have revealed extensive bark accumulations.
Variability in bark accumulation is high because of a combina-
tion of submarine terrain features and tidal currents. Bark
accumulations cover the natural habitat, smothering estuarine
plants and sessile animals. The necessary substratum for
planktonic larvae could adversely affect the estuarine food
chain. The species diversity of marine organisms can be
expected to decrease as a result of bark accumulations.
Probable reductions in species abundance may also result.
Levels of dissolved oxygen within the benthic substrate are
depressed to near anoxic levels when covered with bark. These
impacts are both short- and long-term in duration.
The sloughing of bark and debris during log rafting and
storage is not so severe as it is during log transfer. When
log storage rafts are allowed to ground, benthic habitat is
compacted and organisms are crushed. Log storage rafts
interfere with the light pentration, which reduces estuarine
primary production.
Organic leachates from bark are also contribute to adverse
effects on estuarine waters. Controlled laboratory tests have
shown bark leachates to be toxic to most estuarine organisms
at various concentrations. Lethal concentrations of leachates
throughout a natural estuarine environment have never been
shown.
Log transfer and storage does have definite effects on estuarine
resources. Significant quantification of these effects on
commercial resources is not possible by using present state of
the art measurements.
Site surveys and evaluations of log transfer facilities
proposed for use in this plan were conducted by the U.S. Fish
and Wildlife Service and the National Marine Fisheries Service.
These efforts are intended to insure that all log transfer
facilities conform to the "Southeast Alaska Area Guide" direc-
tives. The results of this work are included in the Appendix.
49
Estuarine effects from log transferring facilities will be
similar for each alternative, differing only in the number of
transfer facilities needed on the primary sale area for each
alternative. These are shown in table 8. The magnitude of
these effects on estuarine habitat are unknown until such time
as each facility is constructed, surveyed, and monitored.
Quantitative descriptions of the effects on estuarine productivity
and commercial resource populations are also not available.
It is assumed that site-specific surveys and guideline applica-
tion will reduce estuarine impacts to acceptable levels.
TABLE 8--New and reconstructed log transfer
facilities by alternative
2 New facilities Reconstructed facilities
: Transfer : Camps : Transfer : Camps
Alternative 2. points? 2: : points :
: Number
i 4 8 6 3 6
2 4 0 0 0 0
3 : 7 5 3 7
4 : 9 6 6 5
5 : 4 4 3 8
Increased access by people to lakes and streams--Expansion of
road systems would lead to increased sport fishing on many
stream systems. This impact would be long term if the roads
were kept open in the future as many are planned to be.
Increased opportunities to conduct direct fisheries habitat
improvement--Several streams on the sale area offer opportuni-
ties for stream enhancement work. This could be done through
appropriated funds or with KV funds from this timber sale.
Habitat improvement opportunities consist primarily of altera-
tion of natural barriers to fish passage. Other opportunities
are for removal of natural debris accumulations that adversely
affect fish habitat.
Opportunities to accomplish fish and wildlife management
projects would be increased by proposed actions during the
1979-84 operating period of this plan. These increased
opportunities are related to better accessability of project
sites and to the use of KV funds to finance work at selected
locations. Many of the projects could be accomplished without
the timber harvesting operations, for example, fishway construc-—
tion. Other projects would be induced by timber harvesting
50
activities and would not occur independently, such as stream
cleanup of blowdown timber along a harvest unit boundary.
Three categories of fisheries project work can be done:
*Fish habitat rehabilitation involving the removal of
instream debris and the stabilization of streambanks
where windfelled timber occurs within or adjacent to
harvest units.
*Fish habitat improvements involving the construction of
fishways to provide fish access beyond natural instream
barriers. These projects may be funded by (KV) money if
they are adjacent to harvest units.
*Fisheries administrative studies involving the study of
fish habitat and population relationships on or adjacent
to harvest units. These may also be funded by KV money.
Predicted effects of implementation--It is assumed that the
degree of impact on fisheries is directly related to the
extent of harvesting adjacent to fish streams. The proximity
to fish streams is not the sole criterion, however, as stable
or relatively problem-free ground immediately adjacent to a
fish stream can be less of a concern for fish habitat protection
than unstable ground well away from the stream.
Table 6 shows the varying extent of streamside cuts by each
alternative. Comparisons of these data show that the amount
of proposed timber to be harvested in low-elevation and
valley bottom lands is substantially greater for Alternative
1. Also, considering the nature of the topography and stream
morphology in southeast Alaska, a large percentage of the
accessible habitat for anadromous fish occurs in these same
low-elevation valley bottom lands. Therefore, it may be
concluded that Alternative 1 will cause a substantially greater
impact on fisheries resources than will any of the other
alternatives.
oy
Unavoidable short-term impacts from timber harvesting, even in
conjunction with the best possible application of habitat
protective prescriptions, are sedimentation and disruption of
fish habitats from temporary road drainage structures. Addi-
tional short-term impacts will result from occasional slash
and logs from hazardous trees falling into or across fish
streams. Some fish and wildlife species would receive increased
localized pressure from recreational activities near logging
camp facilities.
Unavoidable long-term impacts will be habitat loss or alteration
or both from permanent road drainage structures, fill from log
transfer facilities, and accumulations of bark in estuaries.
The altered temperature regime in temperature-sensitive streams
would be a long-term impact for Alternative 1. Additional
possible long-term impacts will be sedimentation, streambank
disruption, migration blockages, human use, and disruption of
stream channel stability resulting from blowdown of residual
streamside timber.
Environmental impacts that are cumulative in nature are habitat
losses from expansion of the forest road system and fills and
bark accumulations at log transferring facilities. Continuous
timber harvesting in watersheds that contain temperature-
sensitive streams would create a cumulative impact on the
temperature regime if Alternative 1 were chosen.
For further details on impacts on fisheries, see the "Fisheries
Specialist's Report."
Wildlife
Developmental activities in the forest environment have varying
effects on different species of wildlife. Many of the species
present in southeast Alaska are most adapted to using the old-
growth spruce-hemlock stands. Converting these stands to
second growth, as Alternatives 1, 3, 4, and 5 propose, would
change the habitat productivity for these wildlife species.
Table 9 shows estimates of the amount of old-growth habitat
each of several key wildlife species need for maintaining
populations levels.
ey
TABLE 9-—Percentage of natural cover types believed necessary
to maintain wildlife populations
: Extent cover needed in the wildlife habitat
Specie or group : management unit 1/
Sub- : General : : General : Winter
; alpine : forest : Estuarine: beach : range
: Percent
Sitka Black-tailed Deer : 50 50 50 50 90
Black Bear 50 BES) 100 25 DS
Wolf : 50 50 50 50 90
Waterfowl : - - 100 - -
Pine Marten ; 50 50 50 50 50
Land Otter : - - 50 50 50
Mink : ~ - 50 50 50
Beaver 3 - = 50 50 50
Upland Game Birds s 50 50 50 50 50
Shore Birds : - - 100 - ~
Nongame Land Birds 50 50 50 50 50
Small Mammals 2/ 5 pett10 50 50 50 50
Marine Mammals 2/ : = - - - -
Amphibians and Reptiles : 72)5) DS) 25 25 725)
Water Birds : = - 100 - -
Raptors 2/ 9 P5=5)0) 25-50 25-50 25-50 25-50
Old-Growth Obligate Birds: 50 50 50 50 50
Northern Bald Eagle : - = 100 50 100
ally Dashes mean that the cover type is not directly related to the
primary habitat need by that kind of wildlife.
ZY Levels of natural habitat necessary for population maintenance
were not set as a part of TLMP. These estimates considered the
habitat needs of species; others were set as a part of TLMP.
With these levels in mind, the following habitat management
objectives were set for each wildlife habitat management unit
(WHMU) :
Alpine--Habitat alteration by management activities is minimal
in this WHMU. Adjacent activity and disturbance of the wildlife
utilizing the alpine is the main concern because of the lack
of escape cover. Land management activities should be planned
in and adjacent to this WHMU so as to control human disturbance
and access.
Subalpine--Properly spaced units could allow harvest of up to
50 percent of the subalpine without significantly affecting
population levels of species utilizing this WHMU. Timber
53
harvesting patterns should emphasize dispersed patchcutting
with a maximum number of entries during a rotation period (100
years).
General Forest Area--Conversion of more than 50 percent of the
mature timber types of this area to management of even-age
stands can be expected to reduce populations of certain indige-
nous species. The spatial and temporal arrangement of cutting
units is critical to proper management of this habitat.
Maximizing the number of cover types will decrease impacts on
individual wildlife species and increase species diversity to
an area.
Key Winter Range--To maintain the natural carrying capacity of
the Forest for Sitka black-tailed deer, nearly all or at least
90 percent of this WHMU should be retained in the natural
state of climax spruce-hemlock forest or in a state which
approximates the climax forest attributes.
General Beach Fringe--This WHMU is highly utilized by wildlife
species. At least 50 percent retention of the natural cover
types is necessary to maintain the potential for natural
levels of wildlife populations.
Estuarine--It is necessary to retain 100 percent of the cover
types adjacent to the estuarine areas to maintain natural
levels of wildlife species. The adjacent cover types retained
should be 500 to 1,000 feet wide.
Each alternative is then evaluated to see how well it meets
the WHMU objectives. The sale area was divided into seven
subareas having similar past cutting practices. Analyses of
WHMUs were made for each subarea by alternative.
The average size of clearcuts would be 82 acres for Alternative
1, 70 acres for Alternative 3, and 77 acres each for Alter-
natives 4 and 5. A smaller clearcut size creates more edge
and therefore more habitat diversity. Figures 2 and 3 show
previous and proposed cuttings in key winter deer range and
the general forest zone. Table 11 shows the impact of each
alternative on certain species and groups of species.
Alternative 1--This alternative adversely affects all the
subarea's key deer winter range by changing more than 10
percent of the climax forest cover type to even-age stands
managed primarily for timber production (fig. 2). Analysis of
this alternative indicates that three WHMUs are negatively
54
affected. They include the general forest zone, key winter
range, and estuarine. Alpine, subalpine, and general beach
fringe receive little or no impacts as a result of the proposed
action.
The effects indicated vary according to subarea considered.
The effects are mostly related to the amount of key winter
range and estuarine WHMU timber harvested and to the spatial
and temporal arrangements of cutting units in the general
forest habitat management unit.
This alternative proposed cutting in the estuarine habitat
Management units of Staney, Naukati, Shaheen, Whale Pass,
Exchange Cove, and Lake Bay. The resulting cutting would
reduce the suitability of these areas to support natural
populations of indigenous species of wildlife.
Seven species or species groups will suffer adverse effects.
Three will be favorably affected (table 10).
TABLE 10--Relative effects on individual
species or species groups by alternative
: Effects of Alternative-- 1/
Specie or : 1 : 2 : 3 4 : 5)
Sitka Black-tailed Deer : - 0) - - -
Black Bear : 0 0) @) 0
Wolf : - 0) _ - -
Waterfowl : - 0) 0 0) 0
Pine Marten 5 - 0 - - -
Land Otter : 0 0 0) 0 0)
Mink : 0 0 0 ) 0)
Beaver “ 0 0 0) 0) 0)
Upland Game Birds 0 0 0) 0 0
Shore Birds : 0 0 0 0) 0
Nongame Land Birds ; a5 0) + + +
Small Mammals 2 + ~ + + +
Marine Mammals : - 0 0 0 0)
Amphibians and Reptiles : - 0 = - -
Water Birds - 0) 0 0 0 )
Raptors : + 0 + oF +
Old-Growth Obligate Birds = 0 = - -
Northern Bald Eagle : - 0 - - ~
1/ - = adverse effect, 0 = no effect, and + = favorable effects.
55
PERCENT CUT
° 3 8 -
Ov
Os
Bb
-
bone |
m
=
b
=
a
m
COFFMAN COVE
Bb
-
i |
m
2 :
> : A.W NAUKATI
< Pose) \
m
is]
l2-MILE
Lb
ie
bo |
mM
3
= NAUKATI
=
x
m
A
CUT PRIOR TO 1979
i ;
Z PROPOSED CUTTING |
FIGURE 2--Percentage of key winter deer range cut by alternative for each subarea
56
Percent Cut
os
STANEY
[ JAILVNYILTV
: S Rats os “UW te
=\\\AW COFFMAN COVE
a
3 “AW STANEY
€ FJAILVNYILIV
= i
A Se ee tee
oe Oe A
b FJAILVNYILIV
CUT PRIOR TO 1979
ZA
ZA PROPOSED CUTTING
FIGURE 3--Percentage of general forest area cut by alternative for each subarea
Alternative 2--This alternative will have no adverse effects
on wildlife populations, nor does it allow for enchancement
through patchcutting to increase edge and increase habitat
diversity. Species and their habitats would remain in their
natural balance without the habitat alteration of timber
harvesting.
Alternative 3--During the IDT process, wildlife resource
considerations were given emphasis by stressing smaller clear-
cuts, maximizing spacing between proposed and existing clearcuts,
harvesting in beach fringe areas only as habitat improvement,
protection of specialized habitat types including lake shores
and riparian zones, and maximizing age-class variety over
large areas, especially those areas with high recreation
potential. Areas of high potential recreational use of
wildlife included the Sarkar Lake, Behm Canal, Hollis, Harris
River, Gold and Galligan Lagoon, and along the main Prince of.
Wales Island interconnecting road system.
This alternative would basically meet all the habitat management
objectives, except for key winter deer range. Cutting in this ©
WHMU, although minor in extent, would reduce the carrying
capacity for deer in all areas except Staney Creek (fig. 2).
Alpine, general beach fringe, and subalpine habitat management
units would receive little or no impacts as a result of this
proposed alternative.
Alternative 4--The effects of this alternative on the wildlife
resource are similar to those of Alternative 3 (figures 2 and
3). During the IDT process, some minor wildlife tradeoffs
were made to stay within the primary sale area. Additional
cutting units in key winter deer range were made in the Staney
and Shaheen areas. Units were added in the general forest
zone, some adjacent to existing clearcuts. Any resulting
effects would be minor and localized, not significantly affect-
ing wildlife populations for any subareas.
Alternative 5--The units dropped from Alternative 4 to create
this alternative are all located in upland roadless areas away
from critical wildlife habitat. Th impact of this alternative
would be slightly less than Alternative 4 for wildlife dependent
on old-growth stands. Further details on wildlife effects may
be obtained on request in the "Wildlife Specialists Report."
58
Vegetation
Clearcutting under Alternatives 1, 3, 4, or 5 would lead to a
series of vegetative changes. A detailed description of these
can be found in the TLMP.
After logging, the vegetation would basically consist of
shrubs, forbs, and a few hemlock seedlings and saplings.
During the first 5 years, the additional light and heat reaching
the forest floor would cause a proliferation of shrubs and
forbs along with seedlings of spruce and hemlock. The shrubs
dominate the cover type for 10 to 15 years, at which time
spruce and hemlock begin to appear above the brush. After 20
to 30 years, the tree canopy normally closes and the brush is
shaded out. From then through the planned rotation age (gener-
ally 100 years), the stand would thin naturally to 100 to 300
trees per acre. The average 100-year-old tree is 110 feet
tall in southeast Alaska. Table 11 summarizes the number of
acres that would be harvested by alternative.
TABLE 11--Size of areas to be harvested on
the sale area by alternative
Alternative : Area
Estimated acres
Sub S33i0)
0
24,000
33,600
5 : 24,500
fon FH
Reforestation of cutover lands depends primarily on natural
reseeding from adjoining stands of timber and, to some extent,
from seedlings established previous to harvest. With minor
exceptions, natural reforestation has proved adequate in
southern southeast Alaska coastal forests. Planting with
nursery-grown spruce seedlings is anticipated on 50 to 100
acres per year where extreme competition from salmonberry is
expected to reduce natural restocking below acceptable levels.
Natural stands, especially on better sites, usually regenerate
too many stems per acre rather than too few. Under this
circumstance, it is often necessary to thin excess stems by
hand, usually 10 to 15 years after logging. This process
concentrates the growth potential on the fewer remaining trees
5)
resulting in faster diameter growth. "Patchy" reproduction
also occurs under some conditions of natural reforestation.
Under this situation, some parts of the new stand are over-
stocked with thousands of new trees, and adjacent areas may
have only a few scattered seedlings. A combination of thinning
and planting is used to correct this problem. A possible
prevention, suggested by limited observations in southeast, is
to burn the slash and brush remaining after logging to create
a more favorable uniform seedbed.
Much of the old-growth hemlock in southeast Alaska is infected
with dwarf mistletoe, a green parasitic plant. Hemlocks
heavily infected with this parasitic plant are subject to a
volume loss and are more vulnerable to attack by other diseases
and insects. Current control of dwarf mistletoe is to sever
all the unmerchantable hemlock left behind following clearcut-
ting to prevent reinfection of the new seedlings.
Timber
Clearcutting is the principle silvicultural system applicable
in the spruce-hemlock forests of southeast Alaska (Ruth and
Harris) for several reasons. Among these are species composi-
tion, dwarf mistletoe control, windfirmness, growth rate, and
susceptibility to injury during logging. Following are some
general impacts of harvesting timber by clearcutting that
would occur under Alternatives 1, 3, 4, or 5:
Loss of timber volume and productivity under this plan would
occur from the following sources: Unsalvageable windthrow,
areas retained to protect other values, and not converting the
entire area to young-growth stands now. These losses would be
irretrivable.
Increased tree vigor in new stands would reduce the loss of
wood fiber because of insect pests and diseases. Thus, annual
production or volume of wood harvested would increase following
the harvesting of old stands. The net annual growth of the
old-growth stands in southeast Alaska is zero, but in an
average stand on an average site, the mean annual increment is
524 boardfeet per acre or 52.4 M bf per acre at 100 years of
age (TLMP).
Roads constructed for timber harvesting would provide access
for timber management activities. Timber harvested by patch-
cutting would provide greater ecological variety in various
stages of plant succession as compared with cutting entire
drainages as done in the past.
60
Blowdown would occur along edges of some clearcuts; cutting in
small clearcuts under this plan could increase total blowdown.
However, Ruth states that windfall is closely related to other
factors, such as topography, soil, species, and stocking, and
that these other variables apparently exert more effect than
size of clearcut. Care would be taken during layout to locate
cutting lines to minimize blowdown.
Blowdown salvage--Severe windstorms on October 30 and November
1, 1978, did extensive damage to timber stands on north Prince
of Wales Island. Wind speeds of about 100 mph were recorded
at nearby Wrangell. The storm track appeared to come out of
the southwest and trend northeasterly, contrary to the prevail-
ing direction of winds from the southeast. Heavy rains accom-
panying the winds saturated the ground, contributing to the
windthrow of trees.
Red Bay, Salmon Bay, and Whale Pass areas were hardest hit,
although extensive damage also occurred as far south as Staney
Creek and Naukati. Much of the blowdown was associated with
existing roads and clearcuts, although notable exceptions
occurred on Marble Island and near Salmon Bay Lake.
Extent of storm damage was measured by visual estimates made
by foresters' from aircraft late in November 1978. Additionally,
photographs were taken of some areas and sketch maps made on
topographic base maps while observers were airborne. Roadside
observations were made in a few areas where the roads were not
blocked by fallen timber. A low sun angle and overcast skys
limited the hours of observation available. Thus, some
damaged areas may not be discovered until this summer. But,
it is unlikely that any significant area (more than 80 acres)
was overlooked.
The stands that blew down included areas laid out for logging
in the current (1974-79) operating period or areas planned for
inclusion in one of the 1979-84 alternatives, as well as in
areas reserved for future entries. The degree of damage
within stands varies as to the number of individual stems
blown over or broken off from approximately 40 to 100 percent.
Stands with damage to less than 40 percent of the stems are
difficult to see with aerial observation methods.
Intermingled with, and adjacent to, the downed trees are
standing live trees which must be felled and yarded with the
damaged trees. This is because the nature of the logging
techniques available to harvest timber. Timber is removed
61
from a harvest area by various overhead cable systems anchored
at both ends to stumps or trees. Logs are then pulled along
the cable system to a road for shipment by truck. Placement
of both ends of the system is important to insure strong cable
anchor points and to provide "lift" so that logs can be swung
free of obstacles where necessary. Scattered, intermingled
live trees interfere with the placement of the cables, and the
blown over, uprooted trees do not provide secure anchors, thus
necessitating the harvest of additional green timber.
Also, some blowdown occurred in leave strips between previously
harvested units. To remove just the damaged portion of these
leave strips would, in most cases, make the remainder physically
unloggable or uneconomical to harvest. The rest would also be
more subject to future windthrow because of the openings made
by the 1978 storm.
Table 12 shows the estimated acreage of windthrown timber, as
well as the total estimated acreage, including live green
timber, that will be harvested because of the windthrow. Also
shown is the acreage of previously planned units that will be
deferred because of their proximity to the blowdown.
The interdisciplinary team reviewed the logging plans to
harvest the blowdown timber in relation to Alternatives 4 and
5. Even though the team made strong efforts to hold the size
of units to less than 160 acres, this was not possible in
every case because of the desirability of cutting to windfirm
boundaries, the pattern of previous cutting, and the require-
ments of logging systems. Five of the 110 units necessary to
log damaged timber are larger than 160 acres. One of these,
mear Red Bay, exceeds 700 acres. Also, 18 to 20 leave strips
between previously cut units will be harvested. Although not
in themselves greater than 160 acres, their removal will join
units which aggregate more than 160 acres.
One effect of the windstorm on the long-term sale is to increase
the acreage available for harvest in 1979-84 by 2,940 acres in
Alternative 4 and 2,380 acres in Alternative 5. For Alternative
3, the increase is estimated to be 2,300 acres. This assumption
is based on salvage of the accessible down timber, with a
minimum of associated standing green timber. Unit size would
be kept small to enhance wildlife and visual values even if
nearby timber stands would be made uneconomical.
62
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63
By alternative, the overall effects on timber would vary as
follows:
Alternative 1 would harvest 960 MM bf of timber from the sale
area. Emphasis would be placed on obtaining maximum wood
fiber at low development cost. Generally, this would result
in large harvest units located in valley bottoms and lower
sideslopes. Harvesting of blowdown timber would be restricted
to timber which is readily available at roadside.
Heavy reliance on valley bottom road systems and high-lead
logging often isolates timber stands upslope from harvest
units. Future logging of such upslope stands is made difficult
by lack of tail holds for cable systems or the need to construct
roads through young stands of trees wasting the new growth.
This alternative seeks to harvest the lands with the highest
potential for timber growth remaining on the sale area. These
stands should be the easiest to regrow and yield the highest
return for the investment.
Alternative 2 would stop the harvesting of timber on the sale
area. The oldest stands would continue to breakup, blowover,
and regenerate naturally as they have for hundreds of years.
Very little if any net growth is occurring in these stands.
The younger stands originating from the cutting of the past 25
years would continue to grow at a fairly rapid rate, depending
on their site index. On the average, these stands should
reach culmination of mean annual increment at about age 80
(Taylor). They will of course continue to grow and add wood
for another 100 years before they reach a static old-growth
condition.
This alternative would forego the opportunity to replace the
old-growth timber with fast-growing second-growth stands. The
volume lost would be the difference in growth rates per acre
per year; the loss would be irretrivable.
Alternative 3 would harvest 790 MM bf on the sale area. The
emphasis of this alternative would be to harvest timber where
it would have a minimal impact on the wildlife and visual
resources. This generally means locating small or no-harvest
units along beaches adjacent to the ferry lane or in key
winter deer range. Cutting adjacent to previously harvested
areas would be restricted to only blowdown trees and inter-
mingled green trees. These areas would be left when the cost
64
of harvesting becomes greater than the value of the wood
recovered. These areas would also be left if salvage would
have required additional harvest of standing green timber to
reach a windfirm boundary.
In many cases, the Alternative 3 layout would not include all
timber available for harvesting in the first entry. In some
cases, camps would be moved by the end of the 5-year period,
leaving a few available first-entry units unlogged. It would
be costly and inefficient to return to these a few years
later.
Alternative 4 would harvest 960 MM bf of timber from the sale
area. Most of the units included in Alternative 3 are included
in Alternative 4. These units were made larger to increase
volume and salvage blowdown or to reach windfirm boundaries.
Additional units were placed along the Prince of Wales Island
main road system but not along the ferry route. A few units
were added in the beach zone.
Alternative 5 would harvest 694 MM bf of timber from the
primary sale area. The main emphasis of this alternative
would prevent development of any inventoried roadless area
greater than 5,000 contiguous acres. The units to be harvested
are identical with Alternative 4 units that occur in currently
roaded and developed areas.
TABLE 13--Cutting units larger than 160 acres
by alternative
Alternative--
iL = 2 : 3 : 4 : 5
Log transfer facilit :Units:Area:Units:Area:Units:Area :Units :Area: Units:Area
: No. Acres No. Acres No. Acres No. Acres No. Acres
Labouchere Bay >, al 169 1 703 3) ib jilSyA 3 134
Whale Pass GS 341 1 160 il Al y/il 1 I7/AL
Coffman Cove RS 888 i 161 3 697 3 697
El Capitan See --- - Seed = ao - ---
Calder : --- No - --- att 165 il 165
Shakan Bay > = --- £cutting - -- - --- - ---
Marble Island c= --- would - --- 1 234 - ---
Naukati <3 12 330 occur. 2 330 - --- --~
_ Shaheen a sD, 320 - Sa - a - a
Thorne Bay pot 162 = SSS 3 545 3 545
--Continued
65
: Alternative--
: L : Zz : 3 : 4 : D)
nsfer facility :Units:Area:Units:Area:Units:Area :Units :Area: Units:Area
> No. Acres No. Acres No. Acres No. Acres No. Acres
: 2A - --- - --- - -==
rbor 7 = ——= - --- = =—— = ===
Bay ti 197 if 298 i 197 i 197
ih 160 = --- = -—— - ===
eets - Sara = aaa = i oe oe
ve 3, 1,328 1 348 il: 342 = -—==
Hole al 546 = === = =-= - ===
ita : = =< os --- = —-—= = ===
"s Cove 7 = == os = as = a
Point fi ae - a - = = a=
Bay : 282 i! 168 al? 168 = =—==
A-Frames oo = - te - Se 3 a=
Creek 3 = -——— = —=— = —- 3 Sa
and {= -_—— = --— - == = =<
ee 168 - --- = --- - -—-
1 Harbor —— ae a ics = om
k fo --- - --- - --- - ---
tals + 22 51,098 8 2,168 TS 3,093 12 2,909
erage unit size: 232 271 243 243m
shes indicate that no units were larger than 160 acres.
TABLE 13--Cutting units larger than 160 acres
by alternative--Continued
G. Socioeconomic
Implementation of any one of the alternatives would affect
jobs, recreation, and public service and social interaction
between communities and logging camps.
Jobs-~Alternatives 1 and 4 would have almost no impact on
current jobs. Timber jobs can be expected to remain the same
under either alternative. Higher construction standards under
Alternative 4 compared with increased road mileage under
Alternative 1 would balance the number of construction jobs.
66
Alternatives 3 and 5 would reduce the number of timber and
support jobs during the 5-year period.
Alternative 2 would nearly eliminate the timber industry from
the Ketchikan Area, except for logging of private lands and
perhaps a cant mill. Considering that induced employment is
proportional to primary employment, the Ketchikan Area would
lose about 50 percent of its employment level, or about 3,400
jobs. This alternative could result in a multimillion dollar
damage settlement the pubiic would have to pay to LPK for
breach of contract.
Recreation--Implementation of any alternative would change the
recreation type and pattern on Prince of Wales Island (see
recreation impacts). The effects on the road-oriented recrea-
tion would vary by alternative. To the extent that an alter-
native would enhance completion of the arterial system, it
would benefit road-oriented recreation and therefore the
economic benefits from this recreation. Fishing and hunting
are primary pursuits of local camp or community residents, and
driving for pleasure combined with fishing and camping are the
main attractions of ferryship travelers.
Alternative 2 could result in about an 80-percent decrease in
road-oriented recreation because of the demise of the logging
communities and the lack of road maintenance. This would
result in most roads being closed.
Alternatives 3 and 4 would have a similar effect on road-
oriented recreation during the life of this plan. Both alter-
natives would tie Coffman Cove, Whale Pass, and Labouchere Bay
to the public road system and the ferry. Alternatives 1 and 5
would provide for public travel between Coffman Cove and the
ferry.
Public service and social interaction--Since Thorne Bay and
Naukati have been connected to the public road system, Craig
has become a shopping center. The people are forming intercom-
munity social ties, and the communities have began cooperating
to achieve mutually beneficial projects, such as State highways,
power facilities, and community fairs. Similar development is
expected as the logging communities of Whale Pass, Coffman
Cove, and Labouchere Bay are connected in the future.
67
H.
Minerals
The proposed timber harvesting plan would have no adverse
effect on minerals and mining. Prospecting would continue,
and roads could enhance opportunities for this activity.
Recreation
Impact on Existing Recreation Use--Most of the existing recrea-
tion use is associated with saltwater shorelines, accessible
lakes, rivers, and streams. Hunting often occurs within a
mile or so of the beach or other points of access and along
some of the Prince of Wales Island road system in recently
clearcut areas. Roads eminating from communities generally
receive high day use with some overnight camping in certain
locations.
In Alternative 1, large units proposed on the shores of Sweet-
water Lake, Sarkar Lake, Staney Creek, and Salmon Bay would
bring logging activities into close proximity to people recrea-
ting in these areas and would affect existing use patterns by
introducing roads and discordant effects. The units proposed
on Sarker Lake are directly located on an identified potential
campground site and on an old trail connecting Sarkar Cove to
Sarkar Lake.
Units proposed in Barnes Lake, Red Bay, Salmon Bay Lake,
Salmon Lake, and along the ferry route will introduce roading
and discordant effects. But, they would not be in so close a
proximity to the recreatisn use areas.
In Alternative 1, the only sections of the mainline road
system that would be tied together are Coffman Cove to Naukati
and Coffman Cove to Ratz Harbor. This would eventually result
in increased public access to recreation use areas in the
Sweetwater-Hatchery-Logjam Creek-Coffman Cove area. Recreation
areas, such as Red Bay and Whale Pass in the northern portion
of Prince of Wales Island, would not be accessible by road in
this 5-year operating period.
68
In Alternative 2, some road closures and population decreases
would result in changed recreation use patterns. No further
links in the Prince of Wales Island road system would be made
under this alternative. No more recreation use areas would be
reached by roads than at present.
In Alternative 3, units and roads are proposed in the Red Bay
and Barnes Lake-Sweetwater Lake area, but they are not to the
scale proposed in Alternative 1. The degree of discordant
effects would be much less than in Alternative 1. Units
planned along much of the main road system are generally small
and in many cases designed to enhance visual variety and
provide views.
Under Alternative 3, all logging camps on Prince of Wales
Island are linked to the main road system. Hence, existing
recreation use areas on the northern half of the island as
well as in the Coffman Cove-Sweetwater area would be made
accessible by road. Coffman Cove will also be tied to Ratz
Harbor, but the connection would be by a more inland route
behind Baird Peak.
In Alternative 4, the impacts on recreation use would be
similar to those in Alternative 3. But, the heavier cutting
along the main road system would produce a high level of
discordant effects along several sections of the road.
Links in the main road system would be constructed to tie
Naukati to Coffman and Naukati to Whale Pass and El Cap through
Sarkar Lake. Hence, recreation areas in these locations will
be made accessible by road. Red Bay and Labouchere Bay,
however, would not be linked to the main road system, and
Coffman Cove would be tied to Ratz Harbor by the same route as
in Alternative 3.
In Alternative 5, the recreation impacts are in the Barnes-
Sweetwater area and would be the same as in Alternative 4.
The only link added to the main road system would be between
Coffman Cove and Naukati.
Impact on Recreation Opportunity--When areas scheduled for
development are entered, recreation opportunities will be
altered. Some activities, such as wilderness or wildland
experiences, may be eliminated in the areas developed, depending
on the type and extent of that development. Other activities
may be enhanced if they are aided by roads and other modifica-
tions.
69
Each drainage area included in this analysis is a somewhat
isolated entity, and activities in one drainage area would not
normally affect potential recreation opportunities in adjacent
drainage areas. Most impacts on recreation are long term, but
they could be reversed in the future if the roads were closed
and timber harvest stopped.
Timber harvest in a roadless drainage can have a profound
effect on the recreation opportunities both during the operation
itself and for many years afterward. Activities associated
with camplife, roadbuilding, logging, hauling, and rafting of
logs ail tend to displace recreation users requiring solitude
and natural environment.
For areas considered in this analysis, increased human activity
and the potential conflict with established wildland use
patterns would spread beyond the camps and logging locations
to nearby bays and islands under some of the alternatives.
After completion of harvesting, solitude would return to the
area as the people leave and facilities are removed. Those
recreation activities aided by the remaining roads and vegeta-
tion changes would then be available in a relatively isolated
environment. More of the semiprimitive recreation qualities
would return as revegetation of cutting units and spur roads
occur and the physical logging effects are masked. With crown
closure of the cutover areas occurring some 15 to 30 years
after harvest, the area would once again begin to provide a
pleasing appearance, except for the main gravel roads. However,
if the drainage area is managed on a multiple-entry concept,
the second entry could be scheduled at about that time, and
the sequence would repeat itself.
Impacts on opportunities for dispersed primitive recreation
would be greater in roadless drainages scheduled for initial
entry than in those previously entered (table 14). The
introduction of roading noise and discordant visual effects
would aiter the opportunity for recreation in an isolated
environment. In either case, opportunity for dispersed primi-
tive recreation would be lower, with the magnitude depending
on the type and standard of roads built and the number and
size of harvest units and closeness to attractions.
70
TABLE 14--Locations which have high values for dispersed
primitive recreation and are proposed for entry by alternative 1/
: Entry proposed by Alternative--
High-value area for : 1 : Z : 3 ; 4 : 5
dispersed primi- :
recreation :
Red Bay > Yes No Yes Yes Yes
Salmon Bay Lake 3 eS No No No No
Whale Pass a NO No Yes No No
Barnes-Sweetwater : ¥es No Yes Yes Yes
Karta : Yes No No No No
Opportunity for dispersed semiprimitive recreation would also
change in roadless areas scheduled for entry (see table 15).
Entry would result in a slight lowering of opportunity, because
access and discordant effects only slightly detract from
semiprimitive recreation. This would depend on the number,
type, and standard of roads built and the number and size of
harvest units, nearness to attractions, and so forth.
TABLE 15--Locations which have high values for dispersed
semiprimitive recreation and are proposed for
entry by alternative 1/
: Entry proposed by Alternative
High-value area for : iL : 2 : 3 ° 4 2 5
dispersed semi- :
primitive recrea- :
tion :
Salmon Bay Lake : Yes No No No No
Red Bay : Yes No Yes Yes Yes
Whale Pass : No No Yes No No
Barnes-Sweetwater : Yes No Yes Yes Yes
Shaken Bay 5 Yes No Yes Yes No
Port Protection é Yes No No Yes Yes
Ratz Harbor K Yes No Yes Yes Yes
Tuxekan Pass : Yes No Yes Yes Yes
Salt Chuck : Nes No Yes Yes Yes
Karta : Yes No No No No
1/ Recreation types are defined in section II-C.
Tal
The opportunity for concentrated recreation would improve in
entered areas. Timber harvesting would introduce discordant
elements and visual effects which may detract from this type
of recreation. The introduction of roads and road-orientated
facilities, such as campgrounds, would. increase the supply of
concentrated recreation opportunities.
The "Recreation and Visual Resource Specialists Report" can be
obtained on request for more details on recreation impacts.
Wilderness
Areas which are entered for timber harvesting or that have
less than 5,000 acres of roadless area remaining would not
normally be considered for Wilderness classification by the
Forest Service until roads and harvested areas are no longer
evident. (See alternative maps for roadless areas being
entered.) Roadless areas which would be affected, by alter-
native, are:
Alternative 1--The total roadless area over 5,000 acres in
size would be reduced by about 120,000 acres. Recognized
potential Wilderness areas at Karta, Salmon Bay, Honker Divide,
and Sarkar would be entered.
Alternative 2--No roadless areas would be affected.
Alternative 3--This alternative would reduce roadless areas
over 5,000 acres in size by about 105,000 acres on the sale
area. Wilderness options would’ be preserved at Karta, Salmon
Bay Lake, Sarkar and Honker Divide.
Alternative 4--This alternative would reduce roadless areas
over 5,000 acres in size by about 105,000 acres on the sale
area. The Wilderness option would be preserved in Karta,
Salmon Bay Lake, Sarkar, and Honker divide.
Alternative 5--No roadless areas would be affected.
Visual
An evaluation of the impacts of these five alternatives on the
visual resource is based on an analysis of how the proposed
activities meet the inventoried visual quality objectives
(VQ0s). These are derived from an inventory of the inherent
scenic quality and the user sensitivity of that area. These
visual quality objectives describe five degrees of acceptable
a2
alteration of the natural landscape, ranging from preservation
to maximum modification. Refer to the "Glossary" for a brief
description or to "National Forest Landscape Management," Vol.
2, Chapter 1, "The Visual Management System," for a more
detailed explanation of these different objectives and how
they are derived.
The following paragraphs summarize the general visual impacts
of each alternative. For a more specific account of the
impacts of each alternative, refer to the "Recreation and
Visual Resource Specialists Report.'' Visual impacts would be
short term. However, future management activities could
extend the impacts for prolonged periods of time.
Alternative 1 would not meet the "Southeast Alaska Area Guide"
policy of "recognizing and protecting lands having special
values, such as boat anchorages, small boat routes, ferry and
tourship routes, recreation beaches...'' It proposes very
extensive cutting along several saltwater shorelines, such as
Tuxekan Passage, West Behm Canal, Traitors Cove, and along
part of the ferry route along Clarence Strait. It also proposes
extensive cutting around lakes having Forest Service cabins
near them and having recognized recreation and/or wilderness
values. The resulting visual quality effect in most areas
would be maximum modification compared to inventoried VQOs of
partial retention in the foreground viewing position and
modification in the middleground. Some units in the Salmon
Bay and Tuxekan Passage areas would result in unacceptable
modification. Visual quality objectives would be met only in
the Sumner Strait and Port Protection areas.
Alternative 2 would result in no additional change in visual
quality.
Alternative 3 would generally meet the VQOs with minor excep-
tions. The resulting visual quality in the middleground
viewing areas of Exchange Cove and Shakan Bay would be maximum
modification rather than the inventoried VQO of modification.
The resulting visual quality in the middleground areas of
Hatchery Lake and Port Protection would be modification instead
of the inventoried VQO of partial retention.
Through lack of cutting, a higher visual quality (generally
preservation) than the inventoried VQO of retention or partial
retention would be achieved in the Karta, Salmon Bay Lake, and
Honker areas. Smaller units and lack of cutting in the fore-
ground would result in a higher visual quality than the inven-
toried objective of partial retention for the Klu Bay and the
73
Alternative 4 effects would be the same as Alternative 3
inventoried objective of maximum modification along the Prince
of Wales Island road system near Red Bay and Coffman Cove.
except that lower visual quality would result along the
Prince of Wales Island road system. It would result in maximum
modification in the Coffman Cove area and in modification
rather than the inventoried VQO of maximum modification near
Red Bay. It would also result in maximum modification rather
than the inventoried VQO of partial retention between Naukati
and Control Lake. Also in this alternative, a unit proposed
on the lower parts of a middleground slope would not meet the
inventoried VQO of partial retention from some viewing points
on the lake.
Alternative 5 meets the VQO's to the same degree as Alternative
Z in the roaded areas and proposes no harvesting in the roadless
areas. This would result in a visual quality closer to
partial retention rather than the inventoried VQO of modifica-
tion along some stretches of the West Behm Canal. Through
Shakan Bay, this alternative would meet the inventoried VQO of
modification in the middleground. Along the West Coast Waterway
just north of Sarkar Cove, this alternative would result in a
visual quality of partial retention rather than modification
as in Alternative 4. From Sumner Straits, the resulting
visual quality will be slightly higher than in Alternative 4,
but it would still meet the VQO of partial retention. Other
roadless areas not entered with Alternative 5 are not viewed
from any sensitive locations, so there would be no change in
the visual impact from Alternative 4.
Alternatives 2 to 5 for the most part would recognize and
protect the most critical recreation use areas, such as the
Forest Service cabins and their associated water bodies, and
the visual quality of views from the ferry and cruiseship
routes and the more important small boat water routes. Trade- “
offs were through the IDT process. Therefore, these alter-
natives meet the Area Guide policies and the 1979-84 operating
guidelines for management of the visual resource.
Cultural Resources
Impacts on cultural resources come from two sources, direct
and indirect. Direct impacts occur when a site is disturbed
by a proposed activity. Indirect impacts are such things as
disturbance and vandalism resulting from increased human
access.
74
Archeological sites are more likely to be found in some areas
than others. Those areas with highest probability are the
coastlines. Medium probability areas are the forested island
interiors, particularly on old beachlines, lakeshores, and
along low reaches of main streams. Low probability areas are
alpine and subalpine zones. Certain alpine and subalpine
areas have higher probabilities for historical sites, primarily
from past mining activities.
The following is a description of each alternative, divided
into key areas in relation to know sites. The probabilities
for locating sites and direct and indirect impacts on cultural
resources are qualitatively described:
Alternative 1--Of all the alternatives, Alternative 1 would
have the greatest impact on cultural resources on Prince of
Wales Island, because many cutting units are located along the
shore. Cultural resource sensitivity areas that would be
affected include sale areas adjacent to Kasherof Passage,
Clarence Strait, Barnes Lake, Exchange Cove, Coffman Cove,
Thorne Bay, Tolstoi Bay, and Twelve-Mile Arm on the east coast
and Naukati Bay, Dry Passage, and Tuxekan Passage on the west
coast. A traditional Native trail ran between Karta Bay and
Klawock (Petroff 1884), and cultural resources associated with
this could be affected. Other aboriginal sites, some of which
are unverified, could be affected at Dry Passage, Staney
Creek, Shaheen, Naukati, Sarkar, Red Bay, Sweetwater Lake,
Whale Pass, Thorne Bay, Tolstoi Bay, Karta drainage, and
Twelve-Mile Arm (Rabich 1978; Sealaska 1975). Historic sites
associated with salteries and canneries could be affected
near Red Bay, Salmon Bay Lake, Whale Pass, Coffman Cove,
Thorne Bay, Shakan, and Tuxekan (Moser 1902). Historic sites
associated with mining could be affected between Karta and
Tolstoi Bay, west of Salmon Lake at Twelve-Mile Arm, Dry
Passage, and Marble Island (Wright and Wright 1908). On
Revillagigedo Island, most of the activities are located
inland, but some cultural resources adjacent to Gedney Pass,
Behm Canal, and at Indian Point could be affected.
Alternative 2--The decision to take no action would have no
impact on cultural resources resulting from timber sale activi-
ties.
Alternatives 3 and 4--Impacts from Alternatives 3 and 4 are
similar, except, that Alternative 4 would include cutting on a
portion of the Kasaan Peninsula. On Prince of Wales Island,
both alternatives place most cutting units inland, thus decreas-
ing the potential for direct impacts on cultural resources.
75
However, cutting units are situated on Marble Island west of
Prince of Wales Island. Marble Island has never been thoroughly
surveyed for cultural resources, and opening the island to
development could increase impacts on any existing cultural
resources. Additionally, indirect impacts could occur to all
the cultural resources listed in Alternative 1, except for
those located near Karta, Sarkar, and Salmon Bay Lake. Cultural
resources associated with historic mining activities could be
affected on Kasaan Peninsula. On Revillagigedo Island cultural
resources could suffer indirect impacts adjacent to Traitors
Cove, Neets Bay, Gedney Pass, and at Indian Point.
Alternative 5--Alternative 5, which restricts the sale area to
existing roaded areas, would decrease part of the effects on
Prince of Wales Island, because some cutting units near Kasaan,
Sarkar Lake, and Ratz Harbor are eliminated. Alternative 5
disallows including some of the interior and mountainous
terrain in the sale area, but these are probably moderate or
low areas of cultural resource sensitivity. Consequently,
indirect impacts would generally be the same as in Alternative
4. On Revillagigedo Island, areas of concern include land
near Gedney Pass, Neets Bay, and at Indian Point.
Further details on the impacts on cultural resources may be
obtained in the "Specialists Report on Cultural Resources."
M. Atmosphere
No slash burning is planned. Operating machinery and logging
camps in the area would put some smoke in the air, and during
‘ dry weather, some dust would occur along gravel roads. Neither
would lead to concentrations great enough to produce any
serious air pollution problems. Some noise pollution would be
generated by trucks, yarders, and other machinery during
timber harvesting and road construction.
EVALUATION OF ALTERNATIVES
LPK has requested that the full 960 MM bf be made available for the
1979-84 operating period. Alternatives 1 and 4 meet this level.
Alternatives 3 and 5 provide approximately 75 percent of this
amount and would require going into contingency areas to meet the
contract commitment. The Forest Service is not ready to accept
this option until the Wilderness issue in southeast Alaska has been
finalized. Alternative 2 does not provide any harvest.
76
The need to harvest damaged timber in a timely manner to protect
forest resources is addressed in the contract. Harvest of dead or
damaged timber is less economically viable than operations harvesting
green timber. The short-term economic loss is justified to protect
the long-term value of soil, fish, wildlife, cultural, timber, and
recreation resources. Since Alternative 2 would preclude timber
harvesting, it completely fails to address the salvage issue.
Alternatives 4 and 5 would provide for as much harvest of damaged
timber as is practical in the areas entered. Because of visual
problems, one major blowdown area (Baird Peak) was not entered in
Alternative 3 or 4. Alternative 3 would get almost as much damaged
timber as Alternative 4, but it would compromise some of the units
for recreation values. Alternative 1 did not emphasize damaged
timber as a selection criteria because of short-term economics.
Consequently, only a minor amount of the damaged timber was proposed
for harvest.
The economic viability of an alternative cannot be precisely stated
until after an appraisal is done. Based on past experience, a good
indicator is the amount of timber scheduled for harvest per mile of
road constructed. A harvest of 2 MM bf per mile of system road
will generally result in a positive dollar return, except for
permanent bridges. With no timber harvest, Alternative 2 has no
economic return. To harvest the 960 MM bf, Alternative 4 requires
the least number of new roads and would appear to return the most
value. However, Alternative 1, with 10 percent more new road
mileage, could be competitive or slightly more economical because
of lower logging costs as a result of operating in only the best
stands and emphasizing relatively short yarding distances using a
mostly hi-lead method. The short-term economics of Alternative 1
would result in later economic and management problems. Alternatives
3 and 5 would probably provide marginal dollar returns.
Wilderness is a national issue. So, it is appropriate that undevel-
oped areas of national interest be managed according to a broad
allocation plan. In this case, the appropriate plan would be TLMP
as part of RARE II. Alternatives with units in the Karta, Salmon
Bay Lake, Sarkar Lakes, or Honker Divide areas would limit the
potential for classified wilderness in these areas. Alternatives
2 and 5 would not have units in these roadless areas or any others.
Alternatives 3 and 4 have no units in these areas of national
interest, but they would develop other inventoried roadless areas.
Alternative 1 would have roads and harvest units in these four
areas and in most other inventoried roadless areas.
V7
The design of harvest units to optimize future management would be
handled best with Alternatives 4 and 5 in that emphasis would be
placed on logical units and windfirm boundaries within the capabili-
ties of present LPK equipment. Alternative 3 would do a slightly
poorer job of designing harvest units for future management because
of tradeoffs of timber value to protect amenity values. Alternative
1 would place no emphasis on providing for future management.
Consequently, future problems with blowdown, accessability, economics,
other resources, and operability would result. Since Alternative 2
would provide for no timber harvest, no future management problems
would be created.
Alternative 4 does the best job of taking the complete first-entry
harvest when operations are in an area. Alternatives 3 and 5 would
fail to do this, and in many cases they would increase costs through
future re-opening of roads. In some cases, camp moves would also
be needed to come back for small first-entry volumes.
An annual harvest of about 250 to 300 MM bf is needed to maintain
economic stability on the Ketchikan Area. The 5-year volume of 960
MM bm represents about two-thirds of that amount. Alternative 1
would best maintain the social and economic stability of the Ketchi-
kan Area for the 5-year period. This is because the type of opera-
tion follows the pattern of operations for the past 10 years.
Alternative 4 would maintain economic stability for the 5-year
period and beyond then.
Extention of the public road system to Whale Pass, and Coffman Cove
would enhance the social interaction of Prince of Wales Island
communities (See "Socioeconomic Effects"). Alternatives 3 and 4
would equally affect the social interaction on Prince of Wales
Island. Alternatives 1, 3, and 4 would complete most of the Prince
of Wales Island road system. Alternative maps 1, 3, and 4 show
which road sections would be completed.
Loss of some jobs in the timber industry with Alternative 3 for 5
years could result in disruption of the economic stability of the
Ketchikan Area. Alternative 5 would fail to maintain economic
stability more than Alternative 3. Alternative 2 would fail com-
pletely to maintain social and economic stability. The resultant
loss of 50 percent of the Ketchikan Area jobs would cause complete
upheaval in the social pattern and would destroy the timber industry
on the Ketchikan Area for an indefinite period.
78
Alternatives 3, 4, and 5 were prepared in conformance with the
policies in the "Southeast Alaska Area Guide." The degree of
consideration of each resource varies somewhat and is depicted in
relative terms in table 16.
TABLE 16--Relationship of alternatives to evaluation criteria 1/
z Rating of Alternative--
Evaluation criterion weiss 5. 4 : 5
us 960 MM bf from primary area = 10 0 7 10 7
125 Timber salvage : 2 0 Th 8 8
e 4 Economic viability oO 0 6 10 7
4. Wilderness eit!) 10 9 9 10
5. Harvest unit design : 3 10 v/ 8 8
6. $Intraisland road system : 4 0 8 8 4
ps Social and economic stability : 9 0 7 10 5)
8&9. Conforms to policy and guide- :
lines :
a. Recreation and visual 3 8 9 7 7
De Soils and water 4 10 8 8 8
¢. Fish 3 10 9 7 8
d. Wildlife 5 10 9 ¥f 8
e. Cultural 4 10 7 6 7
q >
1/ The degree to which an alternative satisfies a criterion is shown
by 10 for the best and O for the least.
VII. IDENTIFICATION OF FOREST SERVICE
PREFERRED ALTERNATIVE
Alternative 4 is the preferred alternative. It would adequately
meet most criteria. The departures from the primary sale area
would be minor, involving three units straddling the sale boundary
to facilitate logging system layout design and the addition of the
Clam Chance adjacent to El Capitan Passage to integrate the north
Prince of Wales Island transportation system.
Alternatives 3 and 5 would not in many cases take the entire first-
entry harvest when roads were open and operations were in an area.
i This would create higher overall costs by requiring a future reopen-
ing of roads and in some cases camps. These alternatives would
also cause a loss of 900 to 3,000 jobs depending on the alternative
and the degree to which induced employment was affected.
13,
VIII.
Unless mutual cancellation of the contract could be arranged,
Alternative 2 would breach the contract and result in costly litiga-
tion. In either case, economic and social costs would be high to a
most of the communities. It would probably close the pulp mill as
wood in transit was used. It is possible that existing independent
sales and Canadian imports could keep the pulp mill operating for a
short period. The spruce mill in Ketchikan and the Annette hemlock
mill would also close or operate intermittently under this alter-
native for lack of supply. In a community, such as Ketchikan,
where alternate employment is not available within commuting distance, |
the economic effect of this alternative would be severe.
Alternative 1 would meet important criteria from the industry point
of view, because harvests of the contract commitment of 960 MM bf
could be made in an economically sound manner. Its greatest defi-
ciency is its failure to recognize other important Tongass National
Forest interests.
Alternative 4 is the preferred alternative, because it would meet
the evaluation criteria more completely than would the other alter- ©
natives. Alternative 4 meets industrial needs under the contract
and protects Tongass National Forest values.
MANAGEMENT REQUIREMENTS
Most of the management requirements necessary for implementing this ,
plan are in the LPK contract. Others are in the operating guide-
lines. Both of these documents are in the Appendix.
Following are some additional requirements not previously included:
*Conduct reconnaissance archeological surveys in units where
they have not already been done and intensive surveys on areas
that appear to yield significant data concerning cultural
resources.
*In the event that a cultural resource is discovered or damaged
during ground-disturbing activities, that cultural resource
will be protected or salvaged as deemed appropriate through
the consultation process outlined in 36 CFR 800 (Federal
Register 1976).
*No sewage discharge into freshwater systems will be permitted.
Under the Water Quality Improvement Act (P.L. 91-244) and the
Federal Water Pollution Control Act of 1972 (P.L. 92-500), as
amended, all domestic sewage waste from logging camps must
80
meet the standards in effect at the time the camp is established.
Effluent must meet minimum standards for biochemical oxygen
demand, suspended solids, fecal coliform (bacteria), and pH.
The discharge facility owner shall apply to the Environmental
Protection Agency for a National Pollutant Discharge Elimination
System permit (Forest Service Manual 7410.3).
*A sale area improvement plan will be developed to provide for
reforestation and timber stand improvement measures made
necessary by the harvest of timber. Actions needed for the
rehabilitation and management of other forest resources, such
as fisheries or wildlife, will be included in the plan. Funds
to implement these activities will be collected as part of
stumpage receipts and congressional appropriations as provided
in the National Forest Management Act.
*Conduct IDT review of harvest units or roads before release.
IX. CONSULTATION WITH OTHERS
The Alaska Department of Fish and Game provided one and at times
two Ad Hoc advisors to the interdisciplinary team. These advisors
worked closely with their Forest Service counterparts to provide
recommendations which resulted in the formation of various alter-
natives.
The U.S. Fish and Wildlife Service and the National Marine Fisheries
Service also provided personnel and information, particularly
regarding location of log transfer sites.
LPK company personnel were consulted in accordance with the provi-
sions of the Long-Term Sale Agreement.
Also, informal discussions were held with members of Tongass Conserva-
tion Society and Southeast Alaska Conservation Council.
Additionally, in June 1978, a four-page advertisement was placed in
the "New Alaskan,'' a monthly newspaper widely distributed throughout
southeast Alaska. An additional 500 copies were mailed or given to
individuals who had previously expressed an interest in national
forest management. The purpose of the advertisement was to inform
the public of the scope of the environmental analysis and to solicit
public opinion on the subject. Forty-two responses were received
reflecting a broad spectrum of opinion. The majority favored
Alternatives 1, 3, or 4. Although each respondent had a preference
for one of the alternatives, they often expressed their analysis of
the strengths or weaknesses of each alternative. These are summa-
rized as follows:
81
Alternative 1--This alternative was viewed as having a low regard
for environmental protection and reflecting a single-use concept of
national forest management instead of multipleuse. It was also
séen as being economically viable, protecting jobs, and meeting
contract requirements.
Alternative 2--No one considered this a viable option.
Alternative 3--Some respondents felt this alternative adequately
protects wildlife, visual, recreational, and other nontimber forest
values. Others felt the protection is excessive and would result
in adverse economic impacts.
Alternative 4--This alternative was seen as meeting contract
requirements with a minimum of adverse environmental and economic
impacts. However, the degree of adverse economic and environmental
impacts is important, and the fear was expressed that this alter-
native would not meet "Southeast Alaska Area Guide" policy and,
depending on a person's viewpoint, that it either gives too much
weight to commercial values or not enough.
Alternative 5--This alternative is seen as maintaining high wilder-
ness values and maximum environmental protection but at a cost of
not meeting contract requirements or maintaining employment.
This Environmental Statement was issued as a draft in December
1978, and the following agencies and organizations were invited to
comment: Advisory Council on Historic Preservation, Washington,
D.C.; State of Alaska Historic Preservation Officer; U.S. Department
of Housing and Urban Development; U.S. Department of the Interior;
Department of the Army, Corps of Engineers; U.S. Department of
Transportation, Federal Highway Administration; U.S. Environmental
Protection Agency; U.S. Department of Energy, Federal Energy
Administration; U.S. Department of Commerce, National Marine
Fisheries Service; State of Alaska, Office of the Governor, State-
Federal Coordinator; State of Alaska's Departments of Community and —
Regional Affairs, Transportation, Commerce and Economic Development,
Environmental Conservation, Fish and Game, Natural Resources,
Public Works, and Law; Alaska State Historic Preservation Officer;
City of Ketchikan: City of Craig; City of Klawock; and Greater
Ketchikan Gateway Borough.
Others invited to comment include the Alaska Loggers Association,
Tongass Conservation Society, Western Forest Industries Association,
Artic Representative of Friends of the Earth, Southeast Alaska
Conservation Council, Alaska Lumbermen's Association, Ketchikan
Chamber of Commerce, Alaska Miners Association, Sealaska Corporation,
82
Citizens for Management of Alaska Lands, The Wilderness Society,
Sierra Club, South Tongass Land Review Committee, and other interested
individuals. Additionally, 500 copies were sent to individuals
expressing an interest in national forest management.
Twenty-eight responses on the draft were received and are displayed
in this document with Forest Service comments on the substantive
portions of those responses.
The major concerns raised by the respondents were:
*Intraisland road connections for Prince of Wales Island.
*Potential damage to fish habitat from roadbuilding and logging.
*The effect of the fall 1978 windstorm which extensively
damaged timber stands on the sale area.
*Reduction of the total roadless area on the sale area.
*A general lack of "hard data" or quantification or facts to
use in the analysis.
*Possible violations of water quality standards.
These concerns have been addressed in expanded or revised portions
of this Final Environmental Statement. The "Effects" section was
extensively revised, particularly those portions dealing with
soils, water, timber, and fish.
The last part of this section contains copies of responses to the
draft environmental statement made by the State of Alaska, other
Federal Agencies, and individuals. In addition, this section
displays brief comments of the Forest Service as they relate to the
responses received. (Many comments are referenced by numerals
placed in the margin of the respective response.)
83
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION X
1200 SIXTH AVENUE
SEATTLE, WASHINGTON 98101
MED ST
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ANNor M/S 443
FEBS 127s
James S. Watson, Forest Supervisor
U.S. Department of Agriculture
Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
We have completed our review of your draft environmental statement for
the LPK Timber Sale Plan for 1979-84. We appreciate the deadline
extension granted us to enable us to also review the six specialist's
reports. We regret that we did not also receive the transportation
specialist's report.
You and your staff are to be commended on a well-written statement
which includes a consistent and valuable comparison between the five
alternatives throughout the statement. The proposed alternative 4
implements and furthers many of the guidelines developed in the SE
Alaska Area Guide and in the Tongass Land Management Plan. We found
the specialist's reports to be well done, and are especially pleased
with the analysis and direction in the fisheries report in regards
to both water quality and fisheries habitat protection.
We have a number of comments and suggestions for the DES.
Mass Wasting
1 The fisheries special report does a good job of addressing most forms
of increased sediment, and does attempt to quantify most actions that
may produce sediments. However, as the ES points out, while the
amount of harvest adjacent to fish streams may be directly related
to the degree of impact on fisheries, unstable ground well away from
the streams may be a more severe long term problem. Since soil mass
movement resulting from actions on steep slopes is a major problem
in many areas of SE Alaska, the discussion in the ES of mass movement
should be expanded in three ways:
1) Page 32 states that alternatives 3, 4, and 5 call for more timber
harvesting on steep slopes than would alternative 1. To permit a
balanced comparison of alternatives, there should be some quantifica-
tion on the number of steep (349-379) and oversteepened (over 37°)
acres, that would be affected under each alternative by both road
construction and timber cutting.
2) While the proposed partial suspension or total suspension of
cut logs will minimize short-term erosion, mass wasting most often
occurs following root decay 3 to 5 years after logging. Therefore,
there should be an expanded discussion of the long-term effects of
actions on steep slopes.
84
3) A discussion of the proposed management plans to minimize the
problems resulting from activities on steep and over-steepened
slopes would round out the section.
Major Connecting Roads
Due to environmental effects and economic costs, reduction in road
mileage is often considered advantageous. Alternatives 3 and 4 include
approximately 20 miles of new roads that are not necessary to reach
timber planned for harvesting during this five year plan. As these
roads connecting the Hollis-Craig-Klawock-Coffman Cove road system to
Whale Pass and Shaken (south connecting road in this letter) and
further connections to the Red Bay and Labouchere Bay road system
(north connecting road in this letter) may well have the longest and
most significant long-term impact on the residents of the island,the
discussions of the effects, reasons for, and placement of these roads
should be expanded. For example, the Southeast Alaska Guide Transporta-
tion Goals orients the forest to develop a system of transportation
modes that best meets the land and resource management goals and needs
of the people. The Tongass Land Management Plan DES states that
whether a community desires to be connected by road or by the Alaska
Marine Highway to other communities often generates major debates
within the region and within individual communities. However, there
is no evidence presented in the DES that any communities desire to
be connected by road, and some evidence (p. 24) that some communities
do not want to be connected even though the planned roads will run to
within a short distance of their site.
The reasons for the placement of these two roads are not mentioned,
and, based on the available information, these roads do not appear to be
placed through the best corridor. For example, the north connecting sec-
tion would require much less new road if the connection ran near the west
side of the island through the Shaken Bay and Labouchere logging
road systems, rather than the proposed Honker Divide- Red Bay connection.
The proposed alternative's south connectiong road appears to enter and
cross the western Sarkar Lakes area that has been considered for inclu-
sion in wilderness or watershed protection management under some of
the alternatives in the Tongass Land Management Plan DEIS. To commit
this land now for a road may foreclose other, more desirable, long-term
management options. Alternative 3, which was designed to minimize
impacts on wildlife and visual resources, proposes the south connecting
road along the east side of the island near Whale Pass. The alterna-
tive 3 alignment appears to be much more desirable than the alternative
4 alignment on environmental grounds, and only slightly more costly in
terms of road construction mileage.
Other Comments
An additional map of the sale area including the major geographic and
elit al features would have clarified many of the discussions in
the DES.
As a sale area improvement plan will be developed to provide for
reforestation, a discussion of the present reforestation plan, methods,
problems, and proposed remedies would be useful.
Many of the mitigation measures to minimize the effects of the harvest
on many of the forest values involve IDT review prior to release of
any unit for timber harvesting or roading. It would be informative
for there to be a fuller discussion of what this team actually does
and can do during this review. Also, the proposed water quality
monitoring should be more specific on what parameters will be measured,
including a measure such as a percentage of intragravel fines similar
to the sediment standard now used by the Alaska Department of Environ-
mental Conservation, and the frequency, duration and location of
85
6 sampling. Specifidty on the monitoring program would allow readers
of the ES to see how your agency intends to implement the requirements
of section 2(a) of Executive Order 11514.
7 The Louisiana-Pacific Corporation proposal, Alternative 1, would
negatively impact many non-timber harvesting values of the national
forest. Harvest in inventoried roadless areas of national interest,
such as the Karta River-Salmon Lake drainage and in the Salmon Bay
Lake area, would prevent wilderness classification for those areas.
Destruction of large areas of key winter habitat for Sitka Black-
tailed Deer would greatly reduce the Forest's carrying capacity for
the deer and other valuable wildlife. Increased stream temperatures
and decreased water quality due to logging and yarding practices would
affect commercially and recreationally valuable fish. For these and
other reasons, the selection and implementation of Alternative 1 would
be considered Environmentally Unsatisfactory.
Based on the assumption that the selected alternative will be
Alternative 4, we are rating this statement LO-2 (LO - Lack of
Objections; 2 - Insufficient Information) from the standpoint of
the Environmental Protection Agency's areas of concern and expertise.
This rating will be published in the Federal Register in accordance
with our responsibility to inform the public of our views on proposed
Federal actions under Section 309 of the Clean Air Act, as amended.
We appreciate the opportunity to review this draft environmental impact
statement. Please do not hesitate to contact me or Judi Schwarz, of my
staff, should you have questions or desire further information regarding
our comments. We can be reached at (206) 442-1285 or (FTS) 399-1285.
Sincerely,
Cee ee B. Srodh
Alexandra B. Smith, Chief
Environmental Evaluation Branch
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE ENVIRONMENTAL PROTECTION AGENCY LETTER
1. The Forest Service agrees that the problem of mass wasting needs
more attention (Top of p. 2.). The discussion on soils has been
expanded in the FES in the sections "Affected Environment" and
"Effects" in response to this concern.
Ds The section on transportation has been rewritten in the FES to
clarify the type of road to be constructed and the purposes for
connecting existing road links (see also our comments on the State
of Alaska and SEACC responses on this subject). The north connecting
road follows the gentlest terrain available between Whale Pass and
Labouchere Bay. It also provides the shortest north-south link
between Hollis and Labouchere Bay, considering the road system
already in place. Both connecting roads access as much or more
commercial timber land as alternative routes.
3. Seventeen USDI Geological Survey topographic map sheets (1 inch = 1
mile) cover the million plus acres of the timber sale, and they are
available for review in most large libraries. The bulk and cost of
these documents precluded our including them with each DES. Terrain
features at a smaller scale blur together with the types of reproduc-
tion processes available, unless we use expensive coated paper
stocks.
86
4. As suggested, a discussion of reforestation is included in the
final statement. Included also are descriptions of other post-
cutting silvicultural practices.
Sis The IDT process continues after the completion of the ES throughout
the implementation of the 5-year project. The process is less
formal in that team membership and leadership are ad hoc, varying
with the location and nature of the resource concern. Resource
Management Assistants (RMA) or Project Engineers (PE) have the
responsibility to call upon Resource Specialists for advice and
assistance in laying out cutting units and locating and designing
roads. RMA's and PE's are required to be knowledgeable enough of
the Area Guide policies to recognize extra-ordinary situations and
to call for specialized assistance where necessary. Resource
Specialists have also “red tagged" some units and roads in which
they feel they should be actively involved in the design and
implementation stages.
6. A discussion of water quality monitoring, planned and underway, is
included in the FES.
The The selected alternative as shown in the FES is Alternative 4.
Hence, no harvest is planned in Salmon Bay Lake. The Karta drainage
has been recommended through the RARE II decision for Wilderness
classification.
United States Department of the Intent RECENED
USFS-KA
OFFICE OF THE SECRETARY
P. O. Box 120
Anchorage, Alaska 99510 ~
ER-79/34 Februqiys
Mr. James Watson
Forest Supervisor
USDA Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
In response to your December 19, 1978 request, we have reviewed the
Draft Environmental Impact Statement for the LPK Timber Sale Plan for
1979-1984, Tongass National Forest, Prince of Wales Division, Alaska
and we offer the following comments for your consideration.
GENERAL COMMENTS
Native communities that would be directly impacted include Hydaburg,
Craig, Klawock, Kasaan and Metlakatla. Since the economics of Metlakatla
and Klawock are very dependent on timber harvest activities, these com-
munities would be impacted more than the others.
Alternative 4 appears to be in the best interests of the concerned
Native communities since it will provide the timber necessary to sup-
port economic growth. However, we believe that Alternative 3 best suits
the resource management requirements necessary for the well-being of
fish and wildlife resources.
87
To better understand and evaluate impacts, we suggest the statement
contain maps which show the location of seasonally important habitat
areas (i.e., raptor nesting areas, shoreline deer food and cover areas,
etc.) and their relationship to the proposed actions.
SPECIFIC COMMENTS
Page 2, paragraph 3. From a fish and wildlife standpoint, this para-
graph dramatically emphasizes the need for renegotiating the long-term
(50-year) timber sale contract. Although we are concerned primarily
with the 5-year period which commences July 1, 1979 and ends June 30,
1984, for purposes of this statement adequate provision for potentially
impacted fish and wildlife components cannot be realistically estab-
lished when long-term timber commitments are set at a fixed figure.
Accordingly, the need for fish and wildlife management as expressed in
terms of a reduction of the oyerall timber haryest for the areas in
question is not available. Therefore, appropriate protection of
indigenous stocks is in some cases not possible,
Page 7, paragraph 4. Providing for and stressing the importance of
tidally influenced wetland meadows in the estuarine zone is laudable,
However, where logging will potentially impact highly productive
fresh-water wetlands, some method of accounting for the amount and
types of wetland area affected under each alternative should be
included so that comprehensive comparisons between alternatives are
possible,
Page 9, paragraph 5. We concur with your statement that "Estuarine
areas also provide significant contributions to the fisheries resources
of the sale area." Subsequently, it becomes apparent that logging
activities occurring in terrestrial areas can affect the stability
of estuarine systems due to increased runoff, etc. Moreover, estuaries
are not statie systems as evidenced by the fluctuation of the various
vertebrate, invertebrate and macrophytic components which are in
dynamic equilibrium with the environment, As a result, it would be
helpful if a more complete listing of estuarine plants and animals
were available such that probable impacts caused by logging could be
more closely defined.
Page 14, Cultural, It is our understanding that the Forest Archeologist
has consulted the staff of the State Historic Preservation Officer
regarding historic and archeological resources within the project
area. However, this is not reflected in the draft statement. The
final statement should contain evidence of consultation with the Advisory
Council on Historic Preservation and the State Historic Preservation
Officer,
Pages 22-23, Issues. We believe the statements in this section accu-
rately depict the situation which presently exists concerning the dis-
position of timber and timber-related resources and their relationship
to the LPK-Forest Service 50-year contract. Particularly, the expressed
concern that "This contract is a constraint on the Forest Service in
applying measures to manage other resources," is well taken and is
indicative of the dilemma which we face when attempting to comment on
a document that withholds certain management alternatives as a result
of prior commitments.
Page 24, Criterion 1. Our concern regarding this criterion have been
expressed in our remarks addressing the assumptions underlying the
LPK-Forest Service 50-year contract.
Page 24, Criterion 5. It is our understanding that leave strips are
not available for harvest at any time, Perhaps this criterion should
be reworded to say, "Design harvest units and logging systems so that
deferred areas will be economically available in the future." Further
the meaning of the first sentence in this criterion is unclear.
88
14
16
1
Page 24, Criterion 6, We recognize the need for consideration of
improving the intra-island road system, However, we feel that it should
not be used as justification in this statement for timber harvest.
Page 27, Effects. This chapter contains many possible mitigating actions.
It should be stated whether these mitigating actions are merely possi-
bilities or whether the U, S. Forest Service and the timber operator
are committed to them. It seems likely that canopy removal also causes
cooling by irradiation of calories into the atmosphere which, when
coupled with the stated daytime warming aspects, would result in a
surface temperature profile with greater extremes. This, potentially,
could result in significant ecological change.
Page 30, paragraph 3, In our opinion, comments in this paragraph con-
cerning the natural maintenance of high dissolved oxygen levels and
the lack of sensitivity of Southeast Alaska streams to D.O. depletion
should be documented.
Page 30, paragraph 4. We are concerned with the assumption that water
quality reductions can be minimized and restored. The methods for
doing such should be documented and supported,
Page 32, Table 5. We suggest that ZAtream crossings, with their impact
on water quality in streams, be included in this table,
Page 32, paragraph 3, In considering the comment, “Some adverse but
acceptable impacts will result," what criteria are used to determine
whether or not an adverse impact is acceptable?
Page 33, paragraph 2, It is our judgment that a "long-term" would be
a span of time greater than the time the 50-year contract has been in
operation, It seems unlikely that the long-term effects on fisheries
could be adequately assessed since the beginning of large-scale cutting
in Southeast Alaska. It is our impression, therefore, that the last
sentence incorrectly implies that long-term effects/on fisheries will
prove to be insignificant.
Page 48, Recreation, The draft statement provides a comparative
evaluation of the impacts to outdoor recreation resources according
to the various proposed alternatives prior to the finalization of the
Tongass Land Management Plan. The outdoor recreation resource impacts
identified in the final environmental statement should reflect coordi-
nation and consistency with the outdoor recreation resource related
policies and direction contained in the finalized Tongass Land Manage-
ment Plan and the Southeast Alaska Area Guide,
The draft statement mentions that some of the proposed logging roads
will be maintained for public access. To better understand the out-
door recreation opportunities and/or impacts associated with this
action, it would be helpful if the final statement would: Identify
those proposed logging roads which will be maintained for public use;
and project the future increase, if any, in outdoor recreation use
and/or other related impacts which might be directly associated with
this action.
Page 59, Chapter VII, paragraph 2, It is apparent that combining the
figures quoting the number of jobs lost does not lend itself to an
adequate analysis of the impact of Alternatives 3 and 5 on the employ-
ment market. Consequently, we suggest that an estimate of loss of jobs
resulting from selection of Alternatives 3 and 5 be separated and that
the analysis used in arriving at the figures be presented.
89
ys BF
12.
Thank you for the opportunity to provide comments on the draft
statement.
Sincerely,
Regional Environmental Officer-
Alaska
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE U.S. DEPARTMENT OF INTERIOR
See the comments on the Environmental Protection Agency response
(No. 3).
We believe this is a forestwide issue more appropiately addressed
as it is now being done in the Tongass Land Management Plan. The
long-term sale commitments are'well below the 450 MM bm programmed
harvest determined in the TLMP for the Tongass National Forest.
Whether this average annual harvest is accomplished through a few
large long-term sales or many small, short duration sales, the
impacts to the fish and wildlife resources would be the same as the
protection policies do not vary with the size or nature of the
sale.
The only freshwater wetlands on the sale area are muskegs and boggy
scrub timber lands. These lands are not consideréd highly productive.
See the pertinent referenced publications, The Forest Ecosystems
of Southeast Alaska.
This has been done. See Section IX.
See reply no. 2 above.
See reply no. 2 above.
Leave strips are an appropriate management prescription when it has
been determined by the IDT that fish habitat cannot otherwise be
protected. The Tongass Land Management Plan has removed from the
programmed harvest about 160 MM bm annually for protection of other
resources. This does not include that volume removed by roadless
area allocation or those lands on steep slopes and in isolated
patches. What is meant by the first sentence is that when laying
out the road system, do not. isolate areas that are planned to be
harvested in future entries.
See comments on the State of Alaska response (No. 5).
The Forest Service is committed to those mitigating measures.
The discussion on water quality has been expanded in the final
statement.
The policies and practices are documented in the Southeast Alaska
Area Guide, Tongass Land Management Plan, and their references.
90
13.
14.
15.
16.
17.
18.
The total number of stream crossings by alternatives is not known
at this time.
Primarily, the Southeast Alaska Area Guide outlines this criteria.
The Forest Service relies on the expert opinion of soil scientists
and hydrologists to make such interpretations.
This is a debatable opinion that unfortunately can neither be
proved nor disproved.
We believe this FES is completely consistent with the Tongass Land
Management Plan.
This has been done. See II-C.5 of the FES.
These estimates are based on tables 3 and 4 and the volume for each
alternative. See also the "Socioeconomic Overview" published by
the Alaska Region, Forest Service, USDA in 1978.
FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D.C. 20426
IN REPLY REFER TO:
FEB 14 1979
Mr. J. S. Watson
Forest Supervisor
USDA - Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
I am replying to your request of December 19, 1979 to the Federal
Energy Regulatory Commission for comments on the Draft Environmental
Impact Statement for the LPK Timber Sale Plan for 1979-84. This Draft
EIS has been reviewed by appropriate FERC staff components upon whose
evaluation this response is based.
The staff concentrates its review of other agencies' environmental
impact statements basically on those areas of the electric power,
natural gas, and 011 pipeline industries for which the Commission has
jurisdiction by law, or where staff has special expertise in evaluating
environmental impacts involved with the proposed action. It does not
appear that there would be any significant impacts in these areas of
concern nor serious conflicts with this agency's responsibilities
should this action be undertaken.
Thank you for the opportunity to review this statement.
Sincerely,
r\ !
Dihe-tyete ween
‘Jack M. Heinemann
Advisor on Environmental Quality
Sit!
DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
January 29, 1979
Gentlemen:
Thank you for forwarding a copy of the draft
environmental statement of "The LPK Timber Sale
Plan for 1979-84". The Department has no comment
on the statement.
Sincerely,
j
pay //2
v Janes M. Wright
Acting Assistant Director (Environmental Programs)
Office of Administrative Programs
USDA Forest Service
Federal Building
Ketchikan, Alaska 99901
OF
fw UNITED STATES DEPARTMENT OF COMMERCE
: : The Assistant Secretary for Science and Technology
s Washington, D.C. 20230
ia af (202) 3773Nk 4335
February 2, 1979
Mr. J. S. Watson
Forest Supervisor
USDA Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
This is in reference to your draft environmental impact
statement entitled "The LPK Timber Sale Plan for 1979-84."
The enclosed comments from the National Oceanic and
Atmospheric Administration, National Marine Fisheries
Service are forwarded for your consideration.
92
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you. We
would appreciate receiving five (5) copies of the final
statement.
Sincerely,
rgd MEE)
Prfata*% fff
Gitte ler
Deputy Assistant Secretary’
for Environmental Affairs
Enclosure: Memo from Mr. Harry L. Rietze, NOAA/NMFS
U.S. DEPARTMENT OF COMMERCE :
National Oceanic and Atmospheric Administration
NATIONAL MARINE FISHERIES SERVICE
P. O. BOX 1668 - JUNEAU, ALASKA 99802
DATE: January 26, 1979
10) EC, Richard Lehman mr
{si Yates M. Barber, Ite JAN 31 1979
THROUGH: F7, Kenneth R. Roberts
WhO Ea
BU ns AK, Harry L. Rietze
Director, Alaska Region
SUBJECT: Comments on Draft Environmental Impact Statément--The LPK
Timber Sale Plan for 1979-84 (U.S. Forest Service) (DEIS
7901.10)
The draft environmental impact statement for the LPK Timber Sale Plan
for 1979-84 that accompanied your memorandum of January 16, 1979 has
been received by the National Marine Fisheries Service for review and
comment.
The statement has been reviewed and the following comments are offered
for your consideration.
GENERAL COMMENTS
Three basic issues that concern the National Marine Fisheries Service
are fish stream habitat protection, estuarine habitat protection, and
the evaluation of alternatives for this timber sale.
Fish stream habitat protection: It is stated that "Prescriptions were
developed (see Appendix B and the ‘Southeast Alaska Area Guide') to
protect fish habitat" (page 33, para. 3). We strongly support the
fishery management practices of the Southeast Alaska Area Guide and the
Operating guidelines for fish stream habitat protection. However, we
are familar with the limited research base that was available to help
formulate those guidelines, and we know that they have not been ad-
equately tested. Therefore, we believe it is premature to assume that
"if all forest development activities conform to accepted policies and
93
guidelines, completed as through site-specific prescriptions, then
impacts on fish are either nonexistent or minimized to an acceptable
level" (page 33, para. 3).
Estuarine habitat protection: Estuaries are important areas for the
rearing of many species of fish, including the juvenile stages of
Pacific salmon. Other valuable resources dependent on estuaries include
crabs, shrimps, herring, sablefish, and halibut. The potential de-
struction of estuarine habitat is inadequately described in the DES. We
agree that "In the estuary, loss of habitat results from rock fills for
construction of log transfer points" (page 35, para. 2); however, roads
beside or through an estuary also may have a large impact. Moreover,
the fact that marine bark accumulation resulting from land-sea log
transferring has a smothering effect on plants and sessile animals, and
the possibility that substratum required by planktonic larvae may. be
covered (Schultz and Berg, 1976), should be acknowledged.
Evaluation of alternatives: Considering the broad geographic and en-
vironmental ramifications of the proposed cutting of 960 MM bm of timber
On Prince of Wales and Revillagigedo Islands within the next 5 years,
the draft EIS is inadequate. The main deficiency is lack of sufficient
details concerning logging plans and protective measures for specific
streams and watersheds. For example, 30 major and numerous small salmon-
producing streams (page 6) are in the proposed cutting area, but most of
these streams are not specifically identified, and it is impossible to
tell exactly where cutting is proposed relative to them.
Sufficient specific data are not given in the soils, water, and fish
sections of this DES to permit us to make an informed judgment on the
most environmentally acceptable alternative. However, it would appear
that alternative 2, followed distantly by alternatives 5 and 3, would
maintain fish habitat and protect fishery resources better than either
alternative 1 or 4. We assume that alternative 2 is not viable. There-
fore, we would prefer adoption of alternative 5, since it appears that
less fish habitat would be affected under this alternative than under
alternative 3. However, it is unclear how, or to what extent, the
policies for protecting fishery resources articulated in the Southeast
Alaska Area Guide were utilized in evaluating the alternatives. In
light of this uncertainty and the recent protection given to roadless
areas by the Department of Agriculture (RARE II), we recommend that a
revised DES be prepared to provide reviewers a better opportunity to
evaluate the merits of all reasonable alternatives.
SPECIFIC COMMENTS
II. AFFECTED ENVIRONMENT
A. Physical
4, Water
Page 7, para. 2. It is stated that "Under the selected alternative, the
number of stream crossings have been minimized to the extent practical."
We suggest also mentioning the degree to which stream crossings on the
other alternatives would be minimized.
Page 7, para. 4. We agree in part that "The sensitive wetlands of
southeast Alaska are the tide influenced meadows in the estuarine zone."
However, we believe that all wetlands are very sensitive to erosion
caused by logging. Freshvyiater wetlands produce a tremendous amount of
detrital material necessary in the food chain of freshwater, anadromous,
and estuarine fishes. We recommend including an estimate of the amount
and the kind of wetlands that would be disturbed by each alternative.
94
B. Biological
2. Fauna
Page 9, para. 5 and page 10, para. 1. We agree that estuaries are very
important to the fisheries resources of the sale area, and suggest
including a more complete discussion of their importance to commercial
and sport fish resources. Some of the more important commercial and
sport species that depend on estuaries and nearshore waters, but that
are not mentioned here, include all salmon, cutthroat trout, Dolly
Varden, steelhead, sablefish, halibut, herring, Dungeness crab, and
clams.
C. Social Aspects
3. Wilderness
Page 14, para. 6. It is stated that Karta, Salmon Bay Lake, Honker
Divide, and Sarkar were not considered in this timber sale so as not to
constrain the RARE II and TLMP processes. We agree with this rationale,
and submit that these and other roadless areas with high fisheries
values should be left in their natural state. That natural, unlogged
watersheds have a high fisheries value is exhibited by the large com-
mercial salmon catches of the 1940's. In addition, the sport fishing
industry in southeast Alaska--a multimillion dollar industry that is
steadily growing--would benefit from such protective action.
5. Transportation
Page 16, para. 2. There seems to be confusion in the transportation
Objectives for the LPK timber sale. The DES states that "One objective
of transportation planning has been to connect the isolated road seg-
ments radiating from Coffman Cove, Whale Pass, E] Capitan, and Labou-
chere Bay to the other population centers and to encourage development
of additional ferry terminals on Prince of Wales Island." But the
Southeast Alaska Area Guide (at page 141) states that "The Forest Service
plans, designs and constructs transportation systems to support various
resource activities and provide access for management, use and protection
on National Forest lands. The State of Alaska has primary responsibility
for planning, project development, design and construction of regional
highways and air facilities as delegated by the Federal Highway Admin-
istration and the Federal Aviation Administration. The primary purpose
of State highway systems is to provide for the moyement of people and
materials from one community to another, regardless of land and resource
allocations along the way, while the Forest Service directs its efforts
toward the development of resource-related transportation systems,
proposals for developing of other major arterial highway systems may
also come from other sources" (emphasis added). Finally, as stated in
TLMP (at page 113) "Road construction produces, by far, the greatest
opportunity for soil loss and sedimentation." Section V. C. Fish (pages
33 and 34) recognizes many of the adverse effects sedimentation has on
fishery resources. We acknowledge that the Forest Service can allow
roads for social purposes, but we suggest that it would be more appro-
priate to address these roads in a separate environmental statement.
Page 18, para. 4. Again, an apparent desire of the Forest Service to
build non-resource-related roads is implied by the statement that "Future
management for the Forest Development Roads will continue to emphasize
connection of communities...." This objective appears to conflict with
the Forest Service's role in transportation planning, as described in
the Southeast Alaska Area Guide (see quotation from its page 141 above).
D. Economic Aspects
Page 19, para. 3 and page 22, para. 1. Tables 2, 3, and 4 are mis-
numbered, and Tables 2 and 4 (numbered 4 and 3 in the DES) do not agree
regarding primary employment in commercial fishing and fish processing
95
in the Ketchikan area (7.9% vs. 17.1%). The source of the data used for
these estimates should be indicated.
F. Issues
Page 23, para. 1 and 4. Statements such as "the other side to this
issue is that if the job level is to be maintained, the same volume
commitment would still be needed regardless of the kind of contract" and
"The issue is whether or not the Tongass National Forest will continue
to supply the timber volume needed to maintain this reliance at its
present level" imply that without the total allowable cut, timber-
related employment will drop within the Ketchikan area. However, in the
section on "Economic Aspects" in the TLMP (page 29) it is stated that
"If privately owned lands are managed on the sustained yield basis, the
total cut in southeast Alaska would be 600 MM bm per year (adjustments
were made for round log exports displacing a portion of cant produc-
tion). As a result, about 450 MM bm per year would be required from the
Tongass to support the industry. Under this set of circumstances, total
employment in the timber industry in southeast Alaska would remain
slightly above the past 7-year average." Since the average cut from the
Tongass was only 520 MM bm per year over the past seven years (TLMP,
page 29), it should be possible to reduce the allowable timber volume on
the Tongass, maintain or increase the number of timber-related jobs,
provide wilderness areas, and protect fish habitat for future genera-
tions.
G. Management Concerns
Page 23, para. 7 and page 24, para. 1. We agree that local community
needs are important management concerns. However, these other develop-
mental needs (e.g., roads) would more appropriately be considered in a
separate environmental statement so that such. needs could be evaluated
separately. As stated in our comments on Section II. B. 5. Transportation,
Forest Service roads should be resource-related. This does not seem
apparent in the statement "Another management concern is that the harvest
should be planned so as to allow road connections between most of the
communities on Prince of Wales Island."
III. EVALUATION CRITERIA
Pages 24 and 25. Of the nine evaluation criteria used to weigh the
alternatives, none specifically weighs the importance of fish or wild-
life resources. This seems in conflict with the Multiple Use-Sustained
Yield Act of 1960, the Wilderness Act of 1964, the National Environmental
Policy Act of 1969, the Endangered Species Act of 1973, the Forest and
Rangeland Renewable Resources Planning Act of 1974, the Sikes Act of
1974, and the Federal Land Policy and Management Act of 1976--all of
which recognize the need for and the desirable qualities of fish and
wildlife on National Forest land.
Page 24, para. 2. As stated in our comments on Section II. B. 5.
Transportation, we believe criterion 6 conflicts with the management
Objectives of the Southeast Alaska Area Guide (page 141). Instead of
making this an evaluation criterion for a timber sale, we believe that a
more appropriate approach would be to consider all non-resource-related
roads in a separate environmental statement.
IV. ALTERNATIVES CONSIDERED
Page 25, para. 1. The maps showing each alternative do not provide
enough information for an effective comparison among alternatives. Our
specific suggestions for improving these maps are as follows:
96
12
13
1. Increase map size to give reviewers enough detail to permit
them to distinguish the size differences among the various
cutting units.
2. Clearly define all land-sea boundaries (e.g., by extremely
dark lines).
3. Differentiate (e.g., by color) all log dumps and log storage
sites specific to any one alternative.
4. Differentiate (e.g.y by color) all cutting units specific to
any one alternative.
5. Differentiate all roads specific to any one alternative.
Page 26, para. 5. It is stated that "In order to facilitate the com-
pletion of the intra-island road system, it is necessary to leave the
primary sale area between Naukati and Whale Pass, thus including the
‘Clam Chance' timber in the long-term sale." As stated above, we believe
that all roads evaluated in this DES should be resource-related. Roads
are one of the greatest sources of sediment in streams during and after
logging. Therefore, cutting plans should be designed to minimize the
length and number of required roads. All non-resource-related roads
should be discussed and evaluated in a separate environmental statement.
V. EFFECTS
Ae Sonilis
Pages 28 and 29. For each alternative, data should be included on the
types and areas of hazardous soils appearing within each fish-producing
watershed. The strengths and weaknesses of each alternative should then
refer to these data. Each alternative is different enough to be dis-
cussed separately. Finally, all conclusions and declaratory statements
should be supported by adequate data and/or proper documentation. (Also
see our comments below for sections V. B. Water and V. C. Fish.)
B. Water
Page 30, para. 1. The statement that "Although the increase in sediment
1s the primary impact from logging and road construction, increases are
relatively low compared to other regions of the United States" should
be supported by adequate data and/or proper documentation.
Page 30, para. 3. Stream turbulence should be mentioned as the primary
cause of high dissolved oxygen (D.0.) levels in streams. Blockages of
backwater areas by logging debris may cause D.0. depletion in streams.
Page 30, para. 4. All anticipated “temporary changes in water quality"
Should be described in the text of this section. We question the
validity of the statement that "all anticipated changes can be reduced
to acceptable levels and returned to natural levels through proper
planning and enforcement of watershed protection measures during and
after logging activities" (emphasis added). This statement should be
(a) qualified (e.g., "could" instead of "can") to indicate the level of
uncertainty and the difficulty of monitoring and enforcing any pro-
tection measures and (b) supported by adequate data and/or proper doc-
umentation.
Page 30, para. 5. It is stated that "Changes in streamflow would prob-
ably be negligible. Normally, restrictions on cutting design eliminate
the potential for a measurably increased streamflow." Again, such
conclusions and statements should be supported by adequate data and/or
proper documentation.
97
Page 30, para. 6. Examples of "Sensitive landforms and channel systems"
should be provided, and their relationship to streams being considered
"most sensitive," as described on page 29, paragraph 6, should be dis-
cussed.
Page 31, para. 1. The Alaska Department of Environmental Conservation's
best management practices" should be listed, along with the Forest
Service's equivalent measures. The rationale as to when or where each
practice or measure will be used should be explained.
Page 31, para. 3, 4, and 5 and page 32. In the discussion of each
alternative, number and size of sensitive landforms, channel systems,
and streams should be discussed. Also, the probability of these land
forms causing water quality problems should be discussed in relation to
adjacent timbering, roading, and road crossings.
Page 32, Table 5. The data presented in Table 5 are very informative.
But to provide a more complete picture, we suggest including data on (a)
the miles of roads adjacent to streams and (b) the number of stream
crossings within each alternative. Streams compared in this table
should be defined as "large," "small," or "intermittent." If small or
intermittent streams vital to rearing salmonids are not considered, this
fact should be so stated.
Page 32, para. 3. Data and/or documentaticn should be provided for the
conclusion that "some adverse but acceptable impacts will result...."
C. Fish
Pages 33-36. The negative impacts on fisheries resources that are
Tisted (e.g., increased sedimentation, changes in stream temperature,
stream and estuary (ecotone) habitat loss, and diminished stream and
estuary habitat productivity) are all regarded as short-term, local, or
unimportant, and therefore not of great concern. In our opinion, how-
ever, it is possible that some impacts may be long-term (there are few
or no data), and we believe that it is erroneous to assume that "guide-
lines" will always be appropriate, applied, and enforced. We are not
certain that logging will be done in accordance with provisions in the
Tongass Guide. For example, the KPC operating guidelines listed in the
appendix (pages 101-112) were dated 1976 and do not appear as complete
as the fisheries policies in the Area Guide, dated 1977.
Page 33, para. 2. Many research efforts have demonstrated that logging
may have detrimental effects on fishery resources and their habitats.
(See comment for page 33, para. 5 below for literature citations.) The
revised DES should include a listing, accompanied by literature citations,
of the long-term research projects conducted in southeast Alaska that
were reviewed to reach the conclusion that timber harvesting does not
Significantly affect fishery resources on a long-term basis. [An
explanation of "long-term" would be appropriate (i.e., does it mean
weeks, months, decades, or centuries?).] In our opinion, adequate
research on the effects of logging on fish production has never been
performed in southeast Alaska.
Page 33, para. 3. The DES acknowledges that the IDT had few data to
support the assumption that its prescriptions for the protection of fish
habitat are acceptable. Despite this acknowledged lack of data, another
very important assumption is made about the acceptability of impacts on
fish. (See quotation under GENERAL COMMENTS above.) To make such a
statement with a good data base is appropriate, but to make such a
statement without any data base is inappropriate, since many studies
have found logging to be harmful to fish habitat.
98
A better approach would be to acknowledge a lack of quantifiable data
upon which a reconmended alternative will be based. Then, a qualitative
analysis of risk should be discussed for each alternative. Finally, a
recommended alternative could be chosen, logically and objectively,
because of its risk ranking.
Page 33, para. 5. Perhaps "Increased opportunities to conduct direct
fish habitat improvement projects" could be more appropriately stated as
follows: "Increased financing would be available to conduct fish habitat
improvement projects." It is our understanding that the same oppor-
tunities would exist under alternative 2, but that funds from logging
revenues would not be available to support such projects.
We suggest that the introduction to the effects of logging on fish
habitat be revised to indicate that when old growth forests are removed
by logging, rapid changes take place that set the ecosystem back to an
early stage of ecological succession. Stream temperatures are raised in
summer (Hall and Lantz, 1969) and possibly lowered in winter (Burton and
Likens, 1973). Forest transpiration rate changes (Molchanov, 1960) and
streamflows are altered (Harr, 1970). Sediment eroded from logging
roads enters streams (Cederholm et al., 1978); sediment increases in
streambed gravel (Koski, 1972; Koski and Walter, 1978), thereby decreasing
delivery of oxygenated water to developing eggs and alevins (Koski,
1975) and reducing benthic invertebrate production (Brusven and Prather,
1974). Increased light penetration to streambeds also alters distribu-
tion, abundance, and production of benthic invertebrates; increased
light production may increase growth of periphyton and algae (Hansmann
and Phinney, 1973). Buffer zones of uncut timber can help protect the
stream/forest ecotone from these undesirable changes, but information
that provides a basis for prescribing sizes and locations of buffer
zones is lacking.
Page 34, para. 1. In addition to the effects mentioned here, sedi-
mentation may physically block alevins from leaving their redds.
Page 34, para. 4. The statement that "application of the guidelines
would keep temperature changes within acceptable limits and return them
to natural levels within 10-15 years after logging" should be supported
by data and documentation.
Page 35, para. 2. Fill material placed within the intertidal zone for
the construction of roads also may cover valuable marine habitat and
create circulation problems within marine wetlands and the stream/estuary
ecotone.
Long-term marine impacts may be caused by bark debris build-up from log
transfer sites. Ratz Harbor, a proposed transfer site for this sale, is
a good example.
Page 35, para. 3. Bark accumulation also has a smothering effect on
plants and sessile animals, and it may cover substrate required by
planktonic larvae (Schultz and Berg, 1976). Appropriate substrate is
important ecologically because many planktonic larvae will postpone
metamorphasis in the absence of a suitable substrate (Day and Wilson,
1934; Wilson, 1937; Thorson, 1946). Therefore, a bark substrate will
reduce the amount of critical habitat ayailable to these species. An
improperly placed log transfer facility could severely disrupt the
environment of a bay. Again, Ratz Harbor is a good example of a bay
that is severely impacted by log debris.
The National Marine Fisheries Service also provided recommendations on
the suitability of all log transfer sites and log storage sites.
99
14
15
17
Some of the proposed log transfer facilities are not in conformance with
the Southeast Alaska Area Guide's policies. Those transfer sites that
were recommended were the best locations chosen from among the alter-
natives available. A heavily impacted bay often was chosen because this
action would tend to localize detrimental effects.
Page 35, para. 5. Roads are commonly the greatest source of siltation
among all logging-related activities. It would be appropriate to compare
the miles of roads adjacent to streams and the number of stream crossings
within each alternative. (See comment above for page 32, Table 5.)
Earlier in the DES (page 6), it is stated that "The sale area has 30
major streams and numerous small, largely unnamed streams." To the
extent possible, these streams and watersheds should be named and their
fisheries values described. The disturbance of every watershed should
be compared and discussed for each alternative.
Page 36, para. 2. All log transfer sites and log storage sites should
be listed for each alternative (rather than merely enumerated) so as to
project the fisheries impacts more clearly.
Page 36, para. 3. Instead of discussing the effects resulting from "the
best possible application," we suggest discussing the effects resulting
from "the most probable application."
Page 36, para. 4. A definition of "long-term" should be provided.
Page 36, para. 5. All environmental impacts should be considered to be
both dynamic and cumulative.
E. Vegetation
Page 44, Table 9. The apparent discrepancy between the number of acres
that would be harvested under alternative 5 (16,993 acres in Table 9 vs.
18,634 acres calculated from data given on page 26) should be corrected.
G. Socioecononic
Page 46, para. 5 and 6; page 47, para. 1 and 2. Only forest-related
jobs are discussed. All types of jobs should be analyzed for each
alternative. The discussion should include impacts on commercial fish-
ing, freshwater and marine sport fishing, tour-chartering, and various
other non-timber-related uses.
The potential for timber harvesting on privately owned lands creating
timber-related jobs should be discussed, especially in the context of
providing an opportunity to reduce timber harvest on National Forest
lands and affording fish and wildlife resources better protection.
Page 47, para. 4. The degree to which non-road-oriented recreation
would be affected by adopting alternative 2 should be discussed. This
discussion should include effects on marine sport fishing, primitive
area sport fishing, etc., over a 100-year timber rotation time frame.
Page 47, para. 5. The discussion of differences between alternatives 3
and 4 should include non-road-related uses, including marine sport
fishing, primitive area sport fishing, etc.
Page 47, para. 6. As mentioned on page 24, "Port Protection and Point
Baker residents have expressed a desire to remain isolated from the road
system." Therefore, the impact of logging large amounts of timber near
these fishing communities, as shown for alternatives 1, 3, 4, and 5,
should be throughly discussed and evaluated.
100
19
20
21
22
23
24
VI. EVALUATION OF ALTERNATIVES
Pages 56-58. We suggest a re-evaluation of these alternatives, since ;
protection of fish and wildlife values was not specifically mentioned in
the Section III. EVALUATION CRITERIA (pages 24 and 25). Any evaluation
of alternatives should be discussed in the context of fitting into a
long-term, multi-purpose plan for the Tongass National Forest (e.g.,
TLMP).
Page 58, para. 3 and 5. The probable effects of timber harvesting on
Native lands should be discussed. These effects may include an increase
in logging-related jobs and an increase in the need for protective
measures for fish and wildlife resources on the Tongass National Forest.
VII. IDENTIFICATION OF FOREST SERVICE PREFERRED ALTERNATIVE
Pages 59 and 60. We suggest a re-evaluation of this section because ~
fish and wildlife resource protection was not specifically addressed in
the criteria used to choose an alternative.
Page 59, Table 12. The weight given to each criterion should be speci-
fied. (We assume all criteria were not given equal weight.)
Page 59, para. 1. The apparent desire of the Forest Service to build
roads that are not resource-related is evident here. Again, any non-
resource-related road should be addressed in a separate environmental
statement. (See our comments above.)
Page 59, para. 2. Again, the potential for increased jobs resulting
from the logging of private lands should be evaluated and discussed.
VIII. MANAGEMENT REQUIREMENTS
Page 61, para. 1. Research is needed to provide data required for an
evaluation of management goals (e.g., fish and wildlife protection).
Funds for such research could be collected as part of stumpage receipts,
and from congressional appropriations.
We would appreciate two copies of the final environmental statement when
it becomes available.
LITERATURE CITED
Brusven, M.A. and K.V. Prather. 1974. Influence of stream sediments
on distribution of macrobenthos. J. Entomol. Soc. British Columbia,
Migee25=328
Burton, T.M., and G.E. Likens. 1973. The effect of strip-cutting on
stream temperatures in the Hubbard Brook Experimental Forest,
New Hampshire. Bio Science, 23 (7): 433-435.
Cederholm, C.J., L.C. Lestelle, B.G. Edie, D.J. Martin, J.V. Tagart
and E.0. Salo. 1978. The effects of landside siltation on the
salmon and trout resources of Stequaleho Creek and the main
Clearwater River, Jefferson County, Washington, 1972-1975.
Univ. Washington, Fish. Res. Inst., Final Report-Part II,
FRI-UW-7804, 53 pp.
Day, J.H. and D.P. Wilson. 1934. On the relationship of substratum to
the metamorphasis of Scolelepis fuliginosa (Claparede). J. Mar.
Biol. Assoc. U.K., 19: 655-662.
101
Hall, J.D. and R.L. Lantz. 1969. Effects of logging on habitat of
coho-salmon and cutthroat trout in coastal streams. In: T.G.
Northcote (ed.), Symposium on Salmon and Trout in Streams, p.
355-375. H.R. MacMillan Lectures in Fisheries, Univ. British
Columbia, Vancouver. 388 p.
Hansmann, E.W., and H.K. Phinney. 1973. Effects of logging on periphyton
in coastal streams of Oregon. Ecology, 54 (1): 194-199.
Harr, R.D. 1976. Forest practices and streamflow in western Oregon.
U.S. Forest Service Gen. Tech. Rep. PNW 49, 18 p. |
Koski, K V. 1972. Effect of sediment on fish resources. Paper presented
at Washington State Dep. Nat. Resources Mgmt. Seminar, Lake Limerick,
Wash., 36 p.
Koski, K V. 1975. The survival and fitness of two stocks of chum salmon
(Oncorhynchus keta) from egg deposition to emergence in a controlled
stream environment at Big Beef Creek. Ph.D. thesis. Fish. Res.
Inst., Univ. Washington, Seattle, 211 p.
Koski, K V. and R.A. Walter. 1978. Forest practices in relation to
management of Alaska's coastal zone resources: a review with
management and guideline recommendations. National Marine Fisheries
Service processed report, prepared for Office of Coastal Management,
State of Alaska, 222 pp.
Molchanov, A.A. 1960. The hydrological role of forests. Acad. Sci.
USSR Inst. Forestry, Moscow. Transl., Israel Prog. for Scientific
Translation, Jerusalem, 1963.
Schultz, R.D. and R.J. Berg. 1976. Some effects of log dumping on
estuaries. Processed report--Alaska Region Environmental Assessment
Division, National Marine Fisheries Service, Juneau, Alaska, 64 pp.
Thorson, G. 1946. Reproduction and larval development of Danish
marine bottom invertebrates. Meddr. Kommn. Danm. Fisk.-og
Havunders (Ser. Plankton), 4: 1-523.
Wilson, D.P. 1937. The influence of the substratum on the metamorphosis
of Notomastus larvae. J. Mar. Biol. Assoc. U.K., 22: 227-243
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE U.S. DEPARTMENT OF COMMERCE
pe Impacts on the estuary have been acknowledged. See Section IV-C.
Dre Forest Service comments on the Southeast Alaska Conservation
Council, Alan Stein, and the State of Alaska responses relate to
these issues.
3. The number of stream crossings are minimized in each alternative.
4. The Forest Service believes this would be an impractical contribu-
tion to the assessment as there are extensive acres of muskegs and
scrub timbered land that technically meet the definition of wetlands.
a See Section IV-C.
6. See the comments on the State of Alaska response.
se This has been done.
102
10.
iile
2K
13".
14.
15\.
16.
17.
18.
19.
20.
21.
This has been assessed through the TLMP and is not within the scope
of this FES.
Fish and wildlife protection and management are standard evaluation
criteria for all national forest projects and are not specific to
this project. They are therefore covered‘in the evaluation criteria
numbers 8 and 9 on pages 25 and 59 of the DES.
The Forest Service believes a total FES covering all the activities
is more comprehensive than one just for the road. See the comments
on the State of Alaska response for further rationale for evaluation
criterion G on page 24 of the DES.
See the comments on the Environmental Protection Agency response
(No. 3).
See the comments on the State of Alaska response (No. 5).
Pages 33-45 of the "Effects" section on "Soils" of the DES has been
rewritten to reasonably meet the scope and practical limits of this
FES.
Only forest-related jobs are discussed, because it is assumed there
would be essentially a neutral effect on jobs in the fishing and
tourist sectors.
The potential for nonroad-oriented recreation would increase as
roads disappear under the forest regrowth. It is difficult to
quantify the actual increase in visitor days, as there already
exists a large unused potential for this type of recreation in
southern southeast Alaska.
There is no difference between Alternatives 3 and 4 regarding the
effects on sport fishing for either marine or freshwater.
The large volume of timber is scheduled for harvest by the Labouchere
Bay camp, because the timber is over mature on lands committed to
the timber sale contract and not otherwise reserved from cutting.
The resources of the forest are not limitless, and, if there are to
be reservations from development on some areas, then other areas
must be open to development. The needs of the Point Baker-—Port
Protection residents have been considered as thoroughly as possible.
See pages 118-119 and pages 127-161 of the FES on the 1974-79
operating period.
See item 9. Fish and wildlife values were considered throughout
the planning of harvest alternatives. The interdisciplinary team
had one wildlife biologist member and, although the Forest Service
fisheries biologist was never formally appointed to the team, he
worked full time on the project with the other team members.
Additionally, Alaska State fish and game biologists contributed
many hours to field investigations, unit design, and team discussions
of the alternatives. Their recommendations were given careful
consideration and generally followed. Fish and wildlife habitat
protection measures are major factors in the policy and guidelines
which make up evaluation criteria 8 and 9. Wildlife values were
also specifically included and given full weight in table 16.
See the response to item 14.
See the reply to item 18.
In table 16 the rating of each alternative reflects the opinion of
the interdisciplinary team as to how well the alternatives meet
evaluation criteria. Although subjective, the rating was made by
people knowledgable of both the resources involved and the varying
103
effects of each alternative on those resources. All criteria were
essentially equally weighed.
22. See item 6.
23. See item 14.
24. The wording of this section has been modified to include management
as well as rehabilitation. Resource management in its broadest
sense includes research as a problemsolving tool.
JAN 30 1879
UNITED STATES DEPARTMENT OF AGRICULTURE
OFFICE OF EQUAL OPPORTUNITY
WASHINGTON, D.C. 20250 JAN 3 0 ‘
. Latics:
7
8140 Supplement 8
Draft Environmental Statement of the
LPK Timber Sale Plan for 1979-84
William Williams, Associate
Deputy Chief for Administration
Forest Service
We have reviewed the draft statement for its treatment of impacts upon
minority persons in the affected area. Census data shows that American
Indians constitute a significant minority population in the Prince of
Wales and Ketchikan Census Subdivisions.
The preferred operating plan will maintain the current volume of timber
production and will impact minorities in the areas of employment and
cultural resources. Since the statement does not include data on popula-
tion or employment by race, it is not possible to determine the impact
that the alternative will have on Indian employment in loaging and timber
related enterprises. We note that the contract between the Forest Service
and the Loufsiana-Pacific Corporation, Ketchikan Division, contains
clauses encouraging the use of local labor and prohibiting discrimination
on the basis of race, color or national origin. We assume that these
provisions are being enforced and have been effective in affording Indians
an equal opportunity for employment.
Regarding cultural resources, the preferred alternative will almost
certainly have some adverse Impact upon sites of early Indian habitation.
This aspect is adequately described in the statement and, hopefully, the
management requirements listed on page 659 will minimize damage to these
sites.
Thank you for the opportunity to review the Draft Environmental Statenent
of the LPK Timber Sale Plan for 1979-84.
/5/
JAMES FRAZIER
Nfrector
cc: J.S. Watson \~
Forest Supervisor
104
_gBENT op
7 DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
*
3 x8 REGIONAL OFFICE
/. é ARCADE PLAZA BUILDING, 1321 SECOND AVENUE
Orang SEATTLE, WASHINGTON 98101
January 29, 1979
REGION X IN REPLY REFER TO:
19 C
Mr. J.S. Watson
Forest Supervisor
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
Subject: The LPK Timber Sale Plan for 1979-84
We have reviewed the statement submitted with your December 19, 1978 letter.
Your preferred alternative no. 4 supports or is consitent with our objectives o+
economic progress for communities, promoting affordable housing for all citizens
and to improve the quality of the human environment. Thus find no objection to
your proposed action. We would not support alternative no. 2 which is to harvest
no timber.
Thanks for the opportunity to comment.
Sincerely,
ee
U. S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION TEN
Room 412 Mohawk Building
222 S.W. Morrison Street
Portland, Oregon 97204
Febraury 5, 1979
IN REPLY REFER TO
HED-010.6
Mr. J. S. Watson, Forest Supervisor
Tongass National Forest
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
The Federal Highway Administration, Region 10, staff has
reviewed the "LPK Timber Sale Plan for 1979" DEIS and has
the following comments for your consideration:
105
Page 18. Main Road New Construction
Consideration should be given to the construction of
turn-outs, boat launching ramps, etc.
Page 27. Section V Effects, A. Soils, first paragraph
In conjunction with the establishment of grasses to
control soil erosion, other temporary and permanent
erosion control measures may be needed during road
construction and logging operations (reference
"Manual of Erosion Control Principles and Practices",
National Cooperative Highway Research Program-Project 16-3).
Page 44. Section "F" Timber
Will the clearcut area be screened from the roadways?
Sincerely yours,
f\
“EIB |
Robert B. Hathaway, Project
Development Program Engineer
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
2221 E. Northern Lights Blvd., Suite 129, Anchorage, Alaska 99504
J. S. Watson
USDA - Forest Service
Tongass National Forest
Federal Building
Ketchikan, Alaska 9990]
The following are our consolidated comments on the Draft Environmental
Impact Statement for the LPK Timber Sale Plan for 1979-84.
General:
1. The Draft Environmental Impact Statement lacks sufficient information
to allow a reader to either evaluate the various alternatives put
forth or to draw upon any conclusions as to the preferred plan. The
statement has to be self sustaining and not relying on written tech-
nical reports located elsewhere for the data needed to evaluate the
proposal. If a summary of the resource reports and logging plan was
shown in a similar manner as the Fish and Wildlife section is pre-
sented, the report would be acceptable.
2. The information needs to be reorganized so that the little data
presented follows a logical sequence. Example: The population for
Prince of Wells Island is located under Transportation and not under
Social Aspects.
106
Specific Comments:
Section II. Affected Environment
Page 11. C. Social Aspects
2 A person not familiar with the area could not tell if the writer
is talking about a community or just a location. This section
should be expanded to include the names, population and major
industry for the permanent and temporary communities. This will
help to set the stage for further evaluation of the social and
recreational resources. The total population figure and number
of communities for the Prince of Wells Island should be in this
section and not under Transportation.
C.1. Recreation
3 Are there any other types of recreation facilities within the
sale area?
Page 12. Dispersed Primitive and Semiprimitive
Both state several areas on the sale area that are rated high
and moderate in quality. Where are these and how will they be
4 affected by the logging development? There is nothing in the
Draft that covers the impact logging will have on these areas.
Page 19. Economic Aspects
If possible, the type and number of employed people living in
5 the permanent communities on Prince of Wells Island should be
shown. The number on the tables (2, 3, and 4) should be
changed. Table 4 comes before 2 and 3.
Page 23. Management Concerns, 2nd Paragraph
6 Do the communities want to be connected by road? From reading
the statement, it is assumed that only the land manager and
the logging company wants the road connection.
Section III.
Page 24. Evaluation Criteria, Item 6
7 The last sentence should be under G. Management Eoneorne?
Section IV.
Page 25. Alternatives Considered
This whole section should be expanded in order to provide the
reader more descriptive information on the logging development
for each alternative. Suggested information: (a) total acreage
to be harvested; (b) miles of new road construction by construc-
tion standards; (c) number of harvest units involved; (d) volume
8 and acreage for each type of logging system; (e) the percent
of merchantable timber being harvested within the confines of
the five year land boundary; (f) the percent of merchantable
timber being left upslope of the units; (g) the number of new
logging camps and log transfer sites needed; (h) number of
employees involved; (i) total acreage of damaged timber found
in the area and the percent that will be harvested; (j) the
percent of unit acreage that lies above a 60% slope for each
logging system involved.
107
All these items are discussed in generalities throughout the
rest of the report without any figures or data attached to
them for comparison.
Section V. Effects
12
13
15
16
Page
Page
Page
Page
Page
Page
Page
Page
Page
Page
28. Alternatives 1, 2, 3, 4, and 5
Each one lacks supporting data to verify the statements made
about the impact logging will have on the soil.
29. Alternative 5, 2nd Paragraph, last sentence ~
Is the Soils Guideline found in Appendix B supposed to be in
this report or the "Soils Specialists' Report"?
31. Alternative 1, 1st Paragraph
Lacks any data to support the statement being made.
31. Alternative 1, 2nd Paragraph
"Several sections of roads are on critical soils and slopes..."
What are several sections - 200 feet or 5 miles of roads? How
does this compare with the other alternatives? This information
is needed for comparison.
35. Paragraph 6, last sentence
Table 5 does not show the varying extent of stream side cuts
by each alternative. All the table shows is the linear miles
of streams involved within or adjacent to the harvest units.
36. Table 6
This should be shown under IV. Alternatives Considered, to
help set the stage for evaluating the effects.
37. D. Wildlife
It is important to know the amount of deer winter habitat
being lost through harvesting the timber, but the key point
for discussion is what level of deer population should be
maintained for the area and how will the proposed cutting
units effect this level.
43. E£. Vegetation, Table 9
This table should be located under IV. Alternatives Considered,
to help set the stage for evaluating the effects.
44, F. Timber
This also lacks supporting data to back up the statements made
on the impact logging will have on it. Example: (a) the
amount of blowdown in the area; (b) the amount of timber in
the area; (c) the amount of upslope timber that will be harvested
or left in the area.
46. G. Socioeconomic
This section should come last since it refers to items discussed
later in the writeup.
108
17
18 Page
20
Page 46. G. Socioeconomic Jobs
Page
Page
Page
Page
Page
The writeup talks about the increased road construction mileage
between alternatives. This is fine, but what is the actual
difference in mileage?
48. I. Recreation
This whole section is weak because it does not address the
impact the logging will have on recreation.
Several things that should be addressed are:
1. How many people presently use the area for recreation?
2. What percent of the recreational use comes from outside
of Prince of Wells Island?
3. What percent of the local population use the area for
recreation?
4. A breakdown of recreational activities and the percent of
use by local and non-local users.
5. What type of people use the area, such as meat hunters,
trophy hunters, subsistence fishermen, sport fishermen,
etc.?
6. What is the expected recreational demand for the area
over the next 10-30 years and by whom?
7. How will the results of the logging actually impact or
benefit the recreational usér for each of the recreation
activities now and in the future?
48. Impact on Existing Recreation Use
This whole section does not show any impacts on the existing
recreation use. All it says is that road construction will
allow a different type of access to the areas and the visual
quality will be lowered by the roads and cutting areas.
48. Alternative 1
How many people will actually be affected by the bringing of
logging activities into close proximity to people recreating
tin these areas? Would it actually change the use patterns by
introducing roads?
50. 2nd Paragraph
The logging will also open up new areas for these people to
use which were not accessable before -- a benefit.
50. 3rd Paragraph, 1st sentence
It is assumed the writer is talking about new logging camps
and logging locations and not existing ones. This should be
clarified.
50. 3rd Paragraph, 5th sentence
If gravel roads are properly put to bed, they will also be
covered with vegetation within 15-30 years, unless the writer
is talking about roads that will be maintained.
109
Page 50. 4th Paragraph, 1st sentence
22
This statement is not clear as to what the writer is talking
about.
Page 50. 4th Paragraph, 3rd sentence,
The opportunity for dispersed primitive recreation would also
23 be greater since it would allow access to more areas not now
accessable to the majority of the potential users. This also
applies to semiprimitive recreation.
Section VI. Evaluation of Alternatives
Page 57. Paragraph 1, 2, and 3
24 In all three items being evaluated, assumptions are being made
without specific data in the text to back up the statements.
Page 58. Paragraph 1, 2, and 3
24 There is no information available in the writeup to veneno the
assumptions being made.
Page 59. Table 12
There is either lacking or nonsignificant information available
25 in the writeup to allow the reader to make a judgement rating
of the alternatives.
Section VII. Identification of Forest Service
Page 59. Preferred Alternative
lst Paragraph, 2nd sentence
This is the first time the writer has talked about unit layout
and it seems out of place since the subject pertains to identi-
fication of preferred alternative. This should have been
brought out earlier in the report in order to help the reader
evaluate the alternatives.
2nd Paragraph, 1st sentence
The statement "...would not in many cases take the entire
first entry harvest...." can only be assumed to be correct.
There is nothing in the text which tells the reader what
percent of the harvest is being taken by each alternative.
These comments are intended to assist you in an improved environmental
statement. Please consider them as best you can.
| Lerwhl
J Nene Weyneth. EX lity F
State Conservationist
cc: K. L. Williams, Director, TSC, SCS, Portland, Oregon
R. M. Davis, Administrator, SCS, USDA, Washington, D. C.
Director, Office of Federal Activities, Environmental Protection Agency,
Washington, D. C.
110
12.
13.
14.
15.
16.
17.
18.
19.
20.
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE USDA SOIL CONSERVATION SERVICE
See the comments on Alan Stein response (No. 3).
This information was cited in the DES under "Transportation" as an
indicator of one class of road users. Other population data are
appropriately cited in the DES and FES under "Economic Aspects."
Yes. See the referenced "Tongass Land Management Plan" for a
detailed listing.
Page 51 of the DES has a detailed listings of the dispersed primitive
and semiprimitive areas. Page 47-52 of the DES assesses the
impacts.
The table numbers have been corrected. Employment data for Prince
of Wales Island alone are not available to us, and the Forest
Service is not legally permitted to collect such data on its own
initiative. Perhaps, that should have been clarified.
See the Forest Service comments on the State of Alaska response
(No. 5).
It is needed under "Evaluation Criteria" to clarify the sixth
criterion.
To the extent the data are known, they are included in the FES.
See "Evaluation of Alternatives," particularly Soils, Watershed,
Fish, and Timber.
Appendix B of the DES contains the guidelines for soil protection.
See "Soils Specialist Report" which supports the statement.
The problem sections are generally only a few hundred feet in
length, except in Alternative 1 where some road segments are one
half mile or more.
In DES table 5, the "extent" of streamside cuts is measured in
miles.
We believe it is more appropriate to leave that information where
it is (see FSM 1950).
We agree. The Forest Service is working with the Alaska Department
of Fish and Game to arrive at deer population levels, but it will
be some time'yet before they can be determined.
See comment 13.
See "References Cited" in the DES for supporting data.
Miles of road by alternative has been incorporated into a table in
the section "Fish."
We have referenced the 1974-79 operating plan ES which has some of
this information. Most of the suggested items are not available.
We believe this has adequately been assessed in the recreation part
of the "Effects" section of the FES.
The Forest Service agrees and so states this on page 49 of the DES.
if
21. Reference is made mainly to roads, but it also includes other
developments that would concentrate people in the area.
22. Logging and roadbuilding are more severe adverse impacts on dispersed
recreation when they occur in a previously undeveloped portion of
the forest than in an area with, existing roads.
23. Agreed.
24. In some cases, one has to rely on the opinion and judgment of
experts such as foresters, soil scientists, biologist, and so
forth.
25. We believe the comparison table is a good way to weigh alternatives
as they relate to evaluation criteria.
JAY S. HAMMOND, Governor
OFFICE OF THE GOVERNOR
POUCH AD
DIVISION OF POLICY DEVELOPMENT AND PLANNING JUNEAU, ALASKA 99811
PHONE: 465-3512
February 1, 1979
Mr. James S. Watson
Forest Supervisor
U.S.D.A. Forest Service
Federal Building
Ketchikan, Alaska 99901
Subject: LPK Timber Sale
Plan for 1979-84 Draft Environmental Statement
State I.D. No. 78110301A
Dear Mr. Watson:
The State Clearinghouse has completed its review of the Louisiana
Pacific Corp, Ketchikan Division (LPK) Timber Sale Plan for 1979-84
Draft Environmental Statement. Consultation and review with the Depart-
ments of Commerce and Economic Development (CED), Environmental Con-
servation (DEC), Fish and Game (DF&G), Natural Resources (DNR), and
Transportation and Public Facilities (DOT/PF) provided us with the
material presented below, which represents the response of the State of
Alaska to the draft sale plan.
The draft Environmental statement (DES) states that the document "was
considered necessary because some previously unroaded and undeveloped
areas of the sale area must be planned for timber harvest prior to
completion of the Tongass Land Management Plan (TLMP)...". We would
like to reiterate our strong support for the Interdisciplinary Team
approach exemplified by the TLMP. We regret that the DES was prepared,
due to the ever changing nature of Federal decision-making on the
Tongass Forest, in the absence of the TLMP.
We support Alternative 4, the preferred alternative, and offer technical
recommendations and objections which we outline in the text of the let-
112
ter. But the major weakness of the DES, influencing both the content
and the tenor of our specific recommendations, is lack of any context to
review the plan within, other than as simply a consideration of the
harvest layout for the next operating period, 1979-1984.
A major focus of the DES should be to present the 5-year plan in the
context of long-range timber harvest in the’Ketchikan working cycle.
The 5-year plan is not an isolated action but is an increment of the 50-
year contract built on the foundation of past harvests and serves to
define future opportunities, both for harvest and for amenities.
The impacts considered are basically only those short-term impacts
resulting from localized harvest activities. Because of this, little
appreciation can be gained for the long-term significance and potential
environmental impact of the 5-year plan itself, or the 50-year contract
it represents.
All that is accomplished by the DES, is to indicate that Alternative l,
proposed by LPK, does not conform to the policies of the "Southeast
Alaska Area Guide" and measures poorly against the evaluation criteria,
while Alternative 4 meets Guide policies and evaluation criteria rel-
atively well.
It is due to the absence of the TLMP, and perhaps even with the TLMP
depending upon the Federal decisions on the Tongass through either the
RARE II or D-2 process, that these weaknesses of the DES should be
attributed to.
With regard to the DES itself, the introduction states: "This...state—
ment evaluates alternatives for the harvest of 960 MM bm of timber on
Tongass National Forest lands...". (page 1) Although technically cor-
rect, this statement is misleading. Five alternatives are detailed, but
only one, the preferred alternative, addresses all of the criteria
listed in Section III (pp. 24-25). Alternatives 2,3 and 5 fail to meet
the primary criterion, that the total volume be taken from the primary
sale area. Alternative 1, since it enters all remaining roadless areas,
fails to address the fourth criterion. Thus, the choice is limited to
Alternative 4. Perhaps "alternative" is the wrong word. If the Inter-
disciplinary team (IDT) process consists of going from point A, LPK's
unacceptable proposal, to point B, Alternative 4, then the process
should be described as such, rather than giving the reader the impression
that five acceptable proposals for timber harvest are presented.
In looking at specific proposals put forth in the preferred Alternative
4, we see three major technical problems to which we will now speak.
I. ROADS
One of the evaluation criteria in the DES is completion of the intra-
island road system. The Forest Service proposes to extend a road to
Hydaburg and to complete connections to Coffman Cove, Whale Pass and
Labouchere Bay on the northern end of Prince of Wales. The rationale
for the intra-island road system apparently includes promoting social
and economic community interties, allowing expanded recreational travel,
providing an alternative to sometimes hazardous air travel and estab-—
lishing new ferry terminals.
The preferred alternative, number 4, does not indicate that the exten-
tion to Hydaburg will be constructed by the Forest Service over the life
of this plan. We are aware that discussions are occurring between
DOT/PF, the Forest Service and the Federal Highways Administration
concerning the Hydaburg road in connection with the Forest Highways
Program. The State supports the completion of the Hydaburg road con—
nection because it is one of the objectives of the Southeast Alaska
Transportation Study. It is agreed that if this road is scheduled for
completion in the future, the project would be subject to the review
ibis}
processes appropriate for Forest Highways projects. Due to this fact,
our comments here refer only to the upper island connections from Sarkar
Lakes through to Red Bay.
The State of Alaska opposes the construction of the connecting road
system until such time as the following factors are considered, and in
light of this study, the road connections are deemed justified.
(1)
(2)
(3)
We oppose any cutting in the Sarkar Lakes or Red Lake watersheds
(see below). Given that this is the case, we would question both
the continued economic viability of the roads and the rationale
behind the particular routes chosen, if they are not to be used as
access roads for logging in these areas. Though it does not appear
that the Sarkar Lakes watershed proper would be entered during the
next 5 years, the selection of major road extentions, arteries, or
timber harvest paths will to a large extent determine the flow of
the timber-harvest over the remaining life of the contract. Undue
pressure may result for harvesting within areas which are environ-
mentally sensitive based on the prior construction of road through
or near the area. This can be seen by a consideration of the
placement of cuts in Alternative 1, the alternative proposed by
LPK, where cuts are clustered around or near existing roadways.
Any extension and completion of the upper island road system must
be conceived and considered within a discussion of the future cut
placement, which is lacking in the DES. We do not see adequate
justification for the roads, nor a thorough enough economic cost—
benefit analysis of the routes chosen in the DES, in lieu of our
opposition to any cuts in the Red Lake or Sarkar Lakes Watersheds. ,
Any road construction, expansion or extention will have social
impacts upon the citizens of Alaska and perhaps ultimately upon the
resources of the State of Alaska. We believe that such a major
transportation development should not be undertaken without a
thorough and visible public planning process. We note in partic-
ular that the Alaska Coastal Management Program, with which Forest
Service activities must be consistent upon the program's adoption,
will require when approved that "Transportation and utility routes
and facilities in the coastal area must be sited, designed and
constructed so as to be compatible with local community goals and
desires as expressed in district programs and local comprehensive
Public transportation development should not be undertaken
by the Forest Service except where support for such development is
expressed in district programs or local comprehensive plans.
plans."
We are aware that with respect to similar type road ventures within
Southeast Alaska, the discussion of maintenance and subsequent lia-
bility is occurring between the Forest Service and DOT/PF. Both
the type of construction and responsibility for maintenance should
be determined prior to construction. The answers to these ques—
tions, however, cannot be adequately anticipated without a vigorous
impact analysis which is currently lacking in the DES. Some of the
potential problems which would be detrimental if unresolved or
which need public involvement in order to establish their accepta-
bility to those communities impacted by the road system are:
a.
Erosion and subsequent water quality problems tend to
occur from roads which are not properly maintained.
Access to uninhibited areas promotes solid waste prob-
lems, off-road vehicle use, damage to fish and game
resources, and other environmental problems.
Unauthorized habitations may be constructed.
Demand may grow in the future for a number of costly
services, from road maintenance to extension of municipal
services.
114
e. Areas that were previously roadless will lose their
undeveloped character.
II. HARVEST LEVELS
The State of Alaska recognizes and acknowledges the contractual obli-
gation stated on page 2 of the DES: "The Forest Service SHALL make up
to 960 MM bm available in each 5-year period if the purchaser requests."
The only two alternatives outlined in the DES which fulfill this obli-
gation are number 4, the preferred alternative, and number 1, the LPK
alternative. Of these two, the State of Alaska supports Alternative
number 4, however, we have three specific serious recommendations and
objections with which we qualify this support.
(1) As mentioned above, we oppose any cutting units in either the
Sarkar Lakes or Red Lake Watersheds. These are areas of high
fisheries and wilderness amenities values, and great precaution
should be taken not to impair these values. We do support the
selection of other, less envionmentally sensitive units, either
within the primary sale area or on the remainder of the pulpwood
allottments. We would appreciate that the FES indicate which
cutting units, if any, are substituted for the sensitive units.
(2) The LPK timber sale plan proposes timber harvest on four (4) State
selections and a log dump site on an additional selection. Under
Alternative 4, timber would be cut on the Port Protection, Hollis,
Thorne Bay, and Whale Passage selections and a log dump site estab-—-
lished at Shrimp Bay. The total volume to be taken is unclear, but
appears to be on the order of 15 MM BF. Based on the arguments
outlined below for each site, the State of Alaska objects to any
harvest on these selections at this time.
The Port Protection and Thorne Bay selections received Forest
Service approval on June 6, 1978, with a "reservation" that timber
in certain units might be harvested in the 1979-1984 operating
period. The State has previously notified the Forest Service that
it does not agree that the Forest Service has the legal right to
place reservations on State selections as the planned harvest in
the 1979-1984 period does not constitute a valid existing right for
LPK.
The Hollis selection received conceptual approval in the June 6
letter, but has not received formal approval. The Whale Passage
selection has received no action to date. The State objects to
planned harvest on both selections at this time.
The Shrimp Bay selection was made both as a hatchery site and rec-—
reation site. Although this selection was denied in a January 11,
1979 letter, the State plans to file an administrative appeal.
Therefore, until the appeal is resolved or the proposed action is
fully discussed with appropriate State representatives and con-—
sensus reached that the activity will not impair the site with
respect to the purposes for which it was selected, the State
objects to the planned activity.
The appropriate resolution to these concerns would be to substitute
additional volume within the sale area for the volume anticipated
from State selections, or alternatively, to negotiate an agreement
with the State which satisfies State concerns on its selections
while not prejudging or in any way compromising the State's posi-
tion that the units do not constitute valid, existing rights for
LPK.
(3) The question of timber volumes necessary to protect employment
opportunities, and the resultant trade off with wilderness, wild-
life, and fisheries resources is one that will continue to be asked
115
10
over the life of the 5-year sale plan. We quote from the letter
from Commissioner LeResche to you on August 4, 1978, on the draft
Tongass Land Management Plan (TLMP): "The State of Alaska's first
goal is that the...(TLMP) must provide sufficient timber volumes to
maintain the present level of employment in our timber industry."
(page 2) "Sufficient timber must be made available to the industry
without reliance on private lands, but if private timber is avail-
able, less must be provided from the forest." (page 4) In that
letter, the State of Alaska outlined ways flexibility should be
built into the planning process. This would allow for necessary
changes in the specific decisions of the plan, depending on the
validity of the economic assumptions upon which the planned deci-
sions were based. We would suggest a similar process here. The
DES states that "an annual harvest of about 250 to 300 MM bm is
needed to maintain economic stability on the Ketchikan Area. The
five-year volume of 960 MM bm represents about two-thirds that
amount." (page 58) 960 MM bm, however, represents “about two-
thirds" of the upper limit of the “about 250-300 MM bm" per year.
It appears that LPK will not cut roughly 15% of the timber allotted
in the current 5-year plan. This situation may also result for the
79-84 plan. Hence there needs to be flexibility in the actions
based on projections associated with economic stability. To
coordinate this flexibility with the desire to minimize "jobs vs.
environment" arguments, we propose that the Forest Service develop
a yearly prioritization schedule of cutting units, ranging from the
least environmentally sensitive to most enviromentally sensitive,
among the cuts selected to be logged over the life of the plan.
This would indicate to the public, as well as LPK, units which
would not be cut if the full allotment is not used. It would also
provide the basis for meaningful public discussion of the trade-
offs occurring between economic values and other amenities if the
harvest levels, combining all sources of timber, are determined by
economic factors beyond the maintenance of the current employment
level in the Ketchikan area.
The description of the affected environment should indicate, 2ccompanied
by maps, the volume and location of all past harvest areas and the
location and character of remaining timber suitable for harvest. It
should illustrate the harvest units of the current 5-year plan, and
indicate which of those will not be cut in the current period. It
should discuss the role of timber harvested from the primary sale area
in relation to timber received by LPK from other sources and to other
harvests within the region. It should also discuss the market outlook
for the 5-year period and the status of LPK processing and marketing
activites. The environmental impacts of the 5-year plan should be
presented as an increment in relation to the 50-year contract throughout
the primary sale area. (Our rgmarks here are also pertinent with regards
to the ALP sale plan scheduled for release shortly.)
The State of Alaska would welcome the opportunity to continue working
with the Forest Service to prioritize the cutting units, as this would
best help us meet our mandate of maintaining economic stability
with the least possible damage to other forest values. If the Forest
Service feels that this prioritization is not possible, we would suggest
they consider the outlook for ability to meet the terms of the 50-year
contract, and, indeed, to harvest through a 100-year rotation, while
complying with environmental guidelines and with pollution control
standards.
III. WATER QUALITY
Impacts upon water quality constitute one of the major environmental
problems associated with timber harvest activities. Because of limited
field staff, poorly defined programs, and lack of coordination, both
within the Forest Service and within the State, viclations of water
quality standards do occur arid often are not properly mitigated.
116
As stated in the DES, the primary water quality impact is increased
sedimentation due to activites associated with roadbuilding. The DES
indicates that impacts are generally temporary, yet it defines temporary
as one to five years in duration. There would seem to be considerable
latitude for violation of the Alaska Water Quality Standards with
respect to sedimentation. Revised Standards, which will go into effect
shortly, allow no measurable increase in sedimentation above natural
conditions. The Standards establish procedures, however, for short-term
variences to allow temporary, unavoidable pollution in excess of the
standard.
The DES states that, "Alternatives 3,4, and 5=-these would affect water
quality in similar ways." (page 32) This is a true but incomplete
statement. The types of effects would be similar for all three alter-
natives, but the magnitude of the effects on water quality would differ
considerably. Alternative 4, calling for more miles of road construc
tion, has the highest potential for water quality damage. According to
Table 5 (p. 32), Alternative 4 affects more miles of stream in every
category. The environmental statement should indicate that differences
exist in the potential for stream damage.
It is also stated throughout the discussion of the effects on fish,
changes in water quality are referred to as temporary. Although in-
creases in sedimentation and temperature may be temporary, impacts on
fish populations may be more long-lasting. The potential longer-term
effects of fish populations deserve mention.
The DES, in addition, mentions that "best management practices (BMP's)"
are being developed by the Department of Environmental Conservation
(along with the Department of Natural Resources) to control nonpoint
pollution from timber harvest activities. The BMP's, if properly
implemented, should provide the most practicable and effective control
of water quality impacts. Achieving proper implementation of this
program will require considerable effort and cooperation by both the
Forest Service and the State. The State is available to work with the
Forest Service in an attempt to achieve this proper implementation.
The DES further states that, "all anticipated (temporary changes in
water quality) can be reduced to acceptable levels and returned to
natural levels through proper planning and enforcement of watershed
protection measures during and after logging activities." A difficult
situation is created by the recognition that sedimentation will occur in
violation of the Alaska Water Quality Standards. The persistent occur-
rence of substantial water quality violations indicates a strong need to
improve both planning and enforcement efforts if the optimistic atti-
tutde of the DES is to be realized.
In our view, the environmental statement should recognize that substan—
tial water quality problems do occur and that any sedimentation which
occurs constitutes a violation of State law through the Alaska Water
Quality Standards. To judge that, "some adverse but acceptable impacts
will result" is not a satisfactory approach to compliance with the
Standards. We would refer to Executive Order 12088, which establishes
that, "the head of each Executive Agency is responsible for compliance
with applicable pollution control standards, including those established
pursuant to... (the) Federal Water Pollution Control Act, as amended..."
The Order also requires each Executive agency to submit an annual plan
to the Office of Management and Budget for the control of environmental
pollution, which must provide for compliance with all applicable pollu-
tion control standards.
OTHER COMMENTS
We have the other following specific comments on the DES.
ly
12
13
14
16
Differention in magnitude of effects on water, fish, wildlife habitat
and estuarine areas should be made between alternatives 3,4, and 5.
Though the type of effect will be similar, greater impact in general
will result from selection of alternative number 4, over alternatives 3
and 5. This should be stated.
On page 38 retention of fringe around the estuarine areas is given as
500-1000 feet. This should be a minimum of % mile. If there is any
question of windfirmness, the fringe should extend to a windfirm bound-
ary beyond % mile.
Reports during 1978 suggested that the Forest Service was subsidizing
the timber companies in Alaska, and that the State of Alaska was sub-
sidizing out-of-State loggers with unemployment insurance benefits. The
first allegation depends on the economic scope of the reporter. The
second problem relates closely to the contractual agreement. Section 23
of the Timber Sale Agreement states "...labor for the conduct of logging
operations, mills and manufacturing plants conducted by the purchaser,
its affiliates, subsidiaries or contractors...be recruited from residents
of Southeast Alaska." In 1977, however, 44% of the unemployment insur-
ance payments made to unemployed persons in the logging, lumber and pulp
industry (SIC 24, 26) went outside of Alaska.
The State would like to see a renewed effort by industry to hire year-
round Alaska residents. This effort is as critical as the availability
of timber in maintaining Ketchikan area employment at its present level.
One major point which was not discussed in this document was the addi-
tion of 100 MM bm of blowdown. We have no argument with the salvage of
blowdown timber, however, it should have been addressed in the DES. In
addition, since the recommended alternative provided 960 MM bm without
the blowdown, we assumed there was now a 100 MM bm surplus. Upon checking
with the Forest Service, we were informed that our assumption was not
accurate. Projection of the amount of timber available in the preferred
alternative had fallen short of 960 MM bm by about 85 MM bm based on
more recent projections. The reasons for the error in projection should
be outlined in the DES.
The citation of Public Law 92-500, as on page 60 of the DES, should
read: the Federal Water Pollution Control Act of 1972 (P.L. 92-500), us
amended. On the same page, the reference is "National Pollutant
Discharge Elimination System."
As was stated earlier, the State of Alaska conditionally supports
Alternative 4. We would like to reiterate our desire to work with the
Forest Service in implementing the specific recommendations expressed in
this letter into the FES. If'we can be of any further assistance in
coordinating State involvement with the Forest Service in this effort,
please contact us.
Attached to this letter are comments received by the Clearinghouse
through thé process of official A-95 review from the Point Baker Asso-
ciation.
Thank you for the opportunity to comment.
Sincerely,
Jerry L. Madden
State-Federal Coordinator
BR:cl
118
Box 535 ;
Petersburg, Alaska 99833
Bill Ross
Office of Policy and Planning
Governor's Office
Capitol Building
Juneau, Alaska 99833
Dear Bill:
Following my conversation with Rick Reed last week, I learned
that I could find out about the stage of the State clearing house
response to the LPK EIS and thus expedite input of the Point
Baker Association; when I stumbled into the planning meeting at
DNR on Friday or Thursday, I learned that I had to get my comments in
soon or the team would not consider them; that they had to be in
writing. So here they are and hope the State will be responsive,
as many of Hammond's ardent backers like Zieske my buddy are counting
On SG.
Sincerely yours,
Sim)
Alan Stein
a =
Box 535
Petersburg, Alaska 99833
January 25, 1979
Ried Stoops
Office of the Commissioner
Department of Natural Nesources
State Office Building
Juneau, Alaska 99801
Dear Ried
I hope that the State’s response to the LPK EIS will include the follwwing points
I Point Baker
@ no cutting on Protection Head because of its importance as a wind break
to both Beker and Protection
b remove cuts within one mile of the State Land selection
ce reduce the number of cuts on Mount Calder and view area which are seen
from cruise ships and by local residents as an eye sore of that majastic
macnificient and malevolent monstor of a peak
d move 10% of the volume from within three miles of Baker to other areas.
The 1974 promise in the KPC EIS is broken
Ate)
IL Fisheries Section
a the state must complain,as Dick Logan promised me, to demand the Forest
Service improve its data base on small streams before laying out 350
clear chts. The FS admits that its estimates on these streams is but 60%
accurate. This is a clear violation of their policy guidlines in the
Area Guide. It is planning based gn the flip of a coin.
b the state must reactivate its guidline of the 1976 era to demand an RMA
be on hand for all bridge nlacements, culvert placements, and when cutting
adjacent to any streamd
More on Baker --remove the float in Port Protection or restrict its usage
to emergency operations. this is a violation of the EIS 1974
which nowhere except in the summary of meetings section
plans for this facility. The EAR for this facility was vigorously
rejected by the Point Baker Association and many individuals.
ed
Sincerely yours and hoping' for a copy of your comments
LP: ‘
y ee ee ae, *
CEQ ts Ge eee
Alan Stein 4
President Point Baker Association
ec the usual fishing groups
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE STATE OF ALASKA
is The Forest Service believes this concern has been sufficiently
addressed in the DEIS (see page 1 and evaluation criteria number 4
on page 24 of the DEIS). The Tongass Land Management Plan is basi-
cally a land allocation plan as opposed to a prescriptive plan.
The Forest Service withdrew from consideration for harvest all
roadless areas of public concern (including those of the State)
within the primary sale area to assure that this 5-year LPK plan
would not preempt the TLMP land allocations. This 5-year operating
plan is consistent with the RARE II decision and the TLMP decision.
2s Until the implementation of RARE II and TLMP, April 15, 1979, the
Forest Service is obligated to consider Wilderness for all roadless
areas when proposed activities would change the wilderness character
of land within inventoried roadless areas. We are also required by
our own policy to have a "no action" alternative in all environmental
assessments. Hence, Alternatives 2 and 5 were required. We believe
however, that similar alternatives would have evolved anyhow, as
our environmental assessment process (see Forest Service Manual
1950) requires a range of alternatives broad enough to cover issues,
concerns, and opportunities. Rarely, if ever, do all alternatives
meet all of the evaluation criteria. All the alternatives in the
DES are feasible. Alternative 2 could be implemented through a
costly settlement with LPK. Alternative 1 does not meet National
Forest System policy, but it was displayed and evaluated because it
represents the desires of a significant number of southeast Alaskans.
Alternatives 3 and 4 are both feasible, but Alternative 4 is the
most acceptable or desirable. Any additional alternatives would
not be greatly different than Alternatives 3 and 4, just different
dispersion patterns of the cutting units and roads within the same
or similar areas.
3. Section II-C-5 has been rewritten to better explain the rationale
for connecting roads.
4. No cutting units or new road construction is planned in Alternative
4 within the Red Lake watershed. In addition, this watershed is
only a small part of the land mass this road would serve.
120
The road and the cutting units which pass by the west side of the
Sarkar Lakes was authorized in the 1974-79 ES. The road is currently
constructed north to a point just across the Sarkar rapids. A
bridge costing more than $500,000 was constructed across the rapids
last year. The planning of this bridge was coordinated through
appropriate State and Federal agencies and, among other reasons,
commits this road to be the main line route to north Prince of
Wales Island. Completion to a point north of the lakes region is
expected prior to implementation of this 5-year plan. The road and
units were shown as proposed, even though previously authorized,
because completion of the timber cut is not expected until after
July 1, 1979. Initial-entry cutting units are shown on the FEIS
map for Alternative 4 in the areas served by the road connections.
The transportation section of the FEIS has been rewritten to provide
a better description of the need for these road connections.
Public planning for an intraisland road system on Prince of Wales
Island dates back to before 1970, when communities were contacted
on this subject in relation to the South Tongass Land Use Plan
which was replaced by the current Tongass Land Management Planning
effort. The 1974-79 FEIS also discussed the need for and intent to
construct the intraisland system in the transportation section
beginning on page 8. Informal discussions since, with community
leaders in Craig, Klawock, Hydaburg, Point Baker, and Port Protec-
tion, indicate no change in their basic position which was stated
in the DES for this period. That position is that Craig, Klawock,
and that part of the Hydaburg Road within the sale area are already
tied to the road system and they favor continued development of the
system, but Port Protection and Point Baker do not wish to be
included in the system. We believe this is consistent with the
State of Alaska's Southeast Alaska Transportation Study.
Although the intraisland road system will have some characteristics
of a public transportation development, it should be noted that the
system is designed for national forest administration and manage-
ment. Public use will be restricted, as described in the FEIS, to
the extent necessary. The Forest Service agrees that the State has
the primary responsibility for development of a public transportation
system for the communities and will cooperate with the State in
planning and constructing highways primarily for the purposes of
community development.
As part of the States comments on transportation, they quote from
the recently issued DEIS for Alaska's Coastal Management Program.
This program is in the draft phase and is still being reviewed.
Federal lands, by directive, are not a part of the States Coastal
Zone as outlined in the program. The reference to Forest Service
actions as "must be consistent" is partially misleading. Federal
actions must be consistent to the maximum extent practicable with
District, Area, and State plans. Presently, no such plans exist so
it is impossible to make a consistency determination.
The design, construction, and maintenance of forest development
roads are managerial considerations with which the Forest Service
has considerable experience and expertise. The Forest Service has
adequate procedures for mitigating the type of potential problems
envisioned by the State in items a-d. To reduce the need to repeat
information provided in other documents and sources, the DEIS
referenced the "Southeast Alaska Area Guide" and other documents
rather than expound on these points in great detail. Item E is
handled through the TLMP — RARE IT process.
No roads or cutting units are planned for the Red Lake watershed in
the 1979-84 period. For a discussion of the Sarkar Lakes watershed
see the comments on the Southeast Alaska Conservation Council
response (No. 1).
121
10.
a Ee
126
13.
Timber harvest planned and supervised under National Forest direc-
tion protects the environment to the degree necessary in relation
to the physical factors present at the site or else the units are
not allowed to be cut. The decisions relative to the allocation of
areas to roadless management of Wilderness is made through the RARE
II or TLMP processes.
In response to the State's concerns about harvest in areas selected
under the Statehood Act, we intend to meet with them in an attempt
to resolve the issue to the satisfaction of both parties.
All of the areas displayed for harvest in a 5-year period will
eventually have timber harvested either in the current period or a
subsequent period of the sale. Considering the 50-year length of
the sale, and assuming a 100-year rotation for the timber, we
assume that half of the commercial forest area will be cut by the
end of the sale. Actually, it may be necessary to cut somewhat
more than half in order to pay for development of roads through
deferred areas. Because of appraisal and logistical problems of
the logging operations, it is not possible to establish priorities
for units. Even if it were possible to do so, this would have
little significance since all units receive environmental safeguards
and will eventually be cut. The consideration of these alternatives
is a prioritization and represents a consideration of these factors.
The map information requested by the State is too voluminous and
expensive to make widespread public distribution in the FES. For
example, timber-type maps of the sale at a 2-inch-to-l-mile scale
cover 140 square feet of paper. The State of Alaska's Department
of Fish and Game has purchased some of these timber type map sheets
for project work. The timber type sheets do show the location of
past harvests and the location of remaining timber stands suitable
for harvest. About the only practical means of displaying this type
of information on such a large area has been done in the referenced
"Timber Land Type Task Force Reports" made during preparation of
the TLMP.
Discussion of the market outlook and sources of timber are not
repeated in this FEIS, as they have been assessed in the referenced
TLMP. LPK has legal rights under their contract (validated by the
NFMA) to select and harvest up to 960 MM bm in the 1979-84 period.
The water quality section of the final environmental statement has
been extensively rewritten to address the concerns raised by State
of Alaska's response to the draft. In those instances where we
anticipate temporary unavoidable pollution in excess of standards,
we will follow the variance procedures established by the State.
The magnitude of effects does vary between alternatives, although
it is very difficult to quantify because none of the alternatives
has been measured in the field to determine all the various factors
needed. The types of effects are generally well known and described,
based on previous experience. The relative quantification can be
estimated by assuming a straight-line relationship between volume
harvested and the effect on the environment. Caution is needed
when using this approach, as placement of cutting units and roads
can have as much effect on the environment as total volume to be
cut.
The retention area for estuarine wildlife habitat management units
is consistent with TLMP and was, in fact, taken from the Wildlife
Task Force Guidelines used to develop wildlife section for the
Tongass Land Management Plan. Windfirmness is always a key consider-
ation when designing cutting unit boundaries. The boundaries were
determined through the IDT process.
122
14. We support the State's concern for employment of southeast Alaska
residents. One of the basic objectives of the long-term timber
sale is to provide a stable economic base for the area. It should
be noted however, that the State's response failed to quote the
entire Section 23 of the contract. The words "So far as it is
practicable to do so..." preface the words the State quotes about
hiring local labor. Not all the skills needed to operate the
contract are available locally in sufficient quantity. Employment
under this contract represents something less than half the total
employment in Alaska logging. It is not fair to ascribe the total
nonresident unemployment payment to it. We join with the State in
encouraging renewed effort by all industries to hire year-round
Alaska residents.
15. The draft statement was nearly completed when the windstorm of
October 30 and November 1, 1978, occurred. It was not possible to
assess the extent of damage and modify alternatives in time to
include a discussion in the draft. Several significant changes
have been made in the layout as a result of the blowdown. The
final statement has been rewritten to include a discussion of the
blowdown.
The volume figures in the DEIS were estimates based on aerial photo
and map analysis. A subsequent field cruise of Alternative 4
revealed the estimates to be too high by 85 MM bm. We estimate
about 100 MM bm additional volume as a result of storm damage. We
did delete approximately 15 MM bm in units adjacent to extensive
storm damage.
16. The citation and reference have been corrected in the FEIS.
STATE OF ALASKA [sm
OFFICE OF THE GOVERNOR
POUCH AD
DIVISION OF POLICY DEVELOPMENT AND PLANNING JUNEAU, ALASKA 99811
PHONE: 465-3512
March 7, 1979
Mr. Jim Watson, Forest Administrator
U.S. Forest Service
Attn: Forest Supervisor
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
The State Clearinghouse would like to take this opportunity to clarify
and further explain our comments to you in our letter of February 1,
1979, concerning the Draft Environmental Statement of the LPK Timber
Sale Plan for 1979-84. We are doing so as the result of mutual dis-
cussions with you and Edgar Brannon concerning the language and context
of our February 1, letter. Like that letter, what follows is a result
of consultation with various state agencies, and represents the opinion
of the State of Alaska.
123
First, let me say that we reaffirm our support for alternative #4, the
preferred alternative, and that we welcome this opportunity to discuss
further with you technical reservations we have with the document and
with some of the decisions contained within it. As the state and the
Forest Service continue to work together on policy making procedures and
land allocation plans, working documents such as this DES sale plan
should be scrutinized as to how well the technical material and actual
decisions reflect established policies and allocations. We would hope
that our intention to do this is not construed as an abandonment of our
full support for the type of work the state has done with the Forest
Service on such tasks of great difficulty and scope as the Southeast
Area Guide and the Tongass Land Management Plan (TLMP). Similarly, as
we enter this era of continuing technical critique, outlined within
existing policy documents and land use allocation plans, we appreciate
the time and effort you have given in responding to our work, so that
consideration can be given to areas of possibly conflicting interpre-
tations.
In reference to the TLMP, the state realizes that the DES was delayed as
long as possible so that it could be developed as much as possible in
the context of TLMP decisions regarding land use. We also appreciate,
as has been outlined in our letter regarding the RARE II FEIS, the
pressure for timber harvest which is placed on that part of the Tongass
Forest not allocated to protective designation, due to the Carter Administra-
tion's actions in Southeast Alaska. Nonetheless, we would hope as has
been continually emphasized throughout the development of the TLMP, that
fhere remains flexibility in the on-the-ground decisions regarding the
actual timber harvested. We are not referring to a reduction of the
timber harvested, nor are we suggesting that LUD designations be changed
or swapped. However, new information which may influence and improve
forest management should continue to be sought, and ways developed for
this information to inform, and change if necessary, management decisions.
Thus we were pleased to hear that there will be no harvest over the next
five years in the Red Lake Watershed. As can be seen by reference to
the attachment, Red Lake is, according to new information to be published
shortly by the Department of Fish and Game, the most productive sport
fishing lake among 22 lakes in S.E. Alaska. The impression that we were
attempting to set precedent by opposing logging in a LUD III VCU (or
even a part thereof) without regards for the need to pick up additional
timber harvest from other LUD III, or IV, VCU's is unfortunate. Rather,
we assumed, and continue to hope that this assumption is accurate,
that harvest flexibility can be retained within and between VCU's, while
maintaining harvest levels. The average 13 percent retention figure for
a LUD IV and the 27 percent permanent retention figure for LUD III
should remain what has been described to us - a rule of thumb averaged
over a LUD class. The state stands willing to share with the Forest
Service new information as it develops regarding other forest values,
and to cooperate in advising on management decisions which protect these
values while insuring an acceptable level of timber harvest through a
shifting of harvest patterns.
The rationale for the upper island road system remains a point of con-
fusion with the state. Perhaps it would be best to articulate the
state's position and offer some recommendations as to how the need for
forest roads could be approached. We note that in our discussion with
you the responsibility of the state in developing public transportation
systems for communities was mutually acknowledged. The state has recognized
a need to connect Hydaburg to the other lower island communities, Klawock,
Craig, and Hollis, and is in discussion with the Forest Service and the
Federal Highways Administration concerning this. We do not see a trans-
portation need on the upper end of the island which would justify the
expenditure of the state's limited resources, for the purposes of community
development or interties. An expanded transportation system is not
necessarily a benefit to the state, and the need for logging roads
should not be confused with the need for a public access system. The
124
discussions the state is having with you concerning the Big Salt road
provides a good example of the difficulties the state faces when a road
designed for forest management needs spawns increased public demand,
resulting in pressure for state involvement when the road itself has not
been built according to state standards. Accordingly, at this time, the
state is reluctant to endorse transportation systems proposed on the
upper island which would point to the need for extensive state involvement
(either in maintenance or operation) in the near future, especially if
the road is not built originally to secondary road standards.
It appears to us that roads within forest areas subject to timber harvest
can have three justifications:
(1) those roads absolutely necessary to get at and remove the timber
harvest;
(2) those roads desirable to improve the quality of forest management
practices;
(3) those roads which acknowledge and satisfy the need for public
transportation systems.
These three types of roads cannot be compared according to the same
criteria, nor are the benefits of each type without their negative
implications. We would hope that the FES will look at the entire range
of ramifications and Forest Service's justification for the type of road
system you would propose to build. It would then be possible for the
state to discuss with you our impression of your plans and the extent to
which they might coordinate with or conflict with our goals and objec-—
tives.
In regard to coastal zone consistency, our earlier remarks should be
qualified. We would replace "must be consistent" on page three, line 7,
under Section (2), with "must be consistent to the maximun extent practi-
cable," pursuant to the Coastal Zone Management Act this requirement
will not take effect, of course, until federal approval of the Alaska
Coastal Management Program (ACMP) is received, which is anticipated
during the coming spring or summer.
All pertinent Alaska Statutes governing Forest Service activities on
National Forest lands, such as fish and game laws and water quality
regulations, are incorporated into the ACMP. Federally owned lands,
further, are exempt from the definition of the coastal zone. Hence,
adoption of the ACMP should not greatly modify the current interaction
between the Forest Service and the state. It should be noted however,
that Forest Service activities with significant spillover on the coastal
zone impacts beyond the boundaries of federal land, such as the develop-
ment of road networks and community connections, must be reviewed by the
state for consistency with the ACMP.
We appreciate your clarifying that all areas being considered statutorily
for wilderness or roadless designation have been removed from considera-
tion for harvest during this five year plan.
Our discussion of prioritization suffers from our choice of words. We
realize that the entire planning process associated with TLMP, RARE II,
the invocation of the Antiquities Act, and any subsequent acts of
Congress establishes priorities for areas of high amenities values which
should be protected. We are not suggesting that prioritization is not
occurring. We are, as we discussed in your office on January 31, 1979,
suggesting that a way to accomplish some "back-end" prioritization might
also be desirable as well. By this we mean that, although all the
timber identified for harvest over the five year plan may very well be
harvested, a way should be developed to prioritize timber so that if the
contractual volume is not all harvested, it would be the most environ-
mentally sensitive areas that would not be cut. It is unfortunate that
125
in our letter, we used the word units. Due to the economic considerations
of reasonable harvest practices, it would be more appropriate to prioritize
those watersheds which should be entered last in the five year period,
as opposed to units. If you are amenable to such a process, the state
would be glad to share information as to which watersheds this should
apply to.
As-you pointed out, the state did not quote in its entirety the language
of the contract pertaining to employment. The words "so far as it is
practicable to do so," should preface the quoted statement on page 8,
paragraph 4. We would stress that we interpret practicable to be a word
which implies to us a good, hard, strong effort on the part of all
parties concerned to achieve the goal of hiring Alaskan residents.
We did not mean to imply that the Forest Service's timing of the DES's
publication with respect to the blowdown was intended to avoid discus-
sion of it in the DES. We realize that the schedule of blowdowns,
originating from a power greater than humans, does not necessarily
coincide with the printing schedule of a document! We merely would like
to see a discussion in the FES of how the blowdown has influenced the
harvest pattern selected, how the error in timber yield occurred and
perhaps what changes might occur in Forest Service methods to prevent
such errors in the future.
As this letter will reach just shortly to the printing of the FES, we do
not know what impact it will have on that document. However, if we can
be of any further assistance in clarifying any additional concerns,
please contact us.
Sincerely,
Sa INO ee
Jerry L. Madden
State-Federal Coordinator
Enclosure
JLM:ms
FOREST SERVICE COMMENTS ON THE
SECOND RESPONSE OF THE STATE OF ALASKA
The Forest Service appreciates the State's clarification of its February
letter. We believe there is agreement between the Forest Service and
the State on all points discussed in this March 7 letter, but two.
These include roads and prioritization of areas.
Concerning the justification of roads, we would add two additional
reasons, and that is to improve the efficiency and feasibility of National
Forest management, and to provide better safety for up to 200 Forest
Service employees who otherwise would have to fly back and forth to
work. On those parts of the national forest, such as north Prince of
Wales Island that have topography suitable for an interconnected road
system, we believe it is desirable, solely from a National Forest manage-
ment standpoint, to construct an interconnected road system.
We understand the State's concern and recognize their role in planning
and constructing a permanent transportation system for the people of
Alaska. We believe that our staged approach, as outlined on pages 16
through 20 of the FEIS, provides the flexibility to meet the State's
goals as well as our own. We would suggest that further explanation and
resolution of this issue be resolved this spring at the scheduled meeting
between the Forest Service, the State, and the Federal Highway Admini-
stration.
126
Prioritization of the harvest, so environmentally sensitive units can be
deferred, is an attractive concept but very difficult to implement. It
should be noted that the Purchaser will have to cut at or near the 960
MM bf level for the remaining periods in order to meet his obligation of
8,250 MM bf by contract termination. Thus, there may be little benefit
to be gained.
We are however, prepared to enter negotiations with the State and the
Purchaser to explore this concept further. The major difficulty will be
to forecast the rate of cutting needed to supply a market 2 to 3 years
in the future so logging road construction can proceed in a timely
fashion. Scheduling of production depends upon more than gross volume
projections. Species/product mix, production capacities of various
camps and transfer facilities, and unforeseen natural events are vari-
ables over which the negotiating parties have very limited control.
Ketchikan Division
Post Office Box 6600
Ketchikan, Alaska 99901, U.S.A.
Telephone: 907-225-2151
Telex: 099-55-251
Answer back: KAYPULPCO KET
January 8, 1979
Mr. J. S. Watson
U. S. Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Jim:
This will be my first time since arriving in Alaska that I
have taken part in the LPK long-term sale five-year selection
process. Many changes have taken place in the last five years,
and they loom very large in this draft environmental statement.
1 The fact that an agency of the U. S. Government would propose
three out of five alternatives that would result in, if nota
major breach of contract, a total breach on the part of the
people of the United States, is appalling to me. It is further
evidence of the degree our autocratic, beaurocratic federal
system has sunk. This on top of recent administration high
handedness in invoking the Antiquities Act in land set aside
in Alaska, the Final Environmental Statement (RARE II) which
is thoroughly inadequate for the timber industry in Alaska
and makes a mockery of the public input process, abrogation of
foreign treaties, etc., leads me to wonder if our old set of
values of honesty, fairness, lawfullness, to name a few, have
any meaning anymore.
The entire draft approaches the five-year selection from a
completely negative viewpoint. After all, the intent is to
develop a forest harvest operating plan for the designated
2 area. The fact that the timber is sold and committed to by
both parties was established at the date of sale in 1951.
Timber harvest certainly takes last place in the eyes of the
IDT. The assumption that "the degree of impact on fisheries
is directly related to the amount of harvest adjacent to fish
streams" (P. 35) has no more support than a repetition of
"may", "could", "perhaps" scattered through the narrative.
i727)
On page 33, may I quote, "To date, research has not shown
that timber harvesting as conducted in Southeast Alaska
significantly affects fisheries resource...". Some facts
please before one resource must blindly pay for excesses
that "may" help another.
In the area of trivia I would like to make these comments:
1. Page 7 - Please show me some "Salal, a most
important shrub on the forest floor."
2. Cultural resources, p. 55, the effect on...historic
sites include "salteries, canneries, old mining
camps and activities." How long does it take to
make an old logging camp a historic site and there-
fore a part of our cultural resource?
In Table 12 - Evaluation Criteria:
I had the same objection in my TLMP comments. Every-
thing is weighted 10 regardless of relative importance.
I have an extremely difficult time trying to understand
that the possible impact on old canneries, salteries,
mines, etc., could be as important as the economic
viability of S. E. Alaska.
Therefore, my choice must be Alternative 1, and I do not
believe it to be single use. It is no different than the
last five-year selection and to now phrase it "single use"
must reflect on those, both U. S. Forest Service and LPK
personnel, who have worked so hard to make it a viable forest
Management operation. In all cases, any plan must be econom-
ically viable, protect jobs and meet contract requirements.
Very truly yours,
SW ae Ga Oa
Merle A. Mosar
General Manager
je
cc: Mr. John A. Sandor
Mr. Don L. Finney
FOREST SERVICE COMMENTS ON THE
RESPONSE OF LOUISIANA-PACIFIC CORPORATION (MERLE MOSER)
1. See comment on the State of Alaska response explaining the reason
for and validity of the alternatives.
2 Many changes have taken place since the contract in 1951. The most
significant are the National Environmental Policy Act and the
National Forest Management Act. These are laws that require new
policy and practices on the national forest. The Forest Service is
committed to their contract with LPK, but it is also committed to
the laws and regulations of the United States.
128
SOUTHEASTERN ALASKA
SEINE BOAT OWNERS & OPERATORS
728 WATER STREET
KETCHIKAN, ALASKA
99901
907-225-6618
January 31, 1979
James S. Watson
Forest Supervisor
U.S.D.A. Forest Service
Federal Building
Ketchikan, AK 99901
Dear Mr. Watson:
Our association would like to submit the following comments
regarding the LPK Timber Sale Plan for 1979 - 1984.
We recommend the use of Alternative 3. Although the harvest
of this alternative only allows for 794 mbf of timber, we
are aware of the need for LPK to have an additional 166 mbf
of timber for their operation. We would suggest that this
additional timber be made available from timber selections in
Alternative 45 for a total of 960 mb£.
This additional 166 mbf should not be from areas around Red
Bay or Tolstoi Bay due to fisheries habitat values in these
areas. We would encourage the usage of blow-down timber for
this harvest. Also, additional timber could be harvested
along existing road systems in the Tuxekan Passage area.
We would urge that the additional cuttings be in areas which
would require the least amount of road building.
We hope that the Forest Service will stay within the area
guide stipulation pertaining to water quality and fish habitat,
and that new road construction will be implemented for the
highest protection of the fisheries resources. We would also
like to emphasize the importance for the greatest possible
utilization of harvested timber before its exportation from the
State.
Sincerely,
SOUTHEAST ALASKA SEINE BOAT OWNERS & OPERATORS
Dg chele, X ae cc: Alaska Trollers Association
Michele Zerbet
: : : United Southeast Alaska Gillnetters
xecutive DireCtor Commercial Fishermen's Cooperative
United Fishermen of Alaska
MZnain.
Ie)
FOREST SERVICE COMMENTS ON THE
RESPONSE OF S.E. ALASKA SEINE BOAT OWNERS AND OPERATORS
1; Alternative 3 does not meet the contract commitment. If the
additional timber to make up the deficit in Alternative 3 were
selected from Alternative 4, then Alternative 3 would become so
similar to Alternative 4 as to be indistinguishable. Some changes,
however, were made in Alternative 4 as a result of catastrophic
blowdown that occurred in November. A substantial portion of this
was in Red Bay. See Section V-F of the FES to see how the blowdown
was incorporated into the selected alternative.
2% The Forest Service is committed to the "Southeast Alaska Area
Guide" policies and will do all in its power to see that they are
complied with.
| ALASKA TROLLERS ASSOCIATION
P.O. BOX 5825
KETCHIKAN, ALASKA 99901
: 907-225-9638
January 29,1978
James S. Watson
Forest Supervisor
U.S.D.A. Forest Service
Federal Building
Ketchikan, Alaska, 99901
Dear Mr. Watson:
The Alaska Trollers Association submits the following comments on the
D.E.I.S. for the LPK Timber Sale Plan for 1979-84.
We recommend Alternative 3, with additional timber volume to reach 960Ombf,
as the best alternative for both protecting the fishery resource and meet-
ing the needs of LPK. The 960mbf can be reached by adding 100mbf of blow-
down timber from the November storm and 66mbf of timber from Alternative
4 cutting units on Kasagn Peninsula, Marble Island, and Thorne Bay. These
additional cutting units would not require significant road building and
thus would not raise significantly the impact on fisheries habitat from
the original Alternative 3 at 794mbf.
We also recommend that the two small cutting units at Red Lake be replaced
by units from Alternative 4 that are already on the road system. Accord-
ing to a study by the Alaska Department of Fish and Game, Red Lake has
the highest conductivity of any lake in southeast Alaska. This conductivity
is directly tied to its high productivity and importance to the commercidl
and recreational fisheries.
We are very concerned about the loss of fish habitat due to culvert and
bridge construction in all of the alternatives. The Forest Service Fisheries
Specialist Report states that there will be an average of 17.78 square yards
of altered fish habitat for the average culvert installation. If this area
was all spawning gravel, then on the 245 miles of road built under Alterna-
tive 3, with the average of 7 culverts per mile, as was the case for the
1974-79 operating period, there would be 30,492.70 square yards of spawning
gravel lost. If half the culverts are on fish streams and there are two
spawners for each yard of gravel, then culvert installation would result
in the loss of 30,492 spawners a year and 152,463 salmon lost over the five
year period. This is a substantial loss to the commercial fishery when
130
returns from each pair of spawners is added. Even if this is not all
spawning gravel, there is still a loss in rearing and holding areas.
We feel the best way to cross fish streams is by bridging. In any case,
we urge the Forest Service to require arched culverts on all unbridged
crossings of fish streams to cut down on this habitat loss. We would like
to see an analysis of fish loss and proposals for mitigation.
We are also very concerned about the Forest Service's commitment to and
enforcement of Area Guide prescriptions on fish habitat and water quality.
There have been slides and heavy deposits of sediments that would not have
occurred if the Area Guide policies, which were to protect fish habitat
in all land use plans, had been enforced. During the working seasons of
1977 and 1978, Traitors River and Shaheen River have suffered heavy in-
creases in sediment loads due to poor road and bridge building practices
and poor response by the Forest Service. On the Traitors River in 1977,
A.D.F.&G. personnel observed turbidity and sediments from a slide when
there were 30,000 pink salmon holding in the bay. The Forest Service was
informed and took some action, but poor follow up resulted in the same
slide moving again after the November '78 storm. Corrective actions will
again have to be taken to stabilize the area. On the Shaheen River in
1977, poor bridge building practices also resulted in massive amounts of
sediment entering the river. Again in 1978, a large slide on the North
Fork of the Shaheen occurred when a road operator, after being asked by
the Forest Service to shut down operations because of unstable soils,
proceeded with operations on a Saturday. These situations have caused
and unknown quantity of damage to fish habitat and the fishery resource.
On pages 32 and 34, when discussing effects of Alternative 3,4,and 5,
on water quality and fish, the statement is made that the effects are
similar. There is no indication that the magnitude of the effects differs.
Alternative 4 has the highest potential for water quality damage and affects
more miles of fish stream.
On page 34 when discussing temporary changes in stream temperature, the
changes are described as acceptable with a return to natural conditions
after 10-15 years. The dry summers of '77 and '78 resulted in fish losses
on many logged over streams. This potential for fish loss should be des-
cribed and calculated.
On page 33, changes described as temporary increases in sediment may have
a long lasing effect on fish populations. The potential longer-term effects
should be described.
To assure the healthiness of both the fishing industry and the timber in-
dustry, the Alaska Trollers Association supports Alternative 3 with ad-
ditional timber volume. Thank you for the opportunity to comment.
Sincerely yours,
Mason Mewar
Sharon Newsome
Executive Secretary
cc: Southeast Alaska Seine Boat Owners and Operators
United Southeast Alaska Gillnetters
Commercial Fishermen's Cooperative
United Fishermen of Alaska
Is yit
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE ALASKA TROLLERS ASSOCIATION
AS See comment on the S.E. Alaska Seine Boat Owners and Operators
response (No. 1).
2 There will be no cutting in this watershed. See comment on the
State of Alaska response (No. 4).
3. We believe we have adequately protected fish habitat. In regard to
this, see the rewritten "Effects" section of the FES.
4. We are strongly committed to the Area Guide Policies. The record
shows that we have been very responsive to the Shaheen bridge
problem and the road slump in Traitor's River. See comments on the
Tongass Conservation Society and Southeast Alaska Conservation
Council responses.
bic The fish losses during those dry years were not correlated with
logging activity. Losses were severe in unlogged areas. Low flows
were the reason for the temperature increases. Timber removal can,
under some conditions, increase low flows.
6. See redrafted "Effects" section in the FES.
SOUTHERN SOUTHEAST REGIONAL
AQUACULTURE ASSOCIATION, INC.
307 Mill Street #5 Ketchikan, Alaska 99901
(907)225-9605 ox ;
President: Jake Jacobsen Executive Director: J.N. Milnes
February 1, 1979 RECEIVED
USFS - KA
FEB 2 1979
Mr. J. S. Watson, Forest Spvsr.
Tongass National Forest
Federal Building
Ketchikan, AK 99901
RE: LPK Timber Sale Plan for 1979 through 1984
Dear Mr. Watson:
SSRAA has reviewed this plan and offers the following recommendations:
1. The sale in the Neets Bay area creates a potential conflict with SSRAA's
plan releases of chum salmon in Neets Bay.
a. Floating net pens will be used to feed the salmon prior to their
release into the estuary. Log storage and net pens will be shar-
ing the same physical space. Log traffic in their use of the
1 storage area will have to avoid the pens.
b. Future hatchery siting will require an abundance of high-quality
fresh water. Logging effects on the stream's water quality must
meet hatchery water quality requirements.
c. Water quality in the estuary may be affected by log storage. The
fry released in the estuary stay for a period of time to graze.
Degradation of the estuary from log storage could adversely affect
fry survival and diminish the economic fry ability of releases in
the estuary.
2. The streams in the logging area on Prince of Wales Island are prime
salmon streams. It is not financially possible for SSRAA to define
stream-by-stream impacts of the effects of logging those areas. Al-
132
though SSRAA lacks the funds to be definitive, it wants to encourage
careful logging practices to protect water quality and rearing habitat.
a. Adherence to State water quality guidelines
b. Adherence to Forest Service guidelines for:
(1) water shed protection measures
(2) stream crossing and culverting
c. Use of KV funds to improve fisheries habitat
3. Alternative Number Four is recommended. Disruption of economic
stability and degradation to the salmon streams are not desired.
Realizing that SSRAA is presenting possible increases in regulatory controls for
logging, SSRAA intends to approach LPK directly with these concerns and attempt to
define a joint effort so that logging and salmon protection are not in conflict and
do not increase regulatory control.
Sincerely,
ah
PES oss Pa a at a
Ronald W. Wendte
Administrative Coordinator
cc: Gilimetter's _Assn-PRIVATE NON PROFIT HATCHERIES
Seiner's Assn.
LPK ;
SSRAA Directors
ee
at
FOREST SERVICE COMMENTS TO THE
RESPONSE TO THE SOUTHERN-SOUTHEAST
REGIONAL AQUACULTURE ASSOCIATION
ibe During the 1979-84 operating period, all log transfer and storage
activities in Neets Bay will be located at Fire Cove, approximately
two miles from both the hatchery and rearing pen sites. Log rafting
from that point will occur periodically (once a week), and each
trip will entail approximately two hours of travel time in the bay.
Coordination of travel should not cause a hardship on either fishing
or logging operations. No timber harvest activities are planned in
either watershed proposed for fry rearing and releases. All activi-
ties will meet State and Federal Water Quality Standards therefore,
optimizing water quality throughout the bay. SSRAA is correct in
predicting that marine log transport may adversely effect productiv-—
ity. Im the vicinity of Fire Cove, there will be some bark accumula-
tion and reduced light availability. This is not in an estuarine
zone and is not appreciable in magnitude, considering the entire
bay area.
Pon SSRAA additionally encouraged careful logging practices for protec-
tion of water quality and fish rearing habitats on Prince of Wales
Island. The preferred alternative has been developed along guide-
lines to protect water quality, watershed quality, and fish habitats.
133
South Tongass Co-chairmen
Land Review Committee Bob Pickerell
POBox SSS Sie KT PicisBorch
Ketchikan, Alaska 99901
907-225-3511
January 2, 1978
J. S. Watson
Forest Supervisor
U.S. Dept. of Agriculture
Federal Puilding
Ketchikan, Alaska 99901
Dear Mr. Watson:
After careful review of the LPK Timber Sale Plan the South Tongass Land Review
Committee unanamously supports Alternative ONE.
This decision was based primarily on two factors:
1. President Carter's withdrawal in November of 1976 of millions of
acres of wilderness land in the "Misty Fjiords" area adjacent to Ketchikan.
2. The most urgent priority during the next helf decade is to assure
steady employment for Ketchikan--Prince of \ales area residents.
Regarding factor jl: The needs of the area for Wilderness set asides have
been more than satisfied with the creation of Misty Fjiords as a National
Monument. Wilderness considerations on Prince of Wales Island are no lon-
ger a priority. Similiar, if not identical, eco-systems exist in thousands
of acres within the Misty Fjiords area. Alternative ONE contains tens of
thousands of acres that will remain essentially roadless wilderness areas
without establishing a formal classification.
Factor #2: Top priority for the forseeable future is to provide job es-
thetics and security for Ketchikan and Prince of Wales Island residents.
Alternative ONE is the only viable solution. In this era of inflation the
U.S. Government should do everything possible to lower development costs
thus allowing Alaskan industry to compete in world markets. All other
alternatives increase production costs and jeopordize job stability. In-
provements in production techniques will take care of long range harvest-
ing of upslope stands.
Alternative ONE has little effect on fishery resources. Above average catches
of salmon have occurred during the past few years in the Ketchikan area...
This proving that proper timber harvesting has a minimal impact on this re-
source and the the jobs it provides.
Recreational and transportation aspects on Prince of Wales Island are improved
in Alternative ONE and create additional job opportunities in these catagor-
ies.
Thank you for the opportunity to comment on the environmental statement. Ous
compliments to your staff for the presentation you prepared.
Sincerely,
eee S iw yy
: fy
. » .
™ bl MN Ne ee
Dick Borch
Bob Pickrell
Co-Chairman
x
pep 134
FOREST SERVICE COMMENTS ON THE
RESPONSE OF SOUTH TONGASS LAND REVIEW COMMITTEE
Ihe Alternative 1 does not meet national forest policy. See comments
on the State of Alaska response (No. 2).
2509 Fourth Ave.
Ketchikan, AK 99901
January 30, 1979
Us Vlatsen Eres Supere ISO ;
.S.D.A. Forest Service, AK Region
Tongass National Forest, Ketchikan Area
Federal Building
Ketchikan, AK 99901
In re: LPK Timber Sale Plan for 1979-84
Dear Mr. Watson:
I have considered the five alternatives detailed in the LPK Timber
Sale D.E.I.S. Thank you for inviting comment on this document.
Slternative 1 and Alternative 2 propose extremes unacceptable to me,
the second one obviously included as a theoretical possibility not
very practical from any point of view. Alternative 4 seems to be
reasonable, I can understand the Forest Service's support of this
proposal.
Given, however, apparent overproduction by LPK during the past year,
as demonstrated by their willingness to let strikers stay out and
families whose support has been employment at LPK actually leave the
community, I'm moved to ask whether their request for 960 MM bm from
the primary sale area is very real. Maybe this is a good year to
give the fish, the wildlife, and our resources for future generations
a chance to multiply. Maybe this is not only the "year of the goat"
but also the "year of the environmentalist." At the moment they
aren't very eager to employ anybody, and they seem to be saying
theywant to reduce inventories, Perhaps it is not unreasonable to
ask whether 794 MM bm as proposed in Alternative 3, or 685 MM bm as
proposed in Alternative 5 wouldn't be sufficient to keep those who
still remain in Ketchikan employed, LPK's customers satisfied, and
enhance other equally valuable resource alternatives, such as fish,
wildlife, and recreation and tourism.
Because Alternative 5 includes areas identified in the RARE II
planning process, which I believe will be proven wiser upon future
consideration than it appears to many at the present, that is my
first choice, I'd go with Alternative 3 if compromise were necessary.
I speak as an individual and not as a representative of any organiza-
tion with which I might be affiliated. Again, thank you for the
opportunity to respond,
Sincerely yours,
Onilin 4, Sad fcl
Constance F., Griffith
CFG:s FOREST SERVICE COMMENTS ON THE
RESPONSE OF CONSTANCE GRIFFITH
alts The Forest Service, by contract obligation must provide up to 960
MM bm per 5-year operating period. This amounts to 192 MM bm per
year, well below the 220 MM bm program harvest established in the
TLMP for the Ketchikan Area.
135
DRS. WILSON AND WILSON, P.C.
ARTHUR N. WILSON, M.D.
JAMES A. WILSON, M.D., F.A.C.S.
ARTHUR N. WILSON, JR., M.D.
P.O. BOX {aid ss7g
KETCHIKAN, ALASKA 99901
December 29, 1978
U.S.D.A. Forest Service
Federal Building
Ketchikan, Alaska 99901
Mr. J.S. Watson, Forest Supervisor
Dear Mr. Watson:
I have reviewed the draft and environ-
mental statement published by the Dept. of
Agriculture for the L.P.K. timber sale for
79-84. I urge the Forest Service to hold to the
960 million board feet of timber necessary
for the pulp mill to continue at present level
of logging activity.
The continuous on-going logging effort
is terribly necessary to this area for all
those of us who are employed in the forest
product area as well as those of us in support-
ive roles in the community.
If this logging program gets cut back
further, I think that even further disasterous
impacts will impinge on Ketchikan as well as
all of Southeastern Alaska.
Sincerely,
James A. Wilson, M.D.
JAW: cw
cc: Don Finney L.P.K.
P.O. Box 6832
Ketchikan, Alaska 99901
USDA Forest Service 29 January 1979
Federal Building
Ketchikan, Alaska 99901
Dear Sirs/Madams:
we have recently reviewed the LPK Timber Sale Plan for 1979-1984
and wish to take this opportunity to express some thoughts on it.
we wholeheartedly support Alternative 5 of the Plan and urge you
to do likewise. We feel that this plan best protects against
environmental degradation while at the same time allowing a reason-
able level of timber harvest. In the final EIS released we urge
you, the Forest service folks, to provide as much information as
possible on the following: 1) historical use of timber, particu-
larly over the last 5 year plan, 2) current inventory of logs,
3) importation of chips from Canada, 4) export of logs to other
states, and 5) timber blown down during the November storm of Prince
of Wales which may be available for use in the mills.
136
2We strongly urge you to refrain from any cutting of timber at all
in the Salmon Bay and Sarkar Lakes areas. As the only two areas
on northern Prince of Wales still uncut, we feel strongly that they
should be spared the ax and saw so that they may remain in their
wild state.
We ask that the magnitude of the effects on water quality, soil,
fish and wildlife habitat for each alternative be clearly stated
in the final EIS.
3We oppose the consideration of the inter-island road system as a
Forest Service evaluation criteria. We are most concerned about
the adverse effect these roads and their accompanying culverts will
have on spawning gravel in fish-producing streams in the areas of
the roads. The fishing industry is of prime importance to the resi-
dents of Southeastern and this vital resource should be more than ade-
quately protected.
4 It has been brought to our attention, though a little publicized
fact, that detrimental road slides have occurred in the areas of
Traitors River and Shaheen Creek. Please see to it that Area Guide
presciptions are followed carefully during the next 5 year plan.
Thank you for your attention to our concerns. We appreciate your
consideration.
Very Sincerely yours,
Wan (C . Hhecbrsr ODS
Alan R. Deubner, DDS.
Render Fooipt Beulonor>
Linda Elliott Deubner
FOREST SERVICE COMMENTS ON THE
RESPONSE OF ALLAN AND LINDA DEUBNER
ils See comments on the Tongass Conservation Society response.
230 See comments on Southeast Alaska Conservation Council response (No.
il))c
Sie See comments on the State of Alaska response (No. 5).
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FOREST SERVICE COMMENTS ON THE
RESPONSE OF ORVEL AND CARMEN HOLUM
ibe Alternative 5 does not meet the contract obligation of the U.S.
Government.
Die See comments on the State of Alaska response (No. 5).
The Point Baker Association consists of fishermen living or having
residences in tthe villages of Point Baker and Port Protection on the
North end of the sale area for LPK on Printe of Wales Island. The PBA
will comment on the fisheries section, the consultation with others,
and the impact of the LPK Draft Environmental Statement on the two
RECEIVED
USFS - KA
FEB 2 1979
communities.
Fisheries
Zieske vs Butz challanged the previous EIS for K pRO.iu
K&L
in the preceeding five year operating period. Water cent y-Viol eos
were a major thrust of the suit which sought improved management of
fish stream habitat in the Tongass. The National Forest Manag ement Act
in 1976 set up provisional regulations resulting in the Tongass Area
Guide published in the spring of 1977. The AG set forth goals and
139
policies for protecting habitat. The Tongass Land Management Plan of
1978 inits draft form elaborated on the A@'s direction. A brief review of
these documents will provide the perspective for evaluating the
adequacy of the DES for LPK. Four yearw and millions of dollars of
planning effort have seperated us from the state of the art of fish
habitat protection that existed in 1974 when the PBA began efforts
that resulted in Zieske vs Butz.
Under Allocation issues, the TLMP indicates only one resource value
that that the FS through negotiation will not compromise-- the biological
productivity of fish streams. p49 In TLMP, protecting fish means to
protect the biological productivity of every fish stream in the Tongass,
of which there are 2,506.p91 Since no adequate research exists t
ar None §; cited in rhe DES,
determine the effects of timber harvest on productivity,@the FS takes
the appoach that the goal of fish habitat management can be met through
two approaches: 1) reserving enough land\through allocation to protect
streamside areas or 2) developing a management policy restrizting actvities. ory
Regardless of option, the FS gaurentees, "streams will be protected in
all allocation and management decisions."
The first option requires allocating a percentage of aperahle timber
to streamside strips of varying quantities of volume. The TLMP states
that 18% of operable timber would have to be reserved to protect fish,
wildlife, and recreation. p91 The regional forester in t e fall of 1973
placed the figure at 13%. But the TLMP Task Force Report on Fish indicates
11% operable timber would be placed in reserve to protect fish habitat
while 68% would be harvested by methods not currently employed such as
skyline loggiig. Despite descrepencies in timber volume to be reserved,
|
TLPM indicates th at the first figure quated above will"provide the
i!
|
i
latitude necessary to develop spevific prescriptions at the project
planning level."" How much volume the DES requires to meet this option is
not stated.
Whether the DES meets the policy guidelines laid down in the AG
to meet the second option is the cause of concern for the PBA. The
AG requires’ that decisions be made based on sufficient knowledge, information, —
and data. Further, the AG requires sufficient informaticn to permit
allocation decisions recognizing the cabability and sensitivity of major
140
fish habitats, At the presciptive stage,the IDT must develop protective
prescriptions based on the characteristics and sensitivity of the area
and will utilize, evaluate aud present and potential spawning and
fearing habitat for fish in main streams and all tributaries. Water
Quality standards will be maintained and a continuous program of
detailed research monitoring and assessment of land use impact on habitat
will be completed; results will modify practices to meet goals. Finally,
mitigation plans will be devekoped to prevent reoccurance of damage and
plans will be developed to deal with damage to habitat.
Does the DES present sufficient data, knowledge, and information
f
or allocating 359 clearcuts averaging 70 acres and building 245 miles of
road?
Unlike the 1974 DES, the 197° D&S fails to provide the reader with
maps locating streams in relationship to land development activities
in the Point Baker Area. Mpas for the entire sales area would be useful.
The statemnt that the main method of identifying smeeer streams, especially
smaller streams,was mapa and aerial photographs and th this method
has an error factor of 40% calls into question whether Area Guide goals
or policy gam was met; how can allocations be made to protect streams
if the existence and location of them is unknown? Does map identification
allow for accurate designation of temperature senbitive streams; does it
meet latest state of the art methods available to anyone reviewing the
literature? From talking to FS biologists,it is our understanding that
this method was employed to carry out the guidelines for temperature
sensitive streams in the 1974 EIS which are essentially unchanged in the
1979 DES. It should be noted that 40% accuracy figure applies to smaller
streams and tributaries but of the 205 cataloged fish streams in the
sale area, Fish and Game evaluated only 42. The total number of miles
of stremas in the sale area should also be made available. The reader
Should know if anly the 42 streams were considered inthe DES, What information
did the IDT c@édect on these streams and on smaller ones? Why wasn't
ths& data made available to the reader?
141
The fisheries report for the DES states that typical fish habitat
management units will be given prescriptive protection measures and that
these generalized, concepts of a fhmu will be applied before units are
relesed for cutting. It is our understanding then that surveyors of
stremas will be doiing their work to keep ahead of road building crews
and we question whether adequate time willl be available to meet AG policy;
further, does the AG require knowledge or information on specific streams
so that allocation protection can be planned for the entire sale area?
How can palns to implement policies restricting activities be carried out,
if data on the productivity or carrying capacity of a stream has nat been
collected at the DES stage, since knowing the volume that must be reserved
to protect producitivty is a key factor in setting ths up the clearcut
locations. Is aerial map methodadology sufficient to predict the impact
that development can have on stream characteristics? The DES only tells
us approxiamtely 3.37 acres of spawning gravel will be permanently
taken out of production because of culvert and bridge construction (p20
peasee report our extrapolation). We know from readily available published
reports that the value of this area that will be taken out of production
is worth $1,853,500. Is this loss within the ragge allowable under the
Area Guide goal for fish?
We are concerned that the DES recognizes that primarily lower mainstream
and intertidal areas: consistitute the bulk of fish habitat.p9 The ‘imemlLicist
implication in that discussion is that headwaters are less important aspects
of hepitat. We would like to see the reasoning behind this conclusion
supported with data or citation of literature. Does tthe forest service
consider in other literature the importance of headwater sources of
water to fish population? The further assumption on the bottom of page
9 that hebitat protective measures will be incorporated into the
final unit release appears as an excuse for having not collected
sufficient data and the fact that the supervisor approved the guidelines
for ppotective neasursspttiteates that subsequent literature and research
may have provided grounds for modification according to AG policy.
We are concerned that the review of the literature starting on page
ten of Pease& report does not always acurately or fairly describe
142
conclusions of reports and in some instances fail@w to cite state of
the art reports which could alter operating procedures or policies,
In some cases: we feel feel descriptions of reports are misleading.
For instance, the point about the Myren report is that because of
variabilities in the stream and ocean, it is impossible to predict the
impact of logging on fish populations except at a several fold change
level. In light of the failure tp predict chhnges to populations, he
recommends examining qualitatitte factors such as stream characteristics.
fhe implication of his report is that hard data on stream characteristics
must be collected. The summary of the Meehan report 1969, which reaches
a contrary conclusion to the Myren report, should mention the statisticalts
errors that Myren has documented and because it has come under severe
review, mention its shortcomings. This report should no longer be cited
by the Forest Service in EIS reports as a justification for cutting near
streams. Id aoe prevailing information should be provided that presents
contrary information.
We are concerned that State of Alaska Water Qualiity Standards will
not he met, a goal of the AG. The Pease report states that"professional
judgement had to subsatzzute sufficefor hard data when making judgements
about temperature sensitive streams." We wonder. how on p8 topographic
features can pwpvide shading at critical points in the sun's position directly
overhead at noon. We wonder if the consideration of marginal habitat on
pS bottom was made based on hard data. We would like to know how many
of the 160 streams that Fish and Game did not evaluate were examined on the
ground. How many tributaries were examined? How will the State Water Quality
Standards be enforced? We are not encouraged by the statement that "throgu
proper streamside management practices, th potential reduction in fish
productivity will be minimized to am acceptahle level and aprroach normal
fifteen years after harvest." p21 Peases
The discussion of blowdown in Pease is an attempt to discredit the
leave strip idea. The failure to present literature, reports, and
statements favorable to buffer strips, shaazd that will present
views contrary to the blowdown argument is a rather viatant fw
misleading. discussione
143
On estuany impacts, we would like to see reports or studies on
frp migration and feeding routes in areas that have or will have
log storage or dumping. Effects of fry migration and feed availablity
in estuaries is an important phase of pe as Aan site identification.
dk: feyget n= TO eishshy aoa
e discussion of the habitat improvents leaves us ajar. Catch-22
thinking is evident here. In order to improve the stream we must impact
it is the reasdning behiné@ the funding arangement and adverse impacts
of development shoujd be weigh ed against benefits before reaching out
for pork barrel projects shch as this.
Beacause of the inadequacies of the DES to meet AG policy, we
recommend that allocation reservations be made along all fish habitat
and be windfirm, We feel state of the art studies justify this recommendation,
We choose alternative 5 because it nce most to protect headwater
reaches. However, we would like to see certain modifications, We wonder
if timber from road removal is included in the amount taken from clear
cuts. If it is not, the allocation goal to LPK could probably be met.
Consultation with other section
to distribute public involvemnet information is rabid in its denounciation
of conservation orientated programs and therefore the forest service
in our opinion relied on an outlet that sigs mist concientious critics
frequently did not read. The timing of notification during the fishing
season was also most inappropriate.
Protection of Point'Baker
We are outraged about the alternative 4 plan for the Pt. Baker area.
At the hearing for an injunction for Zieske v Butz, we pleaded for
omition of clearcuts tht would expose out communities to wind damage.
The judge saw no legal basis for our arguments, Nevertheless, the year
after cutting began a severe storm brought down over 150 tress around the
community of Port Protection. Trecs came down in the clearing around my
home completely demolishing the shack I live@in during construction
of my cabin and breaking the roof on the cabin. Two members of the
community were almost killed when trees came down in front of their
144
10
13
14
stairs and atd only Jack Daniels got them through the terrifying night.
Trees came down in protected locations not adjacent to clearings. Yet
the preferred alternative proposes more cuts that will onen the area
up to winds; the cut on Protection Head, at eh head of Protection and
those S of Protection should be eliminated ot reduced considerably in size.
No more cutting should be allowed within one mile of the Stake Land
selection and the cut that is in the State Land selection should be eliminated
As ally Te FFE. =
Under nc cicumstances should there be any more cutting on Protection
Head.
The float in Port Protection was not mentioned in the DES 1974 and only
mentioned at one mut of two public meetings. Yet the FS cleimed then that
there was no objection to a facility whcih has been used widely by
a camp population of over two hundred neonle. Fishing, claming, crabbing,
and h nting continve in Port Protection as people who Have gaurenteed
incomes compete with many people in the communities that are living
Ssuhsistence lifestyles. Similar resources exist at the camp in Labouchere
Bay. We want to know what FS monitoring of illegal hinting activites
takes place on government roads. We want usage of the float restricted to
emergency medical evacuation and a smaller float put in. The EAR had
many objections from the people of the comrunities. We want the Forest
Service to give the State of Alaska its selections.
The 1974 EIS said that activity in the Point Baker area
would decline after the first five year plan; but now we see a drastic
increae in the amount of timber that will come out of the area. From this
we conclude that wildlife populations will be exterminated by camp residents
and land development. Already, trapping animals have just about been
wiped aut, as we predicted. This contrasts sharrly with the sustained
yield prasutices which three or four trappers in our community practiced,
We woudd like ta see a ten percent reduction in the amcunt of timber
taken within three milesof Point Baker in order to maintain the ¢nviornment
for the creatures which create the values which we hold high. Also there
are very few black bears left. We recommend thtat an enfarcement officer
be stationed in the camp or at least make suprize inspection patrols.
145
We do not want to see the road connection between the rest of the
island and Red Lake or Calder Bay-Hole in the Wall, as we feel resources
in the Red Bay area, perticully Red Salmon and Swans will be subjected to
undue pressure and as the 197), EIS states the North end is part of the
Forest Senvice's paan for the ferry connection to an island hoping
road system. We do not want to see the North end have a ferrry connection.
Sincerely yours
Alian Stein President Point Baker Association
We are also concerned that archeological resources in Labouchere Bay have
been wipped out. Also what is the mitigation plan for taking care of
such violations as a cat in Pat's Creek 1978 and heavy siltation in Traitor's
Creek 1977 as required in the Area G ide policy? pj ease cite stream monitorig
on Prince of Wales for Water Quality according to AG research prescriptions,
FOREST SERVICE COMMENTS ON THE
RESPONSE OF ALAN STEIN
A The Zieske suit against the Forest Service and former Secretary of
Agriculture Butz was based on alleged violations of Water Quality
Acts, the Multiple Use Sustained Yield Act, Wilderness Act, National
Environmental Policy Act, and violations of the Organic Act of
1897, establishing the national forests. The Zieske suit sought to
have the Forest Service enjoined from harvesting timber on 89,000
acres of north Prince of Wales Island adjacent to Port Protection,
Calder Bay, and Red Bay.
Judge von der Heydt of the U.S. District Court in Alaska found in
favor of the defendants, the Forest Service and USDA Secretary
Butz, on all points, except for the Organic Act on which a court
ruling had already been made in West Virgina. It ruled that clear-
cutting of trees other than individually marked trees, which were
either dead, mature, or of large growth, was illegal. This, in
effect, eliminated clearcutting nationwide as a harvest system on
the national forests. With this court precedent set and upheld in
the Appeals: Court, Judge von der Heydt enjoined the Forest Service
from harvesting timber by clearcutting small or immature trees
intermingled with large old-growth trees.
Passage of the National Forest Management Act by Congress in 1976
amended the Organic Act. This removed the legal basis for the
injunction from timber cutting on north Prince of Wales Island. It
did not "set up provisional regulations resulting in the Tongass
Area Guide,'' to quote Mr. Stein. The National Forest Management
Act requires the Forest Service, acting in concert with a National
Committee of Scientists from outside the Forest Service, to establish
146
regulations governing the management of national forests in all
States, not just in Alaska. These regulations are still in prepara-
tion and are expected to be promulgated before the end of this
calendar year.
The "Southeast Alaska Area Guide" was developed by the Tongass
National Forest as a first step in implementing relatively new
national forest policy governing land management planning and
decisionmaking. It is meant to guide the actions of Tongass National
Forest resource managers through various levels of planning and
implementation including the Tongass Land Management Plan (TLMP).
Compromise between demands of various user groups on the forest for
limited resources are recognized as necessary in the TLMP and in
the guide.
The allocation decisions addressed in TLMP allocate national forest
land by land use designations (LUD's) ranging from a few thousand
acres to as many as 2.3 million acres. These LUD's range from
Wilderness (LUD 1) to intensive development of resources (LUD 4).
Most of the primary timber sale area is allocated to LUD 4.
Alternatives 3, 4, and 5 of the DES for the 1979-84 operating
period were developed within the framework of TLMP, recognizing
that all entered areas were LUD III or IV and that compromises were
made between resources and that fish stream productivity was not
impaired.
One of the concerns Mr. Stein expresses is a lack of specificity or
quantification in the DES. The reason for this lack is twofold.
First, recent direction from the Council on Environmental Quality
is to reduce the size and scope of environmental statements particu-
larly where information is already available in other documents.
The purpose of this direction is to make the statement more readable
by concentrating on a description of the action proposed and its
effect on the environment expressed in conversational English.
Technical dissertations of interest to the scientific community and
technical experts are included by reference.
The second reason for the lack of specificity is that the alter-
natives are a "paper" layout, that is, the road locations and unit
boundaries for the most part exist only on maps and photos, not as
painted or blazed lines in the forest. Enough field reconnaissance
has been conducted since 1976 to assure us that the alternatives
could be implemented without significant environmental damage.
Protection of a fish stream from damage does not depend on whether
logging takes place adjacent to the stream or not, but rather the
type of logging permitted and how well the logging is done.
The skills of the sale administrator, logging engineer, and fisheries
biologist in supervising the cutting and yarding of each unit is
the best protection each stream can have. The goal of the interdis-—
ciplinary team in preparing the DES was to select units that would
be possible to lay out and log with minimal adverse impacts.
Maps describing each cutting unit are available for review, as
stated in the DES. Temperature-sensitive streams and cataloged
fish streams are also mapped and available both from aerial photo-
graphic interpretation and field reconnaissance. This data is
adequate to plan the location of cutting units.
Mr. Stein assumes that logging as such has an adverse impact on
fish habitat and populations. This assumption has little basis in
fact. So long as roads and cutting units are properly located and
147
10.
11.
logs, slash, and road construction debris are kept from fish streams,
adverse effects to fish are unlikely to occur. The only "allocation"
question occurs along temperature-sensitive streams where degree of
shade removal becomes a concern. Guidelines to protect temperature-
sensitive streams are a requirement in implementing any timber
harvest proposal involving such streams.
Our calculations indicate a potential dollar cost of approximately
$1,300 per year because of fish habitats affected by culverts.
This annual figure would probably not quite be reached, because all
culverts for the 5-year period are not installed on the first day
of the period, and some culverts are removed as roads are closed
before the end of the period. The rationale for our $1,300 estimate
is included in table 7.
There is no intent in the DES to imply that headwater portions of
streams are unimportant. The watershed section of the final state-
ment has been rewritten to clarify this point.
The statement on research literature review on p. 33 of the DES is
consistent with Mr. Stein's comment on the subject. In the FES,
see section V-C.
The section on effects to estuarine areas has been rewritten in the
FES. Also, see the Forest Service comments on the National Marine
Fisheries Service response.
Windthrow of trees in southeast Alaska's old-growth forests is not
uncommon. It is often associated with new road construction and
timber cutting practices. However, it is also a natural phenomenon
occurring without regard to man's activities. It should be noted
that windthrown trees associated with clearcuts and roadbuilding
are invariably contiguous with the manmade opening in the forest
canopy. It is our opinion that the storm damage Mr. Stein describes
at Port Protection is unrelated to the timber cutting on north
Prince of Wales Island, in that no continuous or even intermittent
"track" of blown down trees can be followed from a cutover unit to
Port Protection.
The units proposed for cutting under Alternative 4 were designed to
provide windfirm boundaries to the extent that windfirm boundaries
could be identified. Unit layout teams will be especially alert to
windthrow hazard as they mark the boundary of each cutting unit in
the field.
The cutting unit at the north end of Protection Head was erroneously
included in Alternative 4. Cutting units on proposed State land
selections are discussed in the comments on the State of Alaska
response to the DES.
The airplane float in Port Protection was discussed at a public
meeting before it was included in the FES for the 1974-79 period.
The subject has also subsequently been discussed with residents of
Port Protection and Point Baker. The float is needed as a human
safety precaution, because wind conditions in adjacent Labouchere
Bay sometimes make aircraft landings hazardous there.
Although the Forest Service does not specifically monitor illegal
hunting activities, our employees are required to report all viola-
tions of State law they observe to the Alaska State Troopers.
Because our employees are not trained police officers, they are not
expected to make arrests or otherwise expose themselves to dangerous
situations involving criminal activity. The Tongass National
Forest, under authority of 16USC 55la, does provide funding to the
State of Alaska for law enforcement on the national forest.
148
iar,
13.
14.
15.
16.
hae
MMial :
The 1974 ES does not say the level of activity would decline after
the first 5-year plan. It says the level of activity would likely
decline after the first entry is completed. The first entry was
defined as removal of 40 to 50 percent of commercial timber and
completion of the basic transportation system necessary to manage
the timber resource. Logging operations were halted for over 2
years of the 5-year period because of the Zieske vs. Butz suit.
Those two seasons of work are included with Alternative 4 in the
current environmental statement. Even without the delay caused by
the court injunction, it was not expected that the first entry
could be completed in 5 years.
Furbearer population levels are not likely to decline as a result
of the habitat alteration proposed by the preferred alternative.
Increased trapping pressure will have more effect on the distribution
of fur harvest among the total number of trappers than on the local
population of furbearers.
Casual observation of black bears on Prince of Wales Island over
the past 20 years indicates an increase of black bear populations
where old-growth timber has been clearcut. It is generally agreed
among biologists that clearcutting is beneficial to black bears so
long as the cutting units are kept reasonable in size and dispersed
over time.
This FES and the Forest Service comments on the State of Alaska's
response discuss the issue of completing the intraisland road
system.
We know of no archeologic resources in Labouchere Bay and have no
record of a "Cat in Pat's Creek." Traitor's River damage was held
to short-term sedimentation and mitigated of any long-term damage
by resculpturing the slide area to relieve water pressure and thus
any additional mass movement. Surface erosion was controlled by
diversion of surface water from the site and by mulching, fertiliz-
ing, and reseeding the site. Stream monitoring on Prince of Wales
Island includes:
*Bonnie Creek at Shaheen.
*Alpha Creek at Sweetwater Lake.
*Tye Creek in Staney Creek.
*3/10 Mile Creek in Staney Creek.
*Old Tom Creek at Skowl Arm
*Indian Creek near Hollis will be started again in spring 1979,
for a 3 to 4 period of years.
[0 Haw 77
149
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FOREST SERVICE COMMENTS ON THE
RESPONSE OF ELZIE ISLEY
ike The plan has been revised to harvest the blowdown you mention.
Jen Biologists all agree that large clearcuts in the wrong places hurt
the deer.
Sic Alternative 1 has a higher percentage of saltwater shoreline
cutting units than the other alternatives. Logging operations on
some of these units would disturb nearby marine mammals. The
effect while adverse would be minor and temporary.
Pe OL Box, E6010
Ketchikan, Alaska 99901
January 17, 1979
Department of Agriculture
U. S. Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Sirs:
Re: D.E.S. on LPK Timber Sale Plan for 1979-84
The E.I.S. has described timber harvesting as an adversary
to all other resources within the National Forest System.
Pressures to halt logging activity are placing the timber
resource into an unmanageable situation.
1 Relief must come through more reasonable "Operating Guide-
lines for Timber Sale Layout." These "Guidelines" are placing
restrictions and constraints on the logging activity to the
point of impossible compliance. I would suggest an LPK-
U.S.F.S. meeting to produce solutions to these problems instead
of waiting until our mutual field personnel are confronted
with impractical approaches.
Sal
If "trade-offs" and reasonable regulations are not utilized,
the long-term sale will be in a deficit appraisal situation.
This would be intolerable to all concerned.
The only other answer is addressed to on the top of page 61
of the E.I.S. This alludes to the use of congressional
appropriations for the rehabilitation of other forest
resources made necessary by timber harvesting. This is a
dangerous approach as it contradicts the philosophy of the
free enterprise system. The real costs are lost in the
bureaucratic process and actual commodity values are distorted.
It is apparent that in the process of compromising resource
values, timber harvesting always gives but never receives.
For example, on page 33 the E.I.S. states that under past
practices logging has not significantly affected the fisheries
resource, but then goes on to describe how more stringent
restrictions on logging practices are needed to protect fish
resources.
The results of the T.L.U.M.P. and RARE II process necessitates
a higher priority for timber resources on the multiple-use
lands remaining. This resource is the basis of the social
and economic stability of Ketchikan and therefore must main-
tain a higher consideration.
I will support Alternative 4 to the extent and with the
understanding it will meet the appraisal standards set up
under the long-term sale contract.
Sincerely,
Medi pibocen —
Lloyd A. Jones
je
cc: Mr. Don Finney
Mr. George Woodbury
Mr. Merle Mosar
FOREST SERVICE COMMENTS ON THE
RESPONSE OF LLOYD JONES
a See page 23 of the DES "Management Concerns" and page 24 of the
DES, ."Evaluation Criteria." Alternative 4 comes closest to meeting
these criteria and, although not the one most favored by LPK, it is
deemed to be the best alternative from an overall environmental,
economic, social, and legal standpoint.
2. Although research has not shown that logging has significantly
affected the fishery resource, it has not shown that it has not.
Until this issue can be satisfactorily resolved through reasearch,
the Forest Service has no choice but to maintain a conservative
approach. We also have a strong mandate from the fishing industry
and the State of Alaska to do this.
152
Rev, Lewis K. McClendon Director, Church Extension Missiv,.
Alma McClenJon Southeast Alaska
Pouch @ Coffman Cove
Ketchikan, Alaska 99901
December 23, 1978
United States Department of Agriculture
FOKEST SERVICE
Federal Building
Ketchikan, Alaska 99901 Ke: LPK Timber Sale plan 1979-84
Att: J.S. Watson, Forest Supervisor
Dear Mr. Watson:
As a citizen, and involved party, I would like to offer comments on the prop-
osed LPK Timber Sale Plan for 1979-84. My involvement is with the loggers and
their families living in the camps primarily on Prince of Wales Island.
I am Trustee in Trust for Trinity Baptist Church, Incorporated, of Ketchikan,
under whose sponsorship we operate Island Ministries. I live in the Valentine
Logging camp at Coffman Cove and operate from there. Our ministry includes
the use of the boat "Circuit Kider'' and we are looking toward the purchase of
a float plane early in 1979.
We are perhaps the only family living in a logging camp (other than those
connected with the school systems) which are not employed by the logging
industry. If all logging in Southeast Alaska should close tomorrow, it would
not effect my income in the least, but would only mean a transfer of operations.
Therefore I can speak with less bias than those who would be more severely
effected.
I wholly concur in the choice of the Forest Service, that Alternative 4 is
the best possible use of the resources with the least undesireable results.
We are all environmentalists, it is just a matter of degree. We are all also
opportunists, and that too, is a matter of degree. As in most things, there
is a middle ground of balance that is generally wisest as proven by history.
Alternative 2 is ridiculous. Even if other jobs were immediately available
and no economic upset were to occur, it would still be ridiculous!! I[Ifwould
be as if a corn farmer decided to Jeave his crop in the field another year....
or forever....so that people could see a fine stand of corn. Timber as a
national resource is a real issue and it is our responsibility to make the
best use of it.
Alternatives 3 and 5 seem not to make the best use of the resource, and the
choice of Alternative 1 would be unwise because it is based on short-term
economics.
We appreciate the efforts of the !orest Service in developing and using one
of our great natural resources. We have come to admire many of the men who
work in our area, and believe them all to be conscientious in their efforts
SOUTHERN BAPTIST HOME MISSION BOARD TONGASS BAPTIST ASSOCIATION
153
to reach a balance between preserve and resource.
It is our hope that Alternative 4 will be chosen as the Sale Plan. This will
lend stability to our people and to the area. The independent Loggers can
plan ahead and LPK can have their timber!
Thank ypu very much.
Most
"I 1g
Lewis Ke McClendon
Pouch L (Coffman Cove)
Ketchikan, Alaska 99901
Southeast Alaska Conservation Council, Inc.
BOX 2778
JUNEAU, ALASKA 99803 907-586-6942
CERTIFIED MAIL--RETURN RECEIPT REQUESTED
January 30, 1979 Sora KA
FEB 1 1979
i, es DS YL —=|
Forest Supervisor J.S. Watson a =
U.S. Forest Service TES = ——|
Ketchikan Area ee | —te
United States Department ep — ba
of Agriculture 5 a SEN CSE
Federal Building
Ketchikan, Alaska 99901
Re: Comments on LPK 1979 ~- 84 Timber Sale Plan
Draft Environmental Statement
Dear Supervisor Watson:
After careful review of the LPK Five Year Plan Draft
Environmental Statement (DEIS), the Southeast Alaska
Conservation Council (SEACC) has identified three major
areas of overriding concern. First and most important,
the preferred alternative (No. 4) proposes extensive
logging and roading within the boundaries of SEACC's
Sarkar Lake wilderness area, which encompasses VCUs 554.1
and 554.2. (See map of SEACC's proposed conservation
areas published by the U.S. Forest Service in March, 1978
as part of the TLMP planning process.) The Sarkar Lake
1 area has unusually high fish and wildlife values, as it
supports substantial runs of coho salmon, steelhead and
cutthroat trout, and comprises the most important trumpeter
swan wintering area in Southeast Alaska. The Alaska
Department of Fish and Game has identified Sarkar Lake
as one of the key waterfowl habitat areas on Prince of
Wales Island. The intricate network of interconnecting
lakes and streams in this area provide an excellent
opportunity for canoeing and sport fishing. The western
portion of this area, which would be roaded and logged
under Alternative 4,contains valuable estuarine habitat
for fish and waterfowl. Its numerous coves, inlets and
a large salt water lagoon interface with a gentle wilderness
of streams and lakes to the east and a beautiful network
of islands in El Capitan Passage to the west. This is the
only wilderness proposal on the west coast of Prince of
154
Wales Island, and offers a unique opportunity for water-
based primitive recreation. SEACC strongly urges the :
Forest Service to delete this area from its proposed logging
program.
Second, the preferred alternative proposes development
of approximately 105,000 acres of presently unroaded wilder-
ness. This proposal, which would dramatically reduce the
remaining unroaded acreage on Prince of Wales Island, appears
to be based primarily upon inaccurate assumptions concerning
the Forest Service's contractual obligation to LPK and the
level of harvest necessary to maintain economic stability.
At most, the 50 year contract only requires the Forest Service
to make available to LPK sufficient timber to permit its
Ketchikan pulp mill to produce 525 tons of pulp per day -
not 960 MMBF over the five year operating period, as stated
in the DEIS. Further, this obligation may be reduced by
other factors including LPK's recent history of importation
of 25% of the chips required for its pulp mill from Canada
and export of 20 MMBF of hemlock logs suitable for pulping
to Washington State. The DEIS should carefully and objectively
reevaluate these assumptions in light of these and other
related facts. The fact that the fifty year contract does
not require the entire contract volume to be harvested within
the primary sale area should be disclosed, and additional
roaded areas outside the primary sale area should be con-
sidered as a reasonable alternative to unroaded areas proposed
for logging. The DEIS should also disclose that the Forest
Service has broad discretion under Section 1(f) of the fifty
year contract to "reserve from cutting strips and blocks of
timber having special scenic value ... or ... which cannot be
logged without causing substantial harm to salmon streams or
lakes." Also, the DEIS should disclose what economic costs
would be involved in the event the Forest Service made available
a volume of timber sufficient for operation of LPK's pulp mill,
but less than LPK's full entitlement under the fifty year
contract. Since LPK has had more than twenty years to recover
its investment in the pulp mill, and the profitability of its
pulp operation is marginal, the damages to which the Forest
Service might be exposed may be relatively insignificant.
Similarly, the DEIS fails to set forth facts in support
of its assumption that 960 MMBF must be made available to LPK
in order to maintain economic stability. Harvest levels in
the Ketchikan Area during the last five years have averaged
only 250 MMBF per year, and there presently exists a back-
log of 167 MMBF of timber at LPK's pulp mill. The commence-
ment of large scale timber operations on native lands, such as
the 80 MMBF timber sale proposed for 1979 on land owned by
the Cape Fox Corporation near Ketchikan, will undoubtedly
substantially reduce the local timber industry's dependence
upon harvest by LPK within its primary sale area.
Third, the DEIS is based on the shaky premise that 1) all
timber harvest activities will conform to adopted guidelines,
and 2) if these guidelines are followed then impacts on fish
will be "either nonexistent or minimized to an acceptable
level". (DEIS at page 33.) The numerous reasons why SEACC
is unwilling to accept this assumption as valid are addressed
in our detailed comments which follow.
1) The DEIS should disclose specifically what revisions
in the fifty year contract will be made to achieve conformance
with the requirements of the National Forest Management Act
of 1976. The explanation concerning this matter at page 2
155
of the DEIS is not only vague, but confusing in that it states
that revisions will be made but the harvest unit selection
process for the 1979 - 84 operating period will not be altered.
Furthermore, the DEIS incorrectly states that the Forest Service
must make available 8,250 MMBF timber under the fifty year
contract; as indicated above, the contract requires this
amount to be made available only in the event that the Forest
Service fails to provide LPK with timber sufficient for full
operation of its pulp mill.
2) The DEIS at page 14 states that "alternatives have
been developed to satisfy contractual volumes for the 1979 -
84 operating period without entering [the Sarkar Lake area,
among others]." This is incorrect, as noted above.
3) Although the DEIS acknowledges that recovery of
windthrow should be one of the goals of its harvesting program,
it fails to disclose whether, and if so, how, the large amount
of blowdown from last fall's storm (which has been estimated
in the press at approximately 100 MMBF in the Ketchikan Area)
will be harvested during the 1979 - 84 operating period.
Obviously, utilization of this source of timber would substan-
tially reduce the need (which the DEIS claims exists) to log
unroaded areas. It would also reduce the pressure to log
those roaded areas with particularly sensitive visual or
habitat values (e.g., along beach areas or adjacent to salmon
spawning streams). Although some of the blowdown may be within
unroaded areas, undoubtedly a substantial portion is located
within roaded areas (although perhaps not within LPK's primary
sale area) not possessing valuable scenic or habitat qualities.
Unfortunately, SEACC and members ofthe public can only speculate
concerning this matter, because the DEIS sets forth no facts
concerning the location and amount of blowdown, and describing
what action, if any, will be undertaken to recover this valuable
timber resource which would otherwise be lost. Inexplicably,
the DEIS description of the five Alternatives mentions salvage
of blowdown only in connection with Alternative 4. In the
absence of a factual explanation for this anomaly, it appears
objectivity in designing and evaluating the Alternatives may
be lacking. This conclusion is reinforced by the fact that
Alternative 5 (which SEACC prefers to Alternative 4, the
Forest Service selection) is defined to be identical with
Alternative 4 (except it contains no roadlessareas) .
4) The statement at page 29 of the DEIS that the impact
of logging-induced surface erosion on streams will be "short
in duration" is not supported by specific reference to studies
which come to this conclusion, and is at odds with the widespread
loss of natural salmon productivity in streams in California,
Oregon, and British Columbia due to erosion from logging and
other developments. No facts are set forth which substantiate
claims made in the Fishery Specialist's Report that the State
water quality requirement for turbidity (25 NTU above
natural conditions for fresh water) will not be violated
as required by Area Guide Policy #6. The DEIS should disclose
historical data indicating logging near streams can cause
turbid conditions greatly exceeding State water quality
standards.
5) The statement at page 30 of the DEIS that "Southeast
Alaska streams are not considered to be highly sensitive to
temperature changes resulting from timber harvest" is not
supported by specific reference to data or studies. The DEIS
fails to disclose studies which indicate contrariwise. Simi-
larly, the statement that "temporary changes in water quality
156
ae
can be expected from timber harvesting [b]ut all anticipated
changes can be reduced to acceptable levels and returned to
natural levels" is not supported by the studies of the affects
of logging on water quality performed to date. These vague
assurances appear to be designed to allay fears and sweep
the troublesome problem of long-term adverse impacts of logging
on water quality, under the rug.
6) The apparent bias in favor of Alternative 4 reappears
with the statement at page 32 that Alternatives 3, 4, and 5
"would affect water quality in similar ways", even though
Alternative 5 would, according to the Fisheries Specialist's
Report, affect substantially fewer miles of water courses
adjacent to harvest units and associated culverts and bridges
than would Alternatives 3 or 4.
7) The DEIS concludes at page 33 that "research has
not shown that timber harvesting as conducted in Southeast
Alaska significantly affects fisheries resources on a long-
term basis." This is misleading in that it implies that research
has shown that timber harvesting does not significantly affect
fishery resources on a long-term basis (which would be incorrect),
and further, is contrary to recent studies. In particular, the
"review of literature" at pages 10 - 12 of the Fisheries
Specialist's Report inaccurately describes the findings of
several of the studies noted, including those of Meehan, Farr
and Bishop (1969) and Myren (1976). Infact, these reports
provide no basis for the conclusion that timber harvesting
will not significantly adversely impact fisheries resources.
The hazy assurance that impacts on fish will be "minimized
to an acceptable level" is obviously intended to soothe and
to lull the reader, rather than apprise him of the potential
adverse consequences of the proposal, contrary to the purpose
of the National Environmental Policy Act. Further, the DEIS
implies that all forest development activities will conform
to the Southeast Alaska Area Guide prescriptions concerning fish
habitat. In fact, however, these prescriptions have been
violated frequently in the past, and will probably continue
to be violated in the future. For example, Area Guide Policy
#6 requires that an interdisciplinary team (IDT) will
provide "sufficient information to permit allocations
which recognize the capabilities and sensitivities of major
fish habitat areas", yet the Fisheries Specialist's Report
at pages 7, 9 and 14 admits adequate data sufficient to
achieve this objection does not yet exist. Area Guide Policy
#7b(5) requires identification of temperature-sensitive
streams prior to timber harvest, yet the Fisheries Specialist's
Report acknowledges that "with the level of information available
through maps, aerial photographs, and basic ground reconnais-
sance, the existence of many smaller streams, especially rearing
streams, is unknown. The location and quantity of streams
shown on maps and aerial photographs compared with what actually
exists on the ground is approximately 60% accurate." Further,
the DEIS fails to disclose that temperature sensitive streams
cannot be identified simply by reviewing aerial photographs
and topographic maps, because depth, surface area, velocity,
sources and opacity - all essential to a determination of the
temperature sensitivity of any given stream - can only be
measured through extensive field survey. The DEIS fails to
refer the reader to studies which underscore the importance
of this detailed field reconnaissance. Other recent studies
not cited by the Forest Service in the DEIS or its subsidiary
reports point out the importance of detailed field survey
work to permit evaluation of the fishery habitat potential
and vulnerability to erosion of streams before logging plans
are designed.
157
disclose and discuss studies which show that sedimentation
clogs and abrades gills, causes bacterial gill disease,
smothers eggs and alevins, reduces dissolved oxygen, and
induces behaviorial changes such as avoidance of spawning
beds. Furthermore, there is no scientific basis for the
DEIS's conclusion at page 34 that "application of the [operating]
guidelines [will] keep temperature changes within acceptable
limits and return them to natural levels within 10 - 15 years
after logging." Studies indicating otherwise should be dis-
closed.
9) The DEIS states blandly that "in the estuary loss
of habitat results from rock fills for construction of log
transfer points", but fails to disclose specifically how much
habitat will be lost under each of the proposed Alternatives,
and fails to relate the estuarine habitat guidelines to this
problem on a site-specific basis. The DEIS also neglects to
discuss the results of surveys which have been conducted by
the U.S. Fish and Wildlife Service in log storage areas in
Southeast Alaska, which indicate among other things that the
leaching of tannic acid from logs stored in salt water sub-
stantially reduces species diversity. This impact should
be frankly disclosed, and reasonable alternatives to salt
water storage, such as dry barging,should be addressed.
8) The DEIS fails to acknowledge the extreme toxicity
of sedimentation to anadromous fish. The DEIS should frankly
10) At page 36, the DEIS implies that there will be no
long-term or cumulative impact on temperature sensitive
streams if any Alternative other than Alternative 1 were
chosen, but presents no data to support this conclusion. The
effect of this statement is to lump Alternatives 3, 4, and 5
together in terms of their adverse impact on streams, con-
trary to Tables 2 - 5 in the Fisheries Specialist's Report.
11) The charts set forth at pages 40 - 41 of the DEIS
do not include information for Alternative 5, apparently
because the DEIS concludes Alternative 5 will have the same
impact on wildlife as Alternative 4. This is not credible,
in view of the fact Alternative 4 involves the logging of
105,000 acres of roadless areas which would remain untouched
under Alternative 5. Table 8 at page 42, because of its
grossly simplistic and limited evaluation scheme, does not
reflect accurately the impact of the various Alternatives
on species of wildlife. Again, it appears the authors of the
DEIS contrived to lump Alternatives 3, 4, and 5 together in
the reader's mind, even though we know from the differences
in size and location of clearcuts that Alternative 5 must have
much less adverse impact on wildlifethan either 3 or 4.
12) The DEIS does not disclose how the Forest Service
has determined that a 100 year rotation period insures that
trees shall generally have reached the culmination of mean
annual increment of growth prior to the second harvest cycle.
The manner in which the Forest Service interprets and applies
this requirement will significantly affect the amount of
timber which can be logged annually on a sustained yield basis.
13) The DEIS concludes that Alternatives 3 and 5 would
reduce the number of timber and support jobs by 900 - 3,000
jobs during the five year period, at pages 47 and 59. The
factual basis for this conclusion should be disclosed so that
readers can draw their own conclusions based on the under-
lying facts. As indicated above, facts available to SEACC
(e.g., average harvest levels during the last five years;
LPK's importation of pulp chips from Canada in recent years;
158
LPK's inventory of 167 MMBF presently in water storage;
substantial timber harvesting on native lands expected in the
near future; and large amounts of blowdown timber presently
available for harvest) indicate that neither Alternative 3
nor Alternative 5 would result in a loss of jobs in the
Ketchikan Area. By jumping to the conclusion that Alternatives
3 and 5 will result in economic dislocation, the DEIS effectively
eliminates these Alternatives from further consideration in
many readers' minds. Through the application of its "evaluation
criteria", and in combination with unsupported conclusions
respecting "economic viability" and the timber volume require-
ment of the fifty year contract, the Forest Service's assump-
tions concerning economic stability predetermine which
Alternative will be selected as "preferred". (DEIS at Table
12, page 59). Furthermore, implicit in the Forest Service's
analysis of socio-economic impacts is its assumption that
logging will have no adverse impact on the fishing industry
and the recreation industry; indeed, the only discussion of
recreation in this regard is to the effect that clearcutting
and its associated road construction increases recreation
opportunities.
14) The DEIS at page 51 states that clearcutting only
"slightly" detracts from semi-primitive recreation, a con-
clusion devoid of any visible means of support. The two
Tables on this page fail to evaluate the severity of the
impacts ofthe various Alternatives on areas highly valued
for dispursed primitive and semi-primitive recreation. The
simple dichotomy between impacts and the absence of impacts
which is displayed may be misleading.
15) The DEIS at page 52 incorrectly states that Alter-
native 4 would preserve the "wilderness option" in the Sarkar
Lake area. As indicated aboye, one of the two yCUs encompassed
within SEACC's Sarkar Lake proposal is destined for logging
under Alternative 4.
16) The DEIS concludes that Alternatives 2S) amanda >
would all meet "Area Guide policies ... for management of the
visual resource". In fact, Alternative 4 does not, according
to statements set forth on page 54.
17) The DEIS at page 56 understates the impact of noises
associated with logging and road construction on wilderness
recreation use of adjacent areas.
18) The DEIS at page 57 incorrectly states that Alternatives
3 and 5 would require "about 50% more mileage than Alternative
4". The discrepancy between this statement and the figures
set forth at page 19 of the Fisheries Specialist's Report (indi-
cating Alternatives 3, 4 and 5 with 245, 235 and 205 miles of
road respectively) should be explained.
19) The DEIS at page 58 states that Alternative 5 would
fail to provide for the completion of first-entry harvesting
during operations within this five year period. Since Alter-
native 5 is identical with Alternative 4 except it does not
include roadless areas, this statement assumes that these
roadless areas will eventually be entered. If this is truly
the plan of the Forest Service, then it may as well confess
this intention now, so that the public won't be misled into
wasting any more time asking the Forest Service to protect these areas .
20) Table 12 at page 59, which purports to objectively
evaluate the five Alternatives based on stated criteria,
has numerous defects. In addition to the erroneous assumption
160
10
concerning the harvest level necessary to maintain economic
stability noted above, this Table also erroneously assumes
that the fifty year contract requires the Forest Service to
make available 960 MM bm from the primary sale area and that
Alternative 4 is much more "economically viable" than
Alternatives 3 or 5. As explained above, the contract
only requires the Forest Service to make available that
amount of timber necessary to keep LPK's pulp mill in full
operation, and that timber outside the primary sale area
may be used for this purpose. With respect to the latter
assumption, it is apparent that all three of these Alternatives
are economically "viable", since "2 MM bm per mile of system
road will generally result in a positive dollar return",
according to the DEIS at page 57. According to the road
system mileages set forth in the Fisheries Specialist's Report,
Alternatives 3, 4 and 5 will provide harvestsof 3.24, 4.08
and 3.33 MM bm per mile, respectively. Since all are "viable",
it seems inappropriate for the Forest Service to concern itself
with how much profit above and beyond that necessary for main-
tenance of LPK's timber operation will be derived from each
of the Alternatives. The direct result of this approach is
to consider corporate profits distributed to shareholders on
a basis equal with such public policy considerations as pro-
tection of fish and wildlife. Further, Table 12 posits as
an objective, the construction of an intra-island road system.
Road building for its own sake (as opposed to road building
for recreational purposes, which would be included in evaluation
criteria #8(a)) is not a statutorily sanctioned function of
the Forest Service. Therefore, it should be dropped from
Table 12. If the foregoing erroneous assumptions are elimi-
nated from this Table, Alternative 4 loses its "preferred"
status. Furthermore, Alternative 4 should not be awarded a
"9" for wilderness protection because unlike Alternatives 3
and 5, it proposes logging and roading of SEACC's Sarkar Lake
conservation area.
21) The DEIS inappropriately sets forth at pages 61 - 62
uninformed public opinion it received in response to a four
page advertisement published in an obscure monthly newspaper in
June 1978. The purpose of the environmental impact statement
process is to educate the public and the decision makers, not to
enshrine opinions formed prior to review of environmental
impact statement documents.
22) In its discussion of the relationship between the
various Alternatives and employment levels in the timber
industry, the DEIS fails to explain the impact of recent
Forest Service decisions to permit LPK to export raw logs
to the Pacific Northwest for processing, apparently reducing
employment levels in the Tongass National Forest.
23) The DEIS affords inadequate consideration to the
economic value of recreation, tourism, guiding and wilderness
activities. The number of people who participate in these
activities within Southeast Alaska is not disclosed. For
example, the DEIS fails to consider the economic value of
the fishery resource to thousands of licensed commercial
fishermen who are not full-time employees in that fishing
industry. Moreover, the DEIS fails to disclose the possi-
bility (or likelihood) that logging may adversely impact the
commercial fishing industry.
24) The DEIS should show on a map which VCU's with high
or moderate rating for wilderness, primitive recreation, or
wildlife, will be roaded or logged under each Alternative to
permit informed comparisons between these proposals.
161
25) The DEIS should consider specific revisions to
the LPK fifty year timber sale contract, in order to insure com-
pliance with the resource inventorying, land use planning and
habitat protection requirements of the National Forest
Mangement Act. As noted above, the DEIS implies some revi-
sions will be made, but fails to either identify them or explain
when they will be implemented.
26) The DEIS fails to acknowledge and explain the impact
of apparent monopolistic or collusive timber sale bidding
practices which have been the subject of correspondence between
Dr. Matthew Berman and Regional Forester John A. Sandor. The
DEIS should explain what action will be taken to obviate these
practices, and the effect, if any, of such action on wasteful
logging practices.
27) The DEIS fails to explain what efforts will be under-
taken by the Forest Service to prevent logging and roading
where soil, slope, habitat or watershed conditions would be
irreversibly damaged, where the forest lands could not be
adequately restocked within five years, or where protection
could not be provided to nearby bodies of water. The DEIS
should set forth specifically what measures will be undertaken
to provide this required environmental protection in each of
the Alternative proposals, and how implementation of these
measures will be monitored to assure achievement of this
objective. Mere reference to the Area Guide's general policy
strictures is insufficient. The public is entitled to know
how the Forest Service proposes to acquire the detailed know-
ledge respecting fish and wildlife habitat and visual sensi-
tivity, and the impacts of the proposed Alternatives thereon,
prior to implementation of the selected Alternative, in order
to be assured that the Forest Service will implement such
strictures. As noted above, data respecting fish habitat
in particular is lacking.
28) The DEIS fails to consider whether current "sustained
yield" forestry practices will result in the permanent loss
of the climax forest in areas subject to logging. For example,
the long-term effect of this impact on the fishery resource
and habitat for mammals and birds has not yet been determined,
because of insufficient data. The DEIS should forthrightly
acknowledge this problem and endeavor to remedy it aS soon as
possible. Further, the DEIS should disclose how many acres
will be logged over the entire rotation period, not just
during the next five years, under alternative levels of harvest
(e.g., 500, 600, 700, 800, 900 and 1,000 MM bm/5 years). This
is important because the acreage cut each year will increase
as logging moves into areas with less timber volume per acre.
The DEIS should disclose whether this will reduce the economic
feasibility of logging, and increase adverse environmental
impactsas the end of the rotation period is approached.
29) The DEIS should address current wasteful scaling
and transportation practices of the timber industry, and
evaluate the economic and environmental benefitsof changing
these practices. For example, rafting rather than dry-barging
logs to mills results in unnecessary loss of timber in transit,
as well as adverse impacts on marine life.
30) The DEIS fails to propose and evaluate measures to
restore and rehabilitate renewable resources which have been
damaged by past forestry practices in the Tongass National
FOGeSiE-
162
31) The DEIS should set forth the goals of the Tongass
Land Management Plan (as proposed in its DEIS), including
standards designed to maintain fish and wildlife populations
and esthetic and recreational resources, and describe how
well each of the proposed Alternatives will implement these
objectives.
32) The Operating Guidelines set forth in Appendix B
of the DEIS have not been shown to provide adequate protection
of resource values harmed by logging and roading. Until
adequate data is collected and studies based thereon establish
a sound underpinning for logging prescriptions, only conser-
vative logging practices should be allowed. For example,
leave strips should be required along streams and lakes. We
know from recent studies that the old growth forest supplies
nutrients, humidity and habitat for organisms on which fish
feed, moderates extreme temperatures, regulates waterflow
(absorbing excess runoff during rainfall and slowly dispensing
runoff during droughts) and prevents erosion and consequent
siltation ofstreams. Even small tributary streams need the
protection of the old growth forest, because they provide
habitat for overwintering coho salmon and dolly varden char.
33) The Forest Service should disclose whether it has
revised downward its official estimate of operable timber
within the Tongass National Forest since estimates were
originally made in the 1950s. If these estimates have been
substantially revised, the public is entitled to know why
the original estimates were inaccurate, in order to evaluate
current Forest Service timber inventorying practices for
similar methodological errors. If the Tongass National
Forest has been "high-graded" during the last twenty years,
the public is entitled to know why this has been permitted
to happen and what effect these practices, if continued, will
have on the methods by which the sustained yield goal will
be achieved in future years when logging moves into low
volume stands previously by-passed. The Forest Service
should establish a monitoring system which will permit the
public to determine precisely whether sustained yield policies
are being followed. The DEIS should describe the visual and
ecological changes which will take place in the Ketchikan Area
during the proposed 100 year rotation cycle under various
harvest levels, so that the public can grasp the enormity of
the ultimate changes now underway incrementally, to permit
informed comparison between these harvest levels.
34) The DEIS should consider all reasonable alternatives
to the clearcutting method of logging, in order to minimize
adverse impacts on wildlife and fishery habitat, and on visual
amenities. The DEIS should evaluate these alternatives, and
propose clearcutting only if the environmental, biological
and esthetic impacts have been assessed and found acceptable.
The DEIS should set forth specific standards to insure clear-
cuts, if they are to be allowed, will be shaped and blended
with the natural terrain to achieve esthetic and wildlife
habitat objectives.
35) The DEIS fails to disclose whether, and if so, how,
the Revised Area Guide to be published in final form in March,
1979 will be implemented through the proposed 1979 - 84 LPK
plan. For example, the DEIS makes no mention of the filter
strip requirement set forth at Table 1, page 4 of the current
Draft of the Revised Area Guide. Since SEACC has been advo-
cating buffer strips along streams for several years, it is
most concerned that this proposal be incorporated within LPK's
five year operating plan. The DEIS should also disclose whether
163
12
13
any policies set forth in the original Area Guide will be
modified in the revised edition. Deletion of the Area Guide's
requirement that "sufficient information" be gathered to insure
protection of fish habitat areas, for example, would under-
mine assurances contained in the DEIS that the fishery
resource would not be adversely impacted.
36) The DEIS makes much of its announced goal of providing
the inhabitants of Prince of Wales Island with an "intra-
island transportation system", but neglects to disclose the
construction and long-term maintenance costs associated with
this proposal. Further, the DEIS fails to set forth any facts
which support its assumption that residents of Prince of Wales
Island are in favor of this proposal; on the contrary, the
only information provided in this regard is that residents
of Point Baker and Point Protection are opposed to this pro-
posal. The "communities" which would be connected by these
new roads, Naukati Bay, Laboucher Bay, Whale Pass and
Coffman Cove, are all just temporary logging camps; it seems
illogical to propose a permanent road network to serve a tran-
sient population. In summary, if the Forest Service is going
to embark upon road building as an avocation, since taxpayer
dollars are involved the fuli, long-term costs and benefits
of this endeavor should be fully disclosed and evaluated in
the DEIS. Moreover, no roads should be proposed until a
comprehensive transportation plan has been presented to the
public for its consideration through public hearings.
37) The DEIS's use of "economic stability" as a criterion
with which to evaluate the various Alternatives is, as noted
above, based on erroneous assumptions. Certainly, economic
stability must be considered by the Forest Service in evaluating
the Alternatives, but this criterion should incorporate the
following factors: 1) the need for economic diversification
within Ketchikan; 2) market projections for forest products
from national forest and private lands in the Ketchikan Area;
3) other industry sectors, such as tourism, fishing and the
government, which may impact economic stability in Ketchikan;
4) the number of direct and indirect jobs which will be created
by the harvest of timber on private and native lands during the
next five years; 5) the continued importation of wood chips
from Canada for use in Ketchikan'spulp mill; 6) the export of
round logs from National Forest lands in the Ketchikan Area;
and 7) LPK's current surplus inventory of logs. In addition,
more general economic questions have been ignored. The DEIS
should include an analysis of the following factors: 1) the
total economic costs of the proposed five year timber sale
under each Alternative, including the cost of layout and
design, fish and wildlife research and management, related
soils, cultural and environmental research, related land use
planning and administrative costs; 2) the projected revenues
of the five year sale under each Alternative
including revenues to the National Forest Fund, purchaser road
credits,K.V.revenues, and revenues to be paid to the State of
Alaska and local communities; 3) a comparison of management
costs, stumpage prices and projected revenues for alternative
harvest levels within the Ketchikan Area, with other national
forest and private timber lands.
38) The DEIS should indicate where cutting units in excess
of 160 acres are proposed to be located under each of the
Alternatives.
39) The DEIS should consider the possibility that all
timber made available to LPK may not be harvested within the
164
next five years, and consider whether those areas with the
highest visual, wilderness and habitat values should be
segregated so that all other areas are roaded and logged
Firsts
40) The DEIS should disclose how much timber has been
harvested on Prince of Wales Island since major timber operations
15 were commenced in the early 1950s and display this information
on a map indicating the location of past harvesting. Based on
this information, the DEIS should determine what level of
annual timber harvest will insure a sustained yield of timber
over the rotation cycle of the forest, providing, of course,
protection of those values identified in TLMP and by Congress.
The public is entitled to know now whether there is in fact
insufficient timber to maintain the industry at its current
level through the rotation cycle.
41) The DEIS should disclose that in the recent past Area
Guide prescriptions have not been followed. For example,
severe road slides occurred at Traitor River and Shaheen Creek.
42) The DEIS fails to disclose how the proposed LPK five
year plan will interface with Alaska's Coastal Zone Management
Program, and local plans promulgated thereunder.
43) The DEIS discussion of impacts on wildlife leaves
the impression that if 50% of the timber in a particular area
is harvested, for example, 100% of the wildlife in that area
will continue to exist. The DEIS should frankly disclose the
adverse impacts on wildlife population which historical data
and studies have found result from clearcut logging.
44) The DEIS does not adequately and accurately disclose
the impacts on archaeological resources which will result from
the various logging Alternatives. This is principally because
the Forest Service lacks an adequate data base. The DEIS should
acknowledge this fact and propos: measures to insure conformance
with the requirements of the Historic Preservation Act of 1966.
45) The DEIS should provide a detaiied description of
its proposed water monitoring program so that the public can
determine whether or not Alaska water quality standards will
be maintained.
Thank you for providing this opportunity to comment.
Very truly yours,
es
Leonard S. Steinberg
Acting Executive Dir or
Southeast Alaska Conservation
Counes 1; ine:
Las /ks
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE SOUTHEAST ALASKA CONSERVATION COUNCIL
1. There are no cutting units or roads proposed in Alternative 4
within value comparison unit (VCU) #554.1K. This VCU contains
23,568 acres and covers 81 percent of the Sarkar Lakes watershed.
165
There is in existence, now, a main haul road from Naukati north
through VCU #554.2K. This road has a permanent bridge across
Sarkar Rapids that was constructed last year. This road and the
cutting units it serve, was authorized in the 1974-79 environmental
statement. The road itself will be completed past the northern
boundary of VCU #554.2K before July 1979. The cutting units were
displayed on the Alternative 4 map, because, even though previously
authorized, they won't be logged until after July 1979, the start
of the next 5-year period. These units are located away from the
view area of the lake system and only a few acres of the units are
within the Sarkar watershed. None of the units impinge upon an
estuary, and no roadless areas are affected.
The road connection through VCU #554.2K is an important one to the
management of national forest resources, in that it ties operations
on the northern and central portions of Prince of Wales Island
together. It also offers good access to recreational use of the
Sarkar Lake system.
Section la of the contract allows operations to move from the
primary sale only if there is insufficient volume for full-scale
operation of the purchaser's pulp plant at 525 tons capacity per
day. Either Alternative 1 or 4 establishes the fact that sufficient
volume is obtainable on the primary sale allotment. Moving from
the primary sale area to avoid entering roadless areas within the
primary sale allotment would mean either displacing timber sales to
other purchasers or entering roadless areas in other parts of the
forest. Neither of those choices is acceptable. Although 105,000
acres seems a large area, nowhere near that amount of forest land
will be cut. The 105,000-acre area loses its roadless characteristic
because, after logging, no portion of the 105,000 acres will remain
in contiguous unroaded blocks of 5,000 acres or more. It should
also be noted that the 105,000 acres is not in a single contiguous
block now. An examination of the map for Alternative 4 reveals the
extent of entry into roadless areas. The area of conflict is the
overlap between gray shaded area (roadiess) and the orange symbols.
There are large areas of gray shading in which no development is
planned for the 1979-84 period.
It is obvious that SEACC interprets the obligations of the United
States under this contract differently than does the Forest Service's
Counsel. The contract requires the purchaser to build and operate
a pulp mill of 525-ton-per-day capacity in order to meet a basic
objective of this timber sale; namely, to provide a stable economic
base in the Ketchikan Area.
The contract is worded in such a way that only three-fourths of the
total processing capacity is required to come from the long-term
sale. There is no prohibition of the import of chips from Canada.
Refer to Section 3b of the contract printed in the Appendix.
The contract amount for the 50-year sale is 1,500,000,000 cubic
feet (8,250,000 M boardfeet) measure. The purchaser, under provision
3c, must cut between a minimum 5,000,000 cubic feet (27,000,000
boardfeet) measure, and a maximum 35,000,000 cubic feet (192,000,000
boardfeet) measure on an annual average basis. If the purchaser is
to obtain the 1,500,000,000 cubic feet measure originally contrac-—
ted, the cut must be at a level near 35,000,000 cubic feet measure
each year for the rest of the sale period. The mathematical average
to obtain this result is slightly less than the maximum allowed in
the contract.
As of January 31, 1979, 3,632,062,000 boardfeet measure (bm) had
been scaled toward the 8,250,000,000 bm sold in the long-term sale.
Assuming 68,000,000 bm more will be scaled before July 1, 1979,
166
10.
then the purchaser will have to log an average of 910 MM bm each 5
years to the end of the sale (7/1/2004) in order to reach the sold
volume.
Although the Regional Forester has authority to substitute areas
selected by the company, there is no authority for that officer to
deny the company less volume than they request so long as they do
not request more than the maximum allowed in 3c or the total sale
volume.
Pages 3-14 of the SEACC letter deal mostly with the validity of
Forest Service policies, practices, research interpretations, and
land allocations in general. These issues have already been
addressed in the "Southeast Alaska Area Guide," "Tongass Land
Management Plan," and related documents, and, as such, they are not
considered within the scope of this environmental statement. The
Forest Service has therefore responded only to the comments consi-
dered substantive to this environmental statement.
The contract provisions which will be changed have not been completed
and thus, are not available in their final form. The changes will
comply with the NFMA and take effect at the beginning of the 1979-
84 operating period.
Major revisions have been made in the FES to salvage the November
1978 blowdown which occurred too late to incorporate into the
draft. See "Timber" in the FES.
It is true that all streams cannot be identified through a photo-
graphic layout. However, prior to release of a unit for harvest,
the unit is assessed on the ground by the Forest Service. Any
streams missed in the initial plan are identified and protected.
The Forest Service acknowledges that there have been isolated
contract violations and accidental damage to fish habitats, but
overall this has been minor.
The forest used the "Tongass Management Plan'' DES as a source for
determining jobs relative to timber harvest.
Citing a visual impact does not mean that Area Guide policy would
not be met.
The "50 percent more mileage" displayed on page 57 in the draft was
an error that has been corrected in this FES.
During preparation of this plan, the Forest Service objective was
to leave as much roadless area as possible to allow more options in
TLMP. The TLMP is scheduled for release before this FES and will
display how all the land will be allocated.
The transportation section has been rewritten to better explain the
Forest Service rationale for the roads. Also, see the comments on
the State of Alaska response.
The revisions have not yet been finally determined.
See the comments on the State of Alaska response (No. 5).
This has been done in the FES.
See the comments on the State of Alaska response (No. 9).
See the comments on the State of Alaska response (No. 10).
167
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Area Supervisor
Wisissale 34
Ketchikan, Aiaska
Dear Mr. “atson:
On behalf of the Tongass Conservation Society I wish to make the following
comments regarding the LPK proposed 5 year plan for 1979-1984.
First, I would like to deal with several specific concerns. Soils have
sufferec under U.%.F.S. management in the past. Recently t»o catastro-
phic slides occurred at Traitors River and Shaheen Creek. Both resulted
from inadequate attention being paid to the Area Guide regulations.
More roads, as proposed, will further aggravate unstable conditions,
contributing to more widespread erosion, siltation of rivers/streams,
further decline in our progressively declining viable salmon spawning
streams, and degradation of our saltwater environment, with consequent
decline in benthic/oquatic ecosystems. This is not acceptable. Both
the ater Suslity Act cnd Coastal Zone Monagement regulations must be
complied vith, and if not yet in effect their major thrusts are certainly
public information. Both Alternative 3 and Alternative 5 mean fewer
road building projects, and, therefore, less erosion and stream
destruction. It is simply not acceptable to stote that streams fale lak
eventually recover, that the potential long term effect will be a
"temporary chunge in streams and estuarine hobitot productivity”.
All Fisheries Habitat Mancgement Units must be identified and remain
undisturbed.
AS you are avare, ours is an unprecictable climate, certainly one in
which the selmon is especially susceptiole. Variables such as temp.
fluctuation, jravel beds cnd spawning habitat, siltation, culverts,
log rafts, and physical barriers such as log obstructions, all have the
potential to eliminate spawning. Jhould these factors exist, those
streams shoulda not be logged.
The heavy humen activity impact and lecching potential of rafting
facilities are proven detrimentol to the estuarine population. As
Alternative 5 has the least such sites'p.36), this alternative is the
better on Alte Ss 5.
Page 37 would seem to indicate that all wilulife will survive, which is
certainiy inaccurate. Projected wilclife losses must be disclosed.
Road building cannot be a primary evaluation criterion in assessing the
volume for each 5 year plan, insofor as it was not a criterion in the
Original contract, nor does it fall under Area Guide recommendations.
It appears that the proposed road from “ev Bay to El Capitan is un-
warranted=-=no cuts are planned, it is unroaced, and would appear to be
very expensive. Additionally, the Point Baker Associotion has expressed
a desire to leave -oint Baker unconnectec to the inter-island road
system.
Both Salmon Bay and Sarkar Lakes remain the only unroaded areas on north
Prince of iales. Soth are Tongass Conservation Society proposals for
conservation units. These must remain unroaded.
U.S.F.S. figures for the past five years indicate a progressive decrease
in the annual cut, «ith the excep tion of bumper year 1974. This, plus
several other factors, demand a closer look at the realities of maintain-
ing a 960mnof figure for the next five year period.
.e are avare of a massive blowdown on Prince of ales sustained in the
November,1978 storm. Many estimate 100mmbf fo available timber. The
projected cuts should reflect this volume.
168
Is it not also true that there is a large volume of residual timber from
g the 1974-1979 sale which should be included in the final volume figure?
Please notify us what this figure totals.
It is felt by many that stumpage fees for the upcoming 5 year period
9 will be even less than for the past five years, and that federal subsidies
Will be even further expanded, ‘lease comment on this.
Is it not true that there is mo contractual obligation to adhere to the
960imnmbf figure, Since other metnods are used in cumputing the required
volume? Is not one mettiod of computation of this figure the maximum
capacity of the miil in Ketchikan? If so, this must surely alter the
volumn figure considerably.
10
There is little mention of current t{n-the-vater inventories. How does
Tl the U.o.F.5. wish to treat this large volume of timber? And what plans
are being made to salvage ull of this timber before it rots should the
mill not reopen in the near future?
Please clurify to «hat extent a new contract will insist upon utilizing
marginal anu special stends of timber, and what portion of the total
these vill comprize.
I havé seen no inention of sizable chip imports from Canada. They
certainly moke up a sizable percentage of the LPK volume, but yet no
aS orcess on is mode for them in the totcl estimated cut.
Moreover, I find no reference to the anticijated volume from native and
Wstate logging activities. lease describe how you have dealt with these
in arriving at the 360mmbf fiyjure.
Recently the Ketchikan press has printed cetuiled accounts of attempts
by LPK to by-pass Forest Service regulctions and proceed with round log
exports to mills in the Lower 43. Is this net a clear violation of
your own regulations and the original 50 year contract terms? If this
does in fact indicate that there is the same surplus «hich Mr. Mosar
of LPK referred to, then why is this not reflected in yet a further
reduction in the requesteu volume?
15
And finally, I wish to know why there is such a sive ciscrepancy
between the employment figures the U.».F.5. uses for Southeast Alaska
Wand figures obtained from other sources. ‘why do you regard logging
jobs as "full time" jobs, but yet fisheries-related employment os only
three-month positions? ‘curely this is not a kosher glimpse of our real
employment picture.
I am therefore led to the conclusion that, for fisheries and wildlife
protection, for maintenance of a realistic timber employment anc economy,
for protection of the environment, and for the proper stewardship of
the entire forest, the 960mmbf figure is clearly excessive. I therefore
urge adoption of Alternative 5, along with strict adherence to the
Area Guide »rescriptions.
I thank you, and hove to hear from you shortly regarding many of the
questions pased herein.
Sincerely,
Wee Miles
Peter 9. Mios, M.N.
Tongass Conservation
Society
169
11.
FOREST SERVICE COMMENTS ON THE
RESPONSE OF THE TONGASS CONSERVATION SOCIETY
To our present knowledge there are no slides in the Shaheen Creek
watershed caused by timber harvest or road construction activities.
The slide you refer to in Traitor's River is actually a very small
slump caused by road construction. It is less than 3-tenth's of an
acre in size. Even though some sediment was introduced, it is not
a catastrophic event when considering the many large slides that
occur under natural conditions. Compared to some of the large
natural slides that have occurred in the past erosion cycle of
Traitor's River, this slide is insignificant. Because of the topo-
graphy and general poor stability of the area, having only one
small slump definitely points to adequate attention being paid to
Area Guides and forest regulations.
It should be noted that the Coastal Zone Management Regulations do
not apply to federal land other than the consistency requirement.
Based on standards set by the Wildlife Task Force for TLMP, the
percentage of natural covertypes should nearly maintain natural
popluations of wildlife. The carrying capacity will not be reduced
for the species if the harvest does not exceed the percentages,
providing timing, spacing, size, and location of cutting is carried
out sensitive to species needs. Certainly no wildlife species will
be eliminated from the sale area.
Information on total population numbers is not available. Estimating
percent of habitat loss infers a net loss in the carrying capacity.
The range is between a minimum viable population level and the
natural carrying capacity.
Habitat is rarely "lost", but it is altered, offering a new type of
habitat benefitting new or different species. The alterations are
within the tolerances of existing or indigenous species utilizing
that habitat for a part of their life cycle.
See the comments on the State of Alaska response (No. 5).
See the comments on the Southeast Alaska Conservation Council
response (No. 1).
The 960 MM bm is well within the program harvest established by
TLMP which take into account reductions for wilderness and other
roadless management plus protection policies.
See section V-F of the FES.
There is approximately 200 MM bm of residual timber all of which is
included in Alternatives 4 and 5 and is displayed on the maps.
The stumpage rates will not decrease. We anticipate stumpage
receipt plus purchaser credit for road construction to equal the
past 5-year period. There have never been, nor is there any planned
federal subsidies to the timber industry.
See the comments on the Southeast Alaska Conservation Council
response (No. 2).
The purchaser is liable for the loss of volume which might occur
during transport of logs from forest to processing plant. There is
a system of log accountability to protect the interest of the
United States.
170
12. Marginal and special components of the timber harvest are estimated
to comprise the following percentages based on air photo evaluation
of Alternative 4.
Unregulated Special Marginal
5% 21% 12%
The contract does not need to speak to the degree of harvest by
timber classification as the timber appraisal makes adjustment for
economic considerations which lay behind the classifications.
This has been greatly discussed in the Tongass Land Management Plan
FES that will be released prior to the ES. We reference this
document as a more appropriate one to address this issue.
13. Importation of Canadian chips or procurement of logs from private
sources do not affect the purchaser's contractural rights to harvest
960 MM bn.
14. This is not within the scope of this ES. See the TLMP FES.
15. Primary manufacture in Alaska is required except for special value
products for which there is no local market. The Regional Forester's
permission is required for such export. The recent export of small
hemlock sawlogs for manufacture in the Pacific Northwest was to
determine feasibility of local sawmilling such logs for higher
value recovery than from pulping.
16. The Forest Service referenced the sources in the DES. See page 19
of the DES.
Petersburg Conservation Society
Petersburg, Alaska
January 28, 1979
USDA Forest Service
Federal Building
Ketchikan, Alaska 99901
RE: DEIS, LPK Timber Sale Plan 1979-84
Dear Sirs:
The Petersburg Conservation Society appreciates the opportunity to
comment on the Draft Environmental Impact Statement for the Louisiana
Pacific Timber Sale Plan, 1979-84 operating period.
Although this timber sale is outside the Stikine district, the planned
activities are of concern to the people of the Petersburg area. There
are major salmon producing streams in the sale area on which the
fishermen of Petersburg depend. There are shellfish areas in bays some
of which have already been affected by logging related activities
and other areas will be affected under this plan. There are prime
recreation areas, particularly for hunting and fishing, used by
Petersburg residents that are proposed for entry under this plan.
A review of the DEIS-indicates that the preferred alternative, if
implemented, will violate several national forest policies, Alaska's
Water Quality Standards, and policies set forth in the Southeast Alaska
Area Guide.
Limitations on Clearcut Size
The size of clearcuts proposed in this DEIS does not conform to stated
national policy. A "Dear Friend" letter from Chief of the Forest Service,
171
John McGuire(p.3, dated November 15, 1978) has this to say on "Size
limitations of clearcuts":
"At one time larger clearcut areas were common in the West,
but because of public concern, the average size of clearcuts
in the West is now less than 30 acres."
In this DEIS we find(p 25-27) that the average clearcut size in the
Alternatives considered is not less than 70 acres and reaches 82 acres
jin Alternative 1. Alternatives provide for 6 to 17 units of 160 acres
or larger and the maximum size of units range from 199 to 546 acres.
In the preferred alternative we find the average size of clearcuts is
77 acres. Twelve units are 160 acres or larger. The size range is
from 9 to 199 acres.
While even the maximum clearcut size of 546 acres is a great improvement
over the thousands of acres of continuous clearcutting of the past, these
alternatives are all seriously at variance with what is stated national
Forest Service policy.
The Forest Service either needs to admit that it has no policy against these
large clearcuts, or it should adhere to what is stated policy.
Prohibition of Steep Slope Logging
"The Watershed Report for the Pk Timber Sale Plan for 1979-84" has
this to say(p. 14):
"Implementation of the timber harvest alternatives(1,3,4,and5)
will generally result in impacts of increased soil erosion,
lower soil productivity, increased water quality(error?),
and increased stream sedimentation."
As a Federal agency, the Forest Service is required by law, PL-92-500,
to comply with Alaska's Water Quality Standards. Not only will the
action proposed violate the Water Quality Standards, but it is contrary
to stated Forest Service policy.
Increases in stream sedimentation for a period of 1-5 years(p. 33)
can scarcely be described as temporary. Likewise, temperature changes
above and below natural levels for periods of 10-15 years (p. 34) are
not changes to be given such cursory treatment.
The map of proposed cutting areas for Alternative 4, the preferred
alternative, indicates that numerous units proposed for cutting lie
on steep slopes. Data should’ be presented to indicate just how many
of the 359 units in this alternative lie on slopes in excess of 35%-
75% where there is increased risk of slope failure. On page 32, the
statement is made that alternatives 3.4. and 5 call for more timber
harvesting on steep slopes than alternative 1. Regardless of the
provision for “appropriate logging systems" and "mitigating actions",
experience has shown that in the 5 to 7 year period, when tree roots
have deteriorated, we cdn expect a high incidence of mass wasting.
Recreation, Wilderness and Esthetic Values
Important areas regarding these values in the long-term sale area are:
Honker Divide(incl. Barnes Lake, Sweetwater Lake and Hatchery Creek)
Salmon Bay Lake
Sarkar Lakes
Red Bay
Karta River System(incl. Salmon Lake)
Port Protection and Point Baker
We feel that it is important that there be no further cutting in these
areas. There is very little left of the northern portion of Prince of
Wales Island. The map of proposed cutting under the various alternatives
does not show the cutting that has taken place outside the sale area.
A once popular sport fishing area with Forest Service cabin was Luck Lake.
Why is it not included in the list showing Recreation Cabin use? If it
is still being maintained, what is the current usage?
172
10
12
13
Esthetics does not appear to be as great a consideration for recreation
along the Thorne Bay-Stanley Creek road system, Hollis, Traitors Cove or
the west shore of Revillagigedo Island. These areas have already been
subjected to extensive clearcutting.
In the "Recreation and Visual Resources Specialist Report"(p. 7) Calder
Mountain area, Klawak Mountains, Salmon Bay and parts of the Red Bay Lake
area are rated as having the highest quality, most distinctive and
diverse landscapes in the area. We find, however, that Salmon Bay,
Red Bay and Calder Mountain are all areas slated for logging under the
preferred alternative.
The most severe impact appears to be on Port Protection. The above report
states that "this VQO has not been met because of two 74 - 79 units that
dominate the view toward the head of the bay." Alternatives 3 and 4
only come close to following the 79-84 guidelines.
It seems strange that the importance of visual quality of the land seen
from the communities of Point Baker and Port Protection should not be
given more importance. The quality of landscape viewed by year-round
residents should be rated at least as important as that seen by
tourists along the Marine Highway route.
The volume of cutting under the preferred alternative cannot be justified
if it is necessary to sacrifice the esthetic values of the Point Baker-
Port Protection area, Sarkar Lakes, Salmon Bay, Red Bay and Sweetwater Lake.
Island Road System
The DEIS mentions that road links are proposed not for the purpose of
harvest, but for the purpose of linking logging communities, for social
reasons. This does not seem like a reasonable investment of federal
monies during a time of budgetary cutbacks, especially when many of
the camp locations are temporary. It is even more ill-advised when
one considers that roading often has the greatest negative impact
on fisheries of any of the forest activities.
Fisheries
We feel that the protection of salmon streams at cutting and roadbuilding
sites and the protection of estuaries, shellfish, bottomfish and
migratory species at dump locations is inadequately addressed in this DEIS.
Economics
The DEIS fails to justify the need to harvest 960 MMbf of timber
during the 5 year operating period. Considering present market conditions
for pulp, this appears in excess of current needs. The recent request
by LPK for export of round logs to Pacific Northwest mills on a long-
term basis indicates a surplus over and above what is needed by its
pulp and cant mills. This will result in exporting primary processing
jobs out of southeast Alaska.
Economic stability in the Ketchikan area is much more dependent on
market conditions than on a large volume of available timber. High
operating costs are the result of logging a virgin forest for pulp in
an area of high labor costs. The LPK mill is in a poor competitive
position compared to modern mills using a high percentage of waste
materials and wood from tree farms with 25 year rotation periods.
Herein lies a tragic fallacy in management. The valuable timber in
the Tongass is old growth saw logs, which are much in demand in Japan
and often can't be replaced by competeing species from other parts of
the world(as opposed to pulpwood, which is far more competitive elsewhere).
Logic would dictate management of the forest for the most valuable and
competitive comodity--old growth saw logs; but instead, we see a rapid
conversion of the old orowth forest to short rotation pulp timber stands,
to the detriment of the future economy of this region.
173
14
16
The reference on page 5/7 to "positive dollar returns" needs to specify
the beneficiary--LPK or the US Treasury? We need to know, in terms of
dollars, what we are getting over and above the costs of administration,
road construction, reforestation and other rehabilitation required on
cut-over land. We need to know the current stumpage to be paid during
this 5 year period of the 50 year timber sale. Is this to continue to
be a deficit sale?
Conclusion
Alternatives 1 & 2 should not be included as valid alternatives. Number 1
violates almost every guideline for good forest practices. It also provides
for entry into the Karta River drainage proposed for Wilderness Designation by
USDA Secretary Bergland. Alternative 2 can not be implemented without
cancellation of the 50 year timber sale contract, which seems improbable,
although the sale does need to be renegotiated in order to protect other
forest resouces, comply with the Southeast Area Guide and meet the
standards of the National Forest Management Act.
The sale should pay for itself and yield a return to the US Treasury.
Alternatives 3, 4, and 5 will violate Alaska's Water Quality Standards, result
in increased soil erosion, lower soil productivity and provide for
clearcuts larger than is stated USFS policy. The preferred alternative
allows for a great deal of loaging on over-steep slopes.
Protection of fish streams and estuaries is inadequate or inadequately
addressed.
With exception of alternative 5, all provide for entry into important
roadless areas. The preferred alternative will have a catastrophic
impact on Point Baker and Port Protection.
Keeping in mind the above concerns, Alternative 5 has the most potential for
becoming acceptable, but details in the DEIS are lacking and the alternative
must be brought into compliance with the Southeast Area Guide and the
National Forest Management Act.
In the Final EIS we would like to see, in addition to the additional
information requested above, as much information as is available on:
the use of timber over the last 5 year plan
current inventory of logs
importation of chips from Canada
the export of logs to other states
available blow-down timber from the Nov'78 storm on Prince of Wales
We will appreciate recieving a copy of your Final EIS. It may be sent
to PO Box 630, Petersburg AK 99833.
Sincerely,
a Aaa he) Q
Thomas H. Wood
President, Petersburg Conservation Society
FOREST SERVICE COMMENTS ON THE
RESPONSE OF PETERSBURG CONSERVATION SOCIETY
ile The Forest Service policy for clearcut size limitations on the
Tongass National Forest is listed on page 110 of the "Southeast
Alaska Area Guide" and states:
"there is established a maximum size limit of 160 acres to be
cut at one place and time. ‘fhe established limit may be
exceeded only after appropriate public notice and review by
174
pas
12.
13.
14.
15
16.
the responsible Forest Service Officer one level above the
Forest Officer who normally would approve the harvest proposal.
Such limits will not apply to the size of the area cut as a
result of natural catastrophic conditions such as fire, insect
and disease attack, or windstorn."
The Forest Service requires compliance with the Water Quality
Standards. The section on "Watersheds" has been rewritten to
clarify this point.
Short term is a standard term in wildland planning which means less
than 5 years. We recognize that to the layman, this may seem too
long. The severity and consequence of the impact is more important
than the duration. The "Effects" section in the FES has been
rewritten in response to many of the comments.
Table 5 in the FES provides this information. See also the discus-—
sion of Mass Soil Movement in the "Soils" section.
The decision to cut or not to cut has been made through the Tongass
Land Management Plan. The LPK 5-year plan ES is concerned with how
to best accomplish the cutting, roadbuilding, and related activities.
Esthetics are a prime consideration in these areas.
The Red Bay and Calder Mountain areas already have extensive cutting
and roading. See Section V-F of the FES concerning salvage of
blowdown. Salmon Bay and the Klawock Mountains have no proposed
cutting.
No cutting units are visible from Point Baker or Port Protection.
See comments on the State of Alaska response (No. 5).
Section V of the FES has been rewritten to better address this
concern.
See comment on the Tongass Conservation Society response (No. 15).
See comment on the Southeast Alaska Conservation Council response
(No. 2).
About 40 percent of the old-growth timber is defective and not
suitable for sawlogs. This is the component of the old growth that
goes into pulp. The converted second-growth stands are planned for
sawlogs, not pulp, as some people think. These second-growth
stands at rotation age (about 100 years) will contain about twice
the utilizable volume per acre than old growth.
This is in reference to the U.S. Treasury, not LPK. The sale is
not now deficit, nor do we expect it to be in the future.
See comment on the State of Alaska response (No. 2).
See comments on the Tongass Conservation Society response.
Aue)
FEDERATION OF WESTERN OUTDOOR CLUBS
President: Karen M. Fant
51192 27thN.E., Seattle, Wa
Vice President: Helen Engle
4011 Alameda, Tacoma, Wa. 98466
Secretary: Virginia Danke
E1103 14th. Spokane, Wa. 99202
Treasurer: Blythe O. Edwards
Established for Mutual Service and for the Promotion of the Proper Use, Enjoyment and
Protection of America’s Scenic, Wildemess and Outdoor Recreation Resources
1978-1979
State ice Presidents:
amp y Wood, Dixie Baade, Alaska
ly Reeves, Martin Litton, California
M. Slansky, Idaho
eth Baldwin, Larry Culp, Montana
pe kisions Oregon
. 98105
‘olsom, Dennis Elliot, Washington
4549 E. 53rd, Maywood, Ca, 90270 Cc TDOORS WEST
. Wolf,
'. :
MEMBER CLUBS pylston Ave. E. #106
Admiralty Audubon Society Est. 1 932 Wa. 98102
Port Townsend, Washington
Jtn D.C. Representative:
Alpine Roamers Y u
Wenatchee, Washington a Mir 50 n Brock Evans, —
Angora Hiking Club PeOls pe FAl ennsylvania Ave. S.E.
(Astoria Oregon Washington, D.C. 20003
Berkeley Hiking Club Petersburg, Alaska
Berkeley, Califomia
Boeing Employees Alpine Society
Seattle, Washington
Califomia Alpine Club
San Francisco, California
Cascade Wildemess Club
Bellingham, Washington
Cascadians
Yakima, Washington
Chemeketans
Salem. Oregon
Contra Costa Hills Club
Oakland, Califomia
Crag Rats
Hood River, Oregon
Desomount Club
Los Angeles, Califomia
Hobnailers
Spokane. Washington
Idaho Alpine Club
Idaho Falls, Idaho
Inter-Mountain Alpine Club
Richland, Washington
Klahhane Club
Port Angeles, Washington
McKenzie Guardians
Blue River, Oregon
Montana Wildemess Association 3 O that th
Bozeman, Montana
Mountaineering Club of Alaska
Anchorage, Alaska
Mountaineers
Seattle. Washington
Mt. Baker Club
Bellingham, Washington
Mt St. Helens Club
Longview, Washington
Obsidians, Inc.
Eugene, Oregon
Olympians, Inc
Hoquiam. Washington
Olympic Peninsula Audubon
Sequim, Washington
Palouse Audubon Society
Moscow, Idaho
Ptarmigans
Vancouver, Washington
Reed College Outing Club
Portland, Oregon
Regional Parks Association
Berkeley, California
Rimrock Mountaineers
Coulee Dam, Washington
Roamer Hiking Club
Inglewood, Califomia
Rocky Mountaineers
Missoula, Montana
Santiam Alpine Club, Inc
Salem, Oregon
Seattle Audubon Society
Seattle, Washington
Sierra Club
San Francisco, California
Skagit Alpine Club
Mount Vernon, Washington
Snake River Audubon Society
Idaho Falls. Idaho
Southeastern Alaska
Mountaineering Association
Ketchikan, Alaska
Spokane Mountaineers, Inc.
Spokane, Washington
Summit Alpine Club
Tacoma, Washington
Tahoma Audubon Society
Tacoma, Washington
Tamalpais Conservation Club
San Francisco, California
Trails Club of O-----
Portland, C
Wanderr
Olu-
w
\
Seattle. Washington
Sog
yh (C2)
Northwest Representative:
Douglas Scott,
4534/2 University Way N.E.
Seattle, Wa. 98105
January 27, 1979
J. S. Watson
Forest Supervisor
Ketchikan Area Office
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
For some reason I have again been removed from the mailing
list of the Ketchikan area office. I just learned two weeks
e Draft Environmental Impact Statement for the LPK
Timber Sale 1979 - '84 operating period had been released over
a month ago. It was not possible for me to obtain my Own copy
for review in time to comment by next week's deadline. For this
féason, my comments are incorporated in those of the Petersburg
Conservation Society.
Since I have again been elected a Federation of Western
Outdoor Clubs vice-president, I need to be informed as to activit-
ies throughout southeast Alaska.
My comments on the Draft Environmental Statement may be brief-
ly summarized as follows:
(1) Implementation of all alternatives with the exception of # 2
will result in increased soil erosion, lower soil productiv-
ity and increased stream sedimentation. This will violate
Alaska's Water Quality Standards as well as stated Forest Ser-
vice policy.
The preferred alternative will
on steep slopes. This is contr
lines.
provide for numerous cutting units
ary to stated Forest Service Guide-
176
3 (3) All alternatives provide for average clearcut size in excess of 30
acres. According to Forest Service Chief, John McGuire, the average
size of clearcuts in the west is now less than 30 acres.
If this actually is Forest Service policy, then it needs to be follow=
ed in Alaska. ‘To do otherwise widens an already large credibility
gap. One thing is written on paper. What happens in practice is
something else.
(4) Specialists reports admit there will be stream sedimentation, temper-
ature changes and alteration of stream flows all of which will have
an adverse impact on the fishery. The Southeast Area Guide was very
poor in its provisions for protection of fish streams as was the
section on water. Unfortunately even those protective provisions
in the Guide are all too often not followed in practice.
4 (5) A specialists report admits there will be a reduction in certain wild-
life populations. The decision to go ahead with cutting plans in the
face of this indicates a lamentable willingness to sacrifice our fish
and wildlife populations to the short term interest of the timber
industry.
Among wildlife populations sure to be adversely affected are the Sitka
blacktail deer, marten, mink, otter and timber wolves.
Forest bird populations have been virtually ignored. Among those
adversely impacted are the hole nesting, insectivores. Their
activities will no doubt be replaced by the need for pesticides.
5 (6) No data is presented to justify the need for a 5 year harvest of
960 MM bm. Economic stability in the Ketchikan area is much more
dependent on market conditions than on a large volume of available
timker. The LPK mill is in a poor competetive position in respect
to the more modern mills using cheaper raw materials.
6 (7) No data is furnished to indicate what stumpage is to be paid or
whether this is to continue to be a deficit sale.
7 (8) All viable alternatives (this excludes 1 and 2) with the exception
of number 5 provide for entry into important roadless areas. Con-
sidering how little is left in a natural state on the northern part
of Prince of Wales Island, it is important that these areas, recog-
nized in the Recreation and Visual Resources Specialist Report,
be protected from further logging.
I will appreciate receiving copies of the Specialists reports that
accompanied the Draft E.I.S. I will also appreciate a copy of the final
E.I.S. May I please be reinstated on the Ketchikan area office mailing
list.
or ices | YOUrSy
ilu ie
rs. Dixie M. Baade
vice president for
FOREST SERVICE COMMENTS ON THE
RESPONSE OF FEDERATION OF WESTERN OUTDOOR CLUBS
Ds See comment on the Petersburg Conservation Society response (No.
2)
2 See comment on the Petersburg Conservation Society response (No.
4).
36 See comment on the Petersburg Conservation Society response (No.
Die
177
4. The adverse effect on Sitka blacktail deer was shown in table 10
and figure 2. The impacts on furbearers will be as a result of
increased demand and utilization of the resource rather than habitat
modification.
Perhaps forest bird populations were not emphasized as they could
have been. Table 10 does show an adverse impact on old growth
obligate birds for all cutting alternatives. Table 9 recognizes
six brood Categories of avian wildlife and the corresponding needs
of the WHMA to maintain near natural levels.
Die See comment on the Southeast Alaska Conservation Council response
(No. 2).
6. This has never been a deficit sale. See comment on the Tongass
Conservation Society response.
io Only Alternative 1 would result in entering any individual roadless
area singled out by any public group for Wilderness management.
Due to decisions of TLMP and RARE II, the option remains open for
entering these areas in future planning periods, should there be a
need.
Louisiana-Pacific Corporation
Ketchikan Division
Post Office Box 6600
Ketchikan, Alaska 99901, U.S.A,
Telephone: 907-225-2151
Telex: 099-55-251
Answer back: KAYPULPCO KET
January 18, 1979
Mr. James Watson, Forest Supervisor
USDA, Forest Service
Federal Building
Ketchikan, Alaska 99901
Dear Mr. Watson:
Following are comments on your Draft Environmental Statement
for the 1979-1984 period of the LPK Long Term Sale.
There is no mention in this draft of how advance roads are
to be handled for the 1984-89 period. This is an important
eonsideration in that without identifying advance road and
units for the next period the Sale cannot proceed in a pro-
gressive manner. There must be one and one-half seasons of
the next period's operating area showing roads and units so
that engineering and construction of these roads can be
completed at least one year ahead of logging.
It must be recognized by the Forest Service that there are
limitations to full suspension yarding. In order to fully
suspend logs while yarding, the ground must lay in a manner
that will allow for cables, choker and suspended log clearance.
It is essential that the Forest Service, prior to committing
to full suspension, examine the ground to make sure there is
adequate deflection so that it is physically possible to fully
suspend,
In comparing the roads described in the text with those shown
on the maps there appears to be some inconsistency. This
should be clarified in the final ETS.
178
4 A determination as to the exportability of cedar during the
1979-84 period must be made before finalization of the EIS.
There are units containing a large percent of cedar that
will not be acceptable to LPK if cedar export is restricted,
There should also be a section explaining the benefits of
flexible log marketing restrictions so that logs surplus to
the pulp operation can be marketed to a higher use.
It is imperative that all IDT reviews of harvest units be com-
pleted in a timely manner, Releases for roads and cutting units
to be logged to those roads must be presented to LPK at least
sixty days prior to construction of these roads. Anything
less than the above will result in delay of LPK operations,
The following comments are addressed to the "Operating
5 Guide Lines for Timber Sale Layout".
There should be an Item (7) added to the Timber Section:
(7) Logging systems must be economical and within the
state of the art presently in use in the South
Tongass.
EA OAT le Ria NRG eal a at,
Fish stream habitat.
Modify Item 2 to read:
Where necessary to yard across a designated fish strean,
stream banks must be protected by full suspension, bridging,
or other means agreed to by the purchaser and Forest Service.
The comments on culvert installations in Item 5 should be
referenced in the typical drawings. Provision in these
drawings should recognize known methods of protecting
stream beds and reference made to innovations that are
acceptable to Forest Service and purchaser and will acconm-
plish stream bed protection,
Item 8b is not clear in that it can be read to mean that
there must be a twenty chain leave strip on the N, NE, E,
and SE side and a ten chain leave strip on the S, SW, W
and NW side. It should be changed to make clear that the
objective is to not open areas of any greater length along
the stream of twenty and ten chains respectively.
Log Transfer Sites and Raft Storage Areas,
There should Re an Item A4¥ and 5 that states the following:
AY The site must have adequate water to float
bundles at all stages of tide.
A5 The site must be protected from prevailing winds
and ocean swells.
Add to last sentence of Item B6....0or modify standing boom
to enhance the above uses,
Add an Item B7:
B7 There must be a rock source adjacent to the site
and the length of haul to the site from the timber
should be minimized,
Add the following to Item Cl....as long as the site is
protected from prevailing winds and ocean swells.
179
Add the following to the final paragraph of Log Transfer
Section,
But the safety of the people involved in the log transfer
operation overrides the protection of the fishing resource.
In reference to your maps of the alternative 1, there is no
log transfer site shown for Hassler Island.
Alternative IV shows no site for Hassler or Roaring Hole.
The log transfer site for Marble Island is located too far
from the timber and will require the construction of one
mile of road that could be eliminated if the site were
located in Marble Passage,
Thank you for the opportunity to comment. T hope the above
will be given consideration in the Final ETS.
Very tr Uy y urs,
re gears
George Woodbur
Logging Manager
hr
FOREST SERVICE COMMENTS ON THE
RESPONSE OF LOUISIANA-PACIFIC CORPORATION (GEORGE WOODBURY)
1. With the implementation of the RARE II and TLMP decisions, future
advanced roads will be handled through the EAR process as there
will be no roadless areas other than those allocated to Wilderness
or roadless management (LUD 2).
Die The Forest Service recognizes the limitations to full suspension
yarding and plans to coordinate unit layout with logging engineers
as well as soil scientists on critical areas.
S16 The maps have been corrected.
4. The exportability of cedar will continue to be governed by Section
1(g) of the contract. We will continue to evaluate the local
market conditions and if changes in the current situation develop,
we will hold public hearings before changing our present policy on
redcedar exports. As to the benefits of flexibility in log marketing
for materials surplus to the needs of the pulp operation; this was
recognized at the time of drafting the contract. Section 22 of the
contract is explicit in its provision for the purchasers commitment
to the development of facilities for processing materials excess to
the needs of the pulp enterprise.
Dis The operating guides were given to the purchaser in September 1976
for comment and use in selecting cutting units. The guidelines are
not all inclusive or governing in every aspect of timber sale
layout. To the extent, LPK's suggestions are not in conflict with
the "Southeast Alaska Area Guides," they are accepted.
6. The maps have been corrected to show the log transfer sites at
Hassler and Roaring Hole. The final location for the transfer site
on Marble Island has not been resolved due to the heavy snow cover
at the various sites. National Marine Fisheries and U.S. Fish and
Wildlife have recommended a site at the northeast corner of the
island.
180
X. REFERENCES
Gregory, R. A.
1956. The effect of clearcutting and soil disturbance on temper-
atures near the soil surface in southeast Alaska. U.S. Dep.
Agric., For. Serv., Alaska Reg., For. Res. Cent. Stat. Paper
Nos. 75.22) pps: titkus.
Miller, John F.
1963. Probable maximum precipitation and rainfall frequency data for
Alaska, for areas to 400 square miles, durations to 24 hours,
and return periods from 1 to 100 years. U.S. Dept. Com.,
Weather Bur. Tech. Paper No. 47,. 69 pp., illus.
Federal Register
1976. 36 CFR 800 Vol. 41., No. 28., February 10. U.S. Govt. Print:
Ofc., Washington, D. C.
Moser, J. F.
1902. The salmon and salmon fisheries of Alaska. Vol. II,. U.S.
Govt. Print. Ofc., Washington, D.C.
National Register of Historic Places
1978. Vol. 43, February 7. U.S. Govt. Print. Ofc., Washington,
D.C., plus monthly updates through Vol. 43, No. 243, December |
35: 1978.
Ruth, R. H., and A. S. Harris
1973. Western hemlock - Sitka spruce. In Silvicultural systems for
the major forest types of the United States. U.S. Dep. Agric.,
For. Serv., Agric. Handb. No. 445, pp. 5-7.
Ruth, R. H., and R. A. Yoder
1953. Reducing wind damage in the forests of Oregon Coast Range.
U.S. Dep. Agric., For. Serv., Pac. Northwest "or. and Range
Expt. Sta., Res. Paper PNW-7.
Petroft, I.
1884. Report on population, industries, and resources of Alaska. In
U.S. Dep. Interior, 10th Census, 1880.
Rabich, Ji) Gs
1978. The archeological potential of Red Bay V.C.U.'s 532 and 533.
U.S. Dep. Agric., For. Serv., Alaska Reg., Tongass Natl. For.,
Ketchikan Area. Unpub. paper.
181 ‘
Sealaska Corporation
1975. Native cemetery and historic sites of southeast Alaska.
Wilsey and Ham, Inc., Seattle.
eeror: R.. Be
1934. Yield of second-growth sestern hemlock-Sitka spruce stands in
; southeastern Alaska. U.S. Dep. Agric., For. Serv., Tech.
i Budde No. 412:
us. Department of Agriculture, Forest Service
1974. Ketchikan Pulp Company Timber Sale, 1974-79 operating period.
x Final Environmental Statement.
Uz S. Department of Agriculture, Forest Service
i National Forest Landscape Management, Vol. 2.
U. S. Department of Agriculture, Forest Service
The forest ecosystem of southeast Alaska. (It describes the
setting, forest insects, fish habitats, wildlife habitats,
soil mass movement, Forest diseases, Forest ecology and
; timber management, water, timber inventory, harvesting,
‘ marketing and trends; and outdoor recreation and scenic
resources.)
U.S. Department of Agriculture, Forest Service, Alaska Region.
1963. Timber management plan for the Ketchikan-Craig working circle,
Tongass National Forest.
m.s. Department of Agriculture, Forest Service, Alaska Region.
1978. Tongass land management plan task force working reports.
TLMP-1 through 8. (These reports cover such topics as landtype/-
timber, fisheries, wildlife, minerals, wilderness and recrea-
tion, and socioeconomic overview.
we
Wright, F. E., and C. W. Wright
1908. The Ketchikan and Wrangell Mining Districts, Alaska. USDI
Geol. Surv. Bull. 347.
Also, specialists working on this plan wrote detailed reports on their
subjects. These unpublished reports are available on the following
topics by request from the Ketchikan Area Office, Forest Service, USDA,
‘Federal Building, Ketchikan, Alaska 99901: Soils and Watershed, Fisheries,
Wildlife, Cultural Resources, and Recreation and Visual Resources.
182
XI. GLOSSARY
Alevin
A salmoid fish fry on which the yolk sac is still apparent.
Ambient (Surrounding; on all sides; condition or situation surround-
ing a point or object on all sides.
Habitat
The natural environment or place of existance of a plant or animal.
Landscape Management Terminology
Character Type
An area of land that has common distinguishing visual
characteristics of landform, waterforms, and vegetative
patterns. Used as a frame of reference to rate physical
features of an area as to their degree of scenic quality.
Visual Quality Objectives
Measureable standards for management of the natural
landscape. These standards or objectives each describe a
different degree of acceptable alteration of the natural
landscape.
Preservation
Management activities, except for very low visual impact
recreation facilities, are prohibited. Allows only
ecological changes.
Retention
Management activities must not be visually evident.
Partial Retention
Management activities can be visible but must be visually
subordinate to the characteristic natural landscape.
183
Modification
Management activities may visually dominate the original
characteristic landscape. However, visual characteristics
of management activity must borrow from those of natural
occurrences within the surrounding area.
Maximum Modification
Management activities may dominate the natural landscape.
When viewed from foreground or middleground viewing
positions, they may not borrow from the natural landscape.
But, when viewed from background positions, the activity
must have the visual characteristics of the natural
landscape.
Unacceptable Modification
Overall extent of management activity is excessive. Size
of activity is poorly related to the scale of landform
and vegetative patterns in a characteristic landcape.
Mean Annual Increment
The total volume of a stand of trees divided by the age of the
stand.
Niche
A site or habitat supplying the factors necessary for the sucessful
existence of a species.
Site Index
A numerical evaluation of the quality of the land for forest
productivity, determined by the rate of growth in height of one or
more species of trees.
Threshold Point
The point at which a stimulus is just strong enough to be perceived
or produce a response.
V-Notch
V-shaped, steep-walled, incised drainages that cut the sideslopes
of glaciated valleys along zones of geologic weakness or post
glacial channeling.
184
XII. INDEX
Alternatives
Considered--26
Consultation--81
Effects of Implementation-—-28-76
Evaluation of--76
FS Preferred Alternative--79
Management Requirements--80
Alternative 1--27, 29, 36, 40, 52, 54, 64, 68, 72, 73,.75-78, 80, 82
Alternative 2--27, 30, 36, 40, 58, 64, 69, 72-73, 75-78, 82
Alternative, 3=-27:, 30, 37,,°40, 52, 54, 58, 64, 69',°°72.5 7351 75-79), 82
Alternative 4--27, 30, 37, 40, 52, 54, 58, 65, 69, 72, 74-80, 82
Alternative 5--28, 31, 37, 40, 52, 54, 58, 65, 69.5.:J2,°745 76-79),--82
Atmosphere--76
Economic Aspects--21
Federal Government-—-21-23
Timber--21-22, 25-27, 60-70, 77, 79-80
Tourism--22
Effects
Employment--66-67, 78-79, 80
Fish--38-48, 50-52 |
Human Population—-70
Lakes-—-73-74
Recreation--50, 67-72
Socioeconomic--66, 67, 68, 69
Streams-—-31-37, 40-44, 48, 51
Soil--29-30, 33, 37
Timber--30, 60-65, 77
Vegetation--59-61
Visual--72-76
Wilderness--72
Wildlife--52-58 {
Wildlife Population--54 !
Environment
Climate--4
Fauna--9 |
Flora--8 i
Geography--4 if
Recreation--12, 13, 67, 68-70
Roads--16-20, 78
Soil--5, 11, 29-31
Visual Quality--72-74, 82
Water--6-7, 31-37
Wildlife Habitat--52-58, 72-74, 77
185
Cultural Resources
Archaelogical Sites—75, 80
Fish
Commercial—21-23, 45
Crab & Shrimp—48
Effects on—-—37-40
Habitat—38, 42-52
Salmon——43—46, 47, 48
Stream sedimentation——40-41
Prince of Wales Island--l, 2, 14, 16, 18, 19-20, 25, 33, 61, 65, 67-72, 76, 79
Revillagigedo Island--l1, 2, 14, 16, 71-72, 76
Visual Management System——73
Transportation
Air--16, 17
Roads—-16-19, 26-28, 31, 33, 36, 45, 68-73, 77-78
Water--16, 17, 26, 68, 73-74
186
XIIL APPENDIX .
j
Unitod Statos Dopartmont of Agriculture Contract No. 1
Forost Sorvico
AGREEMENT TO MODIFY CONTRACT ‘ of
(Timber Sale) Alofs - 1042
[S It ds mutually agreed that the above designated timber sale contract, signed by
L. Turcotte, President, Ketchikan Pulp and Paper Co.
of Bellingham __+,____—Washington ______ hereinafter
called the purchaser and by____——s—C,,_ M,. Granger, Acting Chief oo ...,_ Forest Service _for =
(Name) (litle) 5
the United States of America as of the 15 day of December, 1977 6/as hercitofore modified, be t
modified as follows: Add: 35(n) Advanced Transportation Facilities Construction
Purchaser is authorized to construct, during a current five-year operating period, certain
transportation facilities, such as: Specified roads, bridges, and other transportation
facilities that will be needed for the next ensuing five-year period; provided that the
beginning point for estimating these advance facilities shall be from either (a) the ter-
minus shown on the current five-year operating plan, or (b) the terminis of a mutually agree
to alternate facility, or (c) a terminus adjusted under provisions of Section 35(b); and
provided that any facility approved fro construction under terms of this section shall be
added to Table A2 before construction begins. 4
It is provided further that no facility shall be approved for construction under (a) and (b)
of this section until such time as the Five-year operating plan for the next ensuing five-
year operating period has been approved by the Regional Forester. It is provided further
that facilities constructed under terms of this section shall be used only for operations
for the ensuing five-year operating period.
See Attachment
Draw a diagonal line with pen and ink in unused portion of torm.
2. Pursuant to this mutual agreement, the purchaser hereby agrees to cut and remove timber in strict accordance with all and singular
the terms and provisions of the aforesaid contract as herein modified.
IN WITNESS WHEREOF, the parties hereto have executed this modification of contract as of the 1/. day
of a ee ee S19. A
UNITED STATES OF AMERICA
By: ___John_ A, Sandor, Regional Forester
(Signature of approving officer) (Title) t
Two witnesses: 2/ es \
a
a aL 3
(Name of witness) ) 4
Purchaser
——ketchikan-Pulp Co_—___
tAddrew) {
P fe} B te 600 +
{Name of witness) Purchaser's }
Uusiness
Ketchikan, Alaska 9990] Adutess
(Address) ‘
4, ee Ae AO © sd —_________, certify that Iam the S87. SEREMRY Aaa ae
FU NEY
Secretary of the corporation named as purchaser herein; that. DL. tA) MEY _
who signed this contract on behalf of the purchaser, was then Vv (CG f7tl S(DERS S
eed
of sa corporation; that san contract was duly seacd for and im behalf of said corporation by authority of ifs yovernmy body, and is
within the scope of is corporate powers,
a7
Vid ’ ( ? f, ZY CORPORATE
« . .
st SLAL S/
1] The date approving Forest officer sipny this form,
M The signatures and addresses of feo witnesses are required Uf wale ty to other tsa a corperation E :
SM Weontirctin party ia co partnership. the saptatuces should be NWZ Company by Jeho Doe a member of tre fiom Te contracting pacty ba corporition,
form of sIpN nce should be AYZ Company by Joti Doe. Mevadent foreder et icone acct) and the sealot the corporation pnuyt be unpreysed or mdicated,
A Vhe certitieate must be Completed it the parchaser ty a corporation
Sf Wethe corporation hay ny corporate yesh that hast stall deviated. in which gaye a scrotlor sdhesive seal shill follow the carperite nannie
iy mavict
6/ Delete “ae heretofore qioditied Wh net appleable 2400-9 (3/69)
187
INT me EE tg el IT re
CONTINUATION OF AGREEMENT TO MODIFY CONTRACT - Alofs - 1042, 15
December 1977, Section 35 ee
Purchaser Credit Limit for facilities constructed under terms of this
section shall be computed by using current unit costs that are in effect
as of the date the facility is added to Table A2. ~
188
Contract No.
A1L0O£s-1042
United States Dopartmont of Agricultura
Forost Sorvica
AGREEMENT TO MODIFY CONTRACT
(Timber Sale)
a. It is mutually agreed that the above designated timber sale contract, signed by
L. Turcotte, President, Ketchikan Pulp and Paper Company
of ____ Bellingham __,__Washington hereinafter
‘ Vv
cxdiietahe purchasenandiny C.M. Granger, Acting Chief Forest Service a
(Name) (Title)
26th July 1951
the United States of America as of the day of y ______6/as heretofore modified, be
modified as follows:
Modify table of unit costs by inserting the following items:
Transport Portable Bridges from Seattle to Ketchikan. .... $10.69/Lin. Ft.
Installation ‘of Portable Bridgés., « 2 0 » « « « « @ » «6%. 21909 .90/Line ne.
Removal of Portable Bridges: ... . « «2 = «+ - # * «0 « « « 9$99.00/Lin hth
Land Haul of Portable Bridges. . . 2. 2 6 © © oe ee © « « + $00,10/ft./mile
Water Haul of Portable Bridges . 3 « s 4 «0 2 © © » © «,« « SOOL19/£t5/mille
Draw a diagonal line with pen and ink in unused portion of form.
2. Pursuant to this mutual agreement, the purchaser hereby agrees to cut and remove timber in strict accordance with all and singular
the terms and provisions of the aforesaid contract as herein modified.
IN WITNESS WHEREOF, the parties hereto have executed this modification of contract as of the !/_ day
of. pete |)
UNITED STATES OF AMERICA
JOHN A. SANDOR, Regional Forester
_ By:
(Signature of approving officer) (Title)
Two witnesses: 2/ : |
THA IS IR EE (Berry eee |
(Name of witness) 3/ |
Ketchikan Pulp Company Purchaser
(Address) OF -
P.O. Box 6600
(Name of witness) Parte
i Bus
Ketchikan, Alaska 99901 ave
(Address)
1, 41 1. ke Cr L certify that lam the Ass? CG seenee
: % uy y ————-. Se
Merle A. Mosar Re
Sceretary of the corporation named as purchaser hervin; that
who signed this contract on behalf of the purchaser, was then Vom OM (a SING es SOU Za
of said corporation, that sam contract was duly si-.ed) for und in behalf of said corporauion by authorty of its governing, bbuy, andais
within the scope of ils corporite powers, ' 4
i4aes RAR Ce Le:
aca rN) etude Oras fC
24 Oy).
- - 1, Gea s Conrogatt f |
5 A srap es
Ol BEAL LE
W/ The date approving Forest officer signs this form, fret Ue PUCODO LEN
‘ \ .
2 The sunatares and addresses of two witnesses are required if sale is to other than a cocponiion 94,8 } {) é SA
Bf Mecontiacting party isa co partnenstup, the signatures should be XYZ Company by John Doe a aembor of the firm TH contracting party ts. Cofporition,
form of signature should be NY Z Company, by Joho Doe, Aevident cor otherofficeror agent) snd the sesbot the corporation must be impressed of indicated, *
4) Whe cettiligate must be completed af the purchaser iy a Corponition,
$/ WP the conporstion hay no vorporate seal that Lact stall be stated. i which eave s vcrollor adhesive veal shall follow the corporate naine,
6/ Delete “us herctolore modibed” a not appliesble, .
2400-9 (3/69)
189
Contract Ko,
United Otetos Donartment of Agriculture
Forest Gervioe
AGREEMENT O MODIFY CONTRACT
(Timber Sale) Al0fs-1042
1, It is mutually agreed that the abovo designated timber ealo contract, signed by.
ee eS urcottes= president, ketchiikan=Pilpeand=Paner Company
of Bellingham___——,__- Washington SS _herretnafter
(Title)
the United States of America as of the __ 26th _ day of __Jduly 195] 6/ as herelofore modified, be
modified as follows:
Modify section 2(e) by inserting 2(m) and 2(n) after 2(g) and
adding new contract sections 2(m) and 2(n) after 2(1).
i ae MEGA hie EoreastsServyice = for
eallod the purchaser and by. nger, Acting C
New contract sections 2(m) and 2(n) are attached.
Draw a diagonal line with pea and ink in unused Portion of form.
2. Pursuant to this mutual ar-cement, the purchaser hereby agrees to cut and remove timber {n atrict accordarce with all and singular
the terns and provisions of the aforcsaid contract as herein modified.
IN WITNESS WHEREOF, the parties hereto have executed thia modification of contract as of the 1/ 8th day
Gree November 39
UNITED STATES OF AMERICA
=F a) « \ ve
By: EEE f ae #77 JOHN A. SANDOR, Regional Forester
(Signature of @pproving officer) : (Title)
; es
Two witnesses: 2/ SS
Sie Le we
ee LEN GEE Z ee
(Name of witness) AD a < or 3/
Tf Purchaser
(Addreaal Ketchikan—Pulp—Company— —__
(Name of witness) 20 S0x-1619 ———— Purchase’
(Address) Ketchikan,—Alaska—99901 pistes
T?
1, 4/ Mu R. Pihl ——, certify that I am Cs ee a re 2 ae
Beeretary of the corporation named ae purchaser eer it hate Oe ne Flanagan
who signed this contract on belinlf of the purchaser, wns then es President ess Cee ees
of anid corporation; that snid contract was duly signe! for and in behalf of said corporation by authority of its governing body, and ia
within tho scope of its corporate powers.
SE flee. Cet [ore
BEAL 57
re required If sale le to other than a corporation.
1/) The date approving Forest oMicer alguns this form.
2/) Vhe signatures anit aldicesce of t witnee
S/W contracting arty im aweco y
* partnership, DALES Mthe: X¥Z Com by John D>
ey BURSA J . 2 oMmpany, by ohn Dow a member of the firm. If contracting party on we corporation.
OF tigvaturo ehoull be AVE Co ny, by too. be nt (or ether officer of aye. avd the eral of the corporation muat he ayweeon or dis mci F ‘
4/ Vhe cortiticate muat be completed if the purcheser le ulpuration,
87 WE the corporetion haa no cor borate seal that fact elall be stated, in whic
b case @ acroll of adlesive seal shall foll i
€/ Delete “as beretulure Wodifed” if not applicable, : “cag glee aad
2400-9 (3/69)
190
SAFECO INSURANCE COMPANIES
SAFECO INSURANCE COMPANY OF AMERICA
GENERAL INSURANCE COMPANY OF AMERICA
FIRST NATIONAL INSURANCE COMPANY OF AMERICA
HOME OFFICE: SAFECO PLAZA, SEATTLE, WASHINGTON 98185
CONSENT OF SURETY
We, Safeco Insurance Company of America hereby consent to the "Acareement
/
to Modify Comtract" dated July 26, 1951 :
Timber Sale Contract No. Al0fs-1042 is hereby modified as follows:
Modify section 2(e) by insertina 2(m)-and 2(n) after 2(n4
and addine new contract sections 2(m) and 2(n) after Ze
Sianed, sealed and dated this 7th day of December,1976.
SAFECO INSURANCE COMPANY QF AMEPICA
- ~
ae
Lad a
DY 30 ee ee eae
Theo. W. Dackmann, Attornev-in-"ac
9
ese ee aa ‘
ee = Pe.
Bot a ail pie Nar at
GENERAL INSURANCE COMPANY OF AMERICA
HOME OFFICE: SAFECO PLAZA
SAFECO SEATTLE, WASHINGTON 98185
gS POWER OF ATTORNEY “SAFECO INSURANCE COMPANY OF AMERICA
No. 3065
KNOW ALL.MEN BY THESE PRESENTS:
That Safeco Insurance Company of America and General Insurance Company of America, cach a Washington
corporation, does each hereby appoint
oeee--------- ROBERT A, LaBOW; WILLIAM H. SCHLENKER; JOHN F. SOLON; THEO W. BACKM
CATHY HORPERSER, Seabele, Washington) =--~~4--~9ee-nenan am annchen nc escnssesensccese se
its true and lawful attorney(s)-in-fact, with full authority to execute on its behalf fidelity and surety bonds or undertakings
and other documents of a similar character issued in the course of its business, and to bind the respective company thereby.
IN WITNESS WHEREOF, Safeco Insurance Company of America and General Insurance Company of America have each
executed and attested these presents
see Ee dayi0 ee rip Nae
W D HAMMERSLA SECRETARY GORDON H SWEANY. resect og
CERTIFICATE
Extract from Article VI, Section 12, of the By-Laws of SAFECO Insurance Company of America
and of General Insurance Company of America:
“Article VI, Section 12, — FIDELITY AND SURETY BONDS ... the President, any Vice President, and the Secretary shail
each have authority to appoint individuals as attorneys-in-fact or under other appropriate titles with authority to execute on
behalf of the company fidelity and surety bonds and other documents of similar character issued by the company in the
course of its business . . . On any instrument making or evidencing such appointment, the signatures may be affixed by
facsimile. On any instrument conferring such authority pr on any bond or undertaking of the company, the seal, or a
facsimile thereof, may be impressed or affixed or in any gy yep manner reproduced; provided, however, that the seal shall not
be necessary to the validity of any such instrument or und¢aaking.”
Extract from a Resolution of the Board of Dirgetots of SAFECO Insurance Company of America and
of General Insurance Company of America adopted July 28, 1970:
“On any certificate executed by the Sccretary or an assistant secretary of the Company setting out,
: i °
(i) The provisions of Article VI, Section 12 of the By-Laws, and
(ii) A copy of the power-ofattorney appointment, execuied pursuant thereto, and
(iii) Certifying that said power-of-attorney appointment is in full force and effect,
the signature of the certifying officer may be by facsimile, and the seal of the Company may be a facsimile thereof,”
a
1, Wm. Hammersla, Vice President and Secretary of SAFECO Insurance Company of America and of General Insurance
Company of America, do hereby certify that the foregoing extracts of the By-Laws and of a Resolution of the Board of
Directors of these corporations, and of a Poover-of-Attorey issued pursuant thereto, a+ ue and correct, and that both the
By-Laws, the Resolution and the Power-of-Attorney are still in full force and effect.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed the facsimile seal of each corporation
t
this EA ct day ond Zeemliee 19.
Oy /)WS
IH eC
WO TAREE A SHEMET AMY
192
2(m) - Transfer of Purchaser Credit. Upon Forest Service approval
of Purchaser's written request, unused Effective Purchaser Credit
earned after December 16, 1975, shall be transferred from this contract
to Purchaser's other timber sale contracts within the same National
Forest (36 CFR 221.7).
Effective Purchaser Credit transferred from this contract subsequently
determined to be ineffective under terms of this contract shall
be replaced by cash payments, 0% of the maximum purchaser
credit limit as approved on table A-2 cannot be transferred
from this sale and must be applied to the timber harvested from
the withdrawn areas.
Purchaser Credit transferred to this contract from other contracts
may be used to meet current or subsequent charges for timber
subject to 2(g). Transferred Purchaser Credit may not be used to
cover payments for Base Rates, Required Deposits, charges for
timber harvested on areas withdrawn under PL 92-203 and 94-204, and
$1,273,950 needed to accomplish sale area betterment work.
Transfer of Purchaser Credit to or from Timber Sale Account shall
be made monthly, or at longer intervals, as requested by Purchaser.
Transfers of less than $500 or of amounts needed to meet unfulfilled
payment obligations under 2(g)(1) will not be approved.
2(n)-Use of Deposits. Notwithstanding 2(k), deposits made under
this contract may be used by Forest Service in carrying out
collection rights authorized by Claims Collection Act when Purchaser
Credit has been transferred to this contract. The use of such
deposits shall be limited to the amount of Purchaser Credit which
has been transferred and is further limited to claims arising
under the contract from which the Purchaser Credit was transferred.
193
Contract No.
A10£s-1042
Ynitod Statos Dopartment of Agriculture
4
Forost Sorvico
AGREEMEN. .O MODIFY CONTRACT
(Timber Sale)
ie It is mutually agreed that the above designated timber sale contract, signed by
L, TURCOTIE, President, Ketchikan Pulp and Paper Company
Ae Bellingham : Washington Roinahiee
C, M. GRANGER Acting Chief Forest Service
called the purchaser and by ——- — [ IS
26th July 1951
the United States of America as of the _____________day of 6/as heretofore modified, be
modificd as follows:
The following changed contract sections are modified to read as shown in the following
attachment which is made a part of this agreement:
Section l(c) Section 5 Section 18 Section 35(c) Section 35(1)
Section 1(g) Section 5(a) Section 19 Section 35(d) Section 35(m)
Section 2(a) Section 6(e) Section 21(a) Section 35(e) Table Al
Section 2(f) Section 7 Section 21(b) Section 35(£) Table A2
Section 2( 7) Section: 8 Section 26 Section 35(g) Table of Unit Costs
Section 2(}4) Section 9 Section 30 Section 35(h)
Section 2(k) Section 9(a) Section 35 Section 35(4)
Section 2(1) Section 10 Section 35(a) Section 35(j)
Section 4 Section 15 Section 35(b) Section 35(k)
Draw a diagonal line with pen and ink in unused portion of torm.
2. Pursuant to this mutual agreement, the purchaser hereby agrees to cut and remove timber in strict accordance with all and singular
the terms and provisions of the aforesaid contract as herein modified. A :
INAUITNIZS yo tor the partics hereto have executed this modification of contract as of the Te se aie
of. = x 1975,
7 rs STATES OF AMERICA /
‘a BO BOCAS ey ree Docc hte sn in lO Oa
q By=%! Vee <2 aie £2 pane Ghict
= es ire A ee (Signature of approving olfreet) -; : (Title) —
Two witnesses: 2/ We LS i Sais # Ws >
(ae PA VAM QL
(Name of withess) aie ay
Ketchikan Pulp Coiany ED
(Address) ere
P.O. Box 1619
tName of witness) °
Purchaser's
Ketchikan, Alaska 99901 ee
(Address)
1,4/ D.L. Finney ,certify that lam the Wico! President === 2s
NK sasy Of the corporahon named as purchaser herein; that —___ i Flanagan —s Se ee
who si,.ned this contracton behall of the purchaser, was then bat ae} ident
micah a
of said corporition: that) said) contract was duly signed) for and in Bonar of said corporation by authorty of its poverning body, and is
within the scope of its Corporate powers.
W/o The date approving Porest officer sins this torn
YI The sipnatitres snd addresses of Iwo witneyses are required it sale as toother than a corponition
Me Te contract party taco partnerstap. the syuiatures should be NYZ ¢ erpany by ohn Doe a meniber of dre fir UW contiactiny Party sd Conporition,
for of signature should be AY Z Company. by John Doe, Mravndent forotdterefiiccrar acert) aod the sealet the Corporation must be mapressed of padi ated
4/ The certificate must be Completed it the porchaaer is a corponition
Sf Wthe corporation tas ne corporite seal hat hoot shall be stated. i which case i ycrofl on adhesive seal still follow the COPOLile Hane,
bf Delete “us hetetotore modified at not applicable
CORPORATE
SEAL $i
2400 9 (3/69)
194
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
TIMBER SALE AGREEMENT
(As Modified June 6, 1956, February 9, 1957, June 19, 1964 and
October 1, 1975) j
s
SALES, R-10 Tongass
Ketchikan Pulp & Paper Co., 7/26/51
Contract No. Al0fs-1042
The parties entering into this agreement pursuant to the Act of June 4, 1897
(30 Stat. 35) as amended, and the Act of August 8, 1947 (Public 385, 80th
Congress, lst Session) are acting under the following conditions and con-
siderations: (1) the Forest Service, acting in behalf of the United States
of America, is deeply interested in encouraging and bringing about the
industrial development of Alaska; (2) the purchaser propuses to establish
a new enterprise for the utilization of forest products, including a pulp
mill, and the development of water supply with associated facilities within
the boundaries of Pulptimber Allotments E, F and G, Tongass National Forest
n Southeast Alaska; (3) both parties recognize that this pioneering under-
lt. ‘1g, involving a substantial long-term investment by the purchaser, will
be ac.companied by unusual risks due to many unknown conditions that may be
encountered at the isolated site and during operations, great distance from
markets, present day costs of establishing the necessary facilities;
(4) the Chief, Forest Service, having due regard for the interests of the
United States and for the protection of the natural resources of Alaska,
wishes to facilitate the establishment of such new industry by the purchaser
and the operation of the industry on a commercially sound and permanently
economical basis; (5) it is the policy and intention of the Forest Service
through sustained yield management of the Tongass National Forest, to afford
an opportunity to purchase supplies of timber for permanent operation of
such enterprise as is established in accordance with the terms of this
agreement for the utilization of the timber embraced in this agreement.
NOW, THEREFORE, it,is agreed as follows:
That the contract of July 26, 1951 is a sale of the timber located within
the area shown upon the maps attached to said contract, and by reference
made a part thereof, without regard to the quantity of timber thereon
except that said contract provides that if the timber available for cutting
within said area is insufficient for full scale operation until June 30, 2004
of the purchaser's pulp plants referred to in Section 1(h) of said contract
at the capacities contemplated in Section l(h) of said contract, additional
timber will be allotted by the Forest Service from pvlp timber allotments
(E), (F), and (G) of the Tongass National Forest to meet such needs of such
plants for the period ending June 30, 2004, provided tat the Forest Service
is not obligated to make available for cutting from cuch additional allot-
ments more timber than a total of 1,500,000,000 cubic feet of material
avallable for cutting from al] areas, all as set forth in said contract,
said contract being subject to all other conditions and reservations
stated therein,
Modification as of 10/01/75 in script type.
19/5
That for the purpose of determining the stumpage payments to be made
under the contract, and determining if the total quantity of timber
within the area shown on said maps equals at least 1,500,000,000 cubic
feet, and for all other contract purposes, all reference to cubic feet
in said contract shall be converted into board feet at the ratio of
5.5 board feet for each cubic foot.
Sections 2(a), 2(f), and 5(a) of the original agreement shall be
modified; Section 6 of said original agreement shall be modified;
Sections 6(a), 6(b), 6(c), 6(d), 6(e),; 6(£), 6(g) and 6(h) shall]
be added thereto; and Section 7 shall be modified, all as hereinafter
set forth.
Should any clause or provision ‘of this Modification of Agreement be
adjudicated void by any court of final resort, such decision shall
not be deemed to affect the validity of the Timber Sale Agreement of
July 26, 1951, and said agreement shall remain in full force and effect.
We further agree that if this application is approved, a certain bond
executed by us as principal on the 26th day of July 1951, and approved
by the Acting Chief, Forest Service, on the 20th day of August 1951,
‘hich was given to the United States of America to insure faithful
9liance with the terms of the aforesaid agreement, shall bind us
and our heirs, executors, administrators, successors, and assigns in
the samo --~ner as if said modification had been included in the
origina: agreement, to insure compliance with which said bond was given.
Except as modified hereby, all other provisions of the contract of
July 26, 1951, shall remain in full force and effect.
Description of Timber.--1. The Ketchikan Pulp & Paper Company, a
corporation organized and existing under the laws of the State of
Washington, having an office and principal place of business at
Bellingham, State of Washington, hereinafter called the purchaser,
hereby agrees to purchase from an area definitely designated on the
attached maps which are a Part of this agreement, within Pulptimber
Allotments E, F and G of the Tongass National Forest, at the rate or
rates and in strict conformity with all and Singular the requirements
and conditions hereinafter set forth, all timber marked or designated
for cutting by a Forest Officer, merchantable as hereinafter defined
for pulpwood, Sawlogs and other primary forest products customarily
Produced in Alaska,
Timber upon valid claims and all timber to which there exists valid
claim under contract with the Forest Service is exempted from this
Sale. The estimated amount to be cut under the methods of marking
described in Section 4 is 1,500,000 ,000 cubic feet 0: western hemlock,
Sitka spruce, western red cedar, Alaska cedar, and other species of
timber, more or less,
196
Addi-
tional
Areas
5-Year
Operating
Periods
Selection
of
Logging
Units
for
5-Year
Operating
Periods
l(a). In event the quantity of timber available for cutting within
the above described area is insufficient for full scale operation until
June 30, 2004 of the purchaser's pulp plants hereinafter mentioned at
the capacities contemplated in Section l(h) of this agreement, the
Regional Forester shall designate additional cutting areas within
Pulptimber Allotments E, F and G to meet such needs of such plants for
the period ending June 30, 2004, PROVIDED, that the Regional Forester
is not obligated to make available for cutting more than the 1,500,000 ,000
cubic feet of material covered by this agreement, and PROVIDED FURTIER,
that the Regional Forester may sell timber from time to time in such
amounts from those portions of Pulptimber Allotments E, F and G not
included in the areas hereinabove described which in his judgment are
not needed to meet the terms of this agreement, and PROVIDED FURTHER,
that inability of the United States to fulfill the obligations set out
in this paragraph because of loss of timber within any portion of Pulp-
timber Allotments E, F and G by fire, windthrow, insect or disease
epidemics shall not entitle the Purchaser to the right to cut timber
in any areas outside of Allotments E, F and G, or to any other compensatior
'(b). After an initial operating period ending June 30, 1964, opera-
‘'s under this agreement shall be divided into operating periods of
5 years beginning July 1, 1964 and at 5-year intervals thereafter.
For each such 5-year operating period, logging units will be selected
and logg:. soundaries will be determined, stumpage prices will be
redetermined and modification of this agreement may be made, all in
accordance with the terms and conditions hereinafter stated.
_— a
ie) . Not less than two years in advence of each 5-year operating
period the purchaser shall select logging units for cutting in the
ensuing 5-year period. Timber cover and topographic maps of the units
selected shall thereupon be submitted to the Regional Forester who may
require a substitution for any selected unit if he deems such action
necessary to prevent loss of rapidly deteriorating timber killed or
damaged by fire, insects or windthrow or to protect other important
National Forest interests. The location of the unit boundaries and
of the lines of any interspersed patches of log-grade or poorly
accessible timber, as drawn by the purchaser to exclude material he
considers economically unoperable during the ensuing 5-year period,
shall be subject to review and adjustment by the Regional Forester.
Not Less than one year in advance of each five-year operating pertod
the Regional Forester will notify purchaser of tentative dectsion
on acceptability of units selected for cutting in the ensuing five-
vear operating period. Should at any time during the life of this
agreement, a fire of major proportion, a serious windstorm, extremely
damaging insect or disease attacks, or other catastrophe of great
moment, befall the timber included in this agreement, the Regional
Forester may require substitution of the logging units to be cut during
the then current 5-year operating period and require the purchaser to
readjust his current logging activities for the purpose of salvaging
such killed or injured timber.
Sa te ae ne ee ee oe SS Oe ee
197
l(d). The Regional Forester will not reguire cutting of timber stands
on any logging unit even though previously selected for such period
nor require modifications of this agreement under the provision of
Section 2(e) which will result in average delivered costs of logs to
the purchaser's pulp mill, as determined by the Regional Forester which
would place the purchaser in a disadvantageous position with respect
to similar enterprises in the Puget Sound region: PROVIDED, that for
the initial and two subsequent operating periods ending June 30, 1974
the weighted average estimated costs of pulp logs delivered at the
purchaser's pulp plant, including stumpage and payments under Section 2(f),
Separately for each operating period, shall not be higher than a
percentage to be determined as hereinafter stated of the weighted
average delivered costs at manufacturing plant of hemlock logs of
Similar quality purchased by mills of the Puget Sound region, which
percentage shall be determined by the Regional Forester as being
equitable to keep the purchaser's operation in a competitive position
with similar enterprises located in the Puget Sound region, but said
percentage shall not be less than 50 nor more than 75; and PROVIDED
FURTHER, that for the initial operating period ending June 30, 1964
said percentage is fixed at 60.
Unless changes are made by mutual consent of the Regional Forester
and the ~"rchaser, logging Operations during the initial operating
period eiu..g June 30, 1964, shall be conducted on the areas shown
on the attached maps and designated "Logging Units for Operation for
the Operating Period ending June 30, 1964."
If the purchaser believes that any unit or part thereof laid out for
logging during the initial operating period ending June 30, 1964 or
during any ensuing 5-year period does not possess the characteristics
necessary to fulfill the above mentioned provisions as to log costs,
he shall be entitled on request to the Secretary, in connection with
an appeal under Section 25 of this agreement, to have any such unit
Or part thereof inspected by a board of three qualified logging oper-
ators-or logging engineers, of which one member shall be selected
by the purchaser, one by the Secretary, and the third by the other
two members. The board shall submit to the Secretary its recommendations
of any substitution in the units selected for logging or any changes
in the location of unit boundaries or of the lines of interspersed
patches of unoperable timber which it deems necessary to bring the
log costs in line as closely as possible with the intention expressed
in this subsection, which recommendation will be considered by the
Secretary.
J(e). The Regional Forester may grant the use of timber from portions
Timber of the sale area to others than the purchaser for local ultimate use In
for Southeast Alaska to the extent of not more than two percent of the
Local estimated total stand in any logging unit, if in the judgment of the
Use Regional Forester, the operations of the Purchaser will not be materially
interfered with thereby.
198
Reservationsl(f). The Regional Forester may reserve from cutting strips and
for Scenic
Purposes
and
Salmon
Protection
Elpoec
blocks of timber having special scenic value in connection with water
courses, recreation sites and highways, or strips or blocks which
cannot be logged without causing substantial harm to salmon streams
or lakes.
1(g). Veneer logs, sawlogs, pulplogs, cordwood and other primary
forest products shall not be transported for manufacture outside
the State of Alaska without consent of ‘the Regional Forester, but
such consent will not be withheld for the export of such products
RESTR [CtION having special value so long as in the opinion of the Regional
voant
Con
Construction
Pollution
Control
Initial
Rates
Forester competitive markets for such special products do not exist
within Alaska.
1(h). Prior to July 1, 1954 the purchaser or interests with which
he is affiliated, shall install at some point within the boundaries
of Pulptimber Allotments E, F and G as shown on attached map, a pulp
manufacturing plant with a designed capacity of not less than 300 tons
per day and may be increased to 525 tons per day by not later than
July 1, 1964. Prior to July 1, 1952, the purchaser shall make a
‘‘isfactory showing to the Regional Forester that the principal items
of i.uchinery and equipment for such plant have been placed on order
with manufacturers. Failure of the purchaser to make the showing
or to ins: ** the plant, as provided for above, shall render this
agreement subject to cancellation in the discretion of the Chief,
Forest Service hereinafter called the Chief; PROVIDED, however, if
in the judgment of the Chief the failure to make the showing or to
complete the plant has been caused by an act or acts of an agent
of the United States or by other circumstances beyond the control
of the Purchaser, and if the purchaser has exercised due diligence
in trying to meet the conditions specified, the Chief shall grant
a reasonable extension of time within which to meet these conditions,
but financial inability shall not be considered to be a circumstance
beyond the control of the purchaser.
1(i). °* The purchaser shall make such showing as may be required by
the Chief, Forest Service, in respect to adequate measure for con-
trol of disposal of plant effluents in the design, processing methods,
and operation of the pulp plant described in Section l(h) of this
agreement.
2(a) Payments. The purchaser hereby agrees to pay to the Treasurer
of the United States, or such other depository or officer as shall
hereinafter be designated, to be placed to the credit of the United
States, for the timber at the following rates for stumpage:
199
Spee ape >
ee ae
e
i
-
a ee
iy tbr howl
ne ke:
ERM BOSOM.
ioe ee
(ey
ws
Adjusted
Rates
For all timber scaled or measured after date of this amendment and
prior to July 1, 1964, at the following rates:
$1.99 per M board feet for spruce ‘logs
$1.57 per M board feet for hemlock logs
$1.50 per M board feet for cedar logs
$2.00 per M board feet for logs of other species,
1.5 cents per linear foot. for piling or poles
95 feet in length.
1.0 cents per linear foot for piling or poles
95 feet and under in length.
PROVIDED, that timber which has been assembled into completed rafts
and which has not yet been scaled on the date reappraised rates go
into effect, shall be marked or otherwise identified and shall be
charged for when scaled at the rates in effect the day before the
reappraised rates become effective...
M. ‘al unmerchantable on account of defect (net scale in percent
of gress scale) as hereinafter defined may be removed without charge
in the discretion of the Regional Forester. Material unmerchantablLe
because of 4-nte as heretnagter defined, removed at the option of the
Purchaser, may be removed without change at the discretion of the
Regional Forester.
For all timber scaled or measured during the period beginning July 1,
1964, and ending June 30, 1969, and for all timber scaled or measured
within each succeeding 5-year period thereafter, at such rates as
shall be designated by the Chief in advance of the beginning of each
period to apply during the period.
Z¢b)). The Chief shall before July 1, 1964, and before July 1 of
each fifth year thereafter during the time this agreement remains
in force, make a reappraisal and designate the rates per unit of
measures that shall be paid by the purchaser for the several classes
of material scaled or measured during the 5-year period next
following each such date.
The stumpage rates fixed as the result of such reappraisals shall be
equitable to the purchaser in comparison with the rates on other
pulpwood sales on the Tongass National Forest and sha!l be consistent
with the provisions of Section l(d) of this agreement,
If the purchaser believes that the stumpage rates designated by the
Chief under the provisions of Sections 2(b) and 2(c) of this agree-
ment do not conform with the purposes and intentions of said Sections,
he shall be entitled on request to the Secretary, in connection with
an appeal under Section 25 of this agreement, to have such rates
200
Eme rgency
Reap-
praisals
Minimum
Adjusted
Rates.
Cont ‘act
Modi Ji-
cations
reviewed by a board of three qualified logging operators or logging —
engineers of which one member shall be selected by the purchaser,
one by the Secretary, and the third by the other two members. The |
board shall submit to the Secretary its regommendation of any changes
in the designated stumpage rates which it deems to be necessary to
make said rates conform with the purposes and intentions of said
Sections, which recommendations will be considered by the Secretary. |
At least 60 days before each date for adjustment of stumpage rates
the Regional Forester shall notify the purchaser of the reappraised
rates and contract modifications which he has tentatively decided
to recommend to the Chief and shall invite the purchaser to make
any presentations desired. The recommendation of the Regional Forester
to the Chief shall be accompanied by the purchaser's presentations
on any matters on which agreement has not been reached.
2CC)is Upon receipt of a written application from the purchaser whe:
it is shown that because of substantial changes in market or other
economic conditions since the last reappraisal, current rates are
‘nreasonably high, the Chief of the Forest Service in his discretion
L. -edetermine and establish the stumpage rates and designate a date
when the rates as redetermined shall be effective, which date shall —
be the earliest practicable and in any event within six (6) months
of the dat +f application.
Any stumpage rates redetermined upon application to the Chief shall
be determined in accordance with the method and under the terms
above set forth, and shall apply only during the remainder of the
5-year period then current.
2¢d):< In no event, hewever, shall the stumpage rates for products ©
from material the utilization of which is required by this agreement —
as established at the beginning of any 5-year period, or upon appJi-
cation from the purchaser, be less than the rates named in the adver-
tisement through which the timber covered by this agreement was offered
for sale.
2(e). © Subject to the provisions of Section 1(d) of this agreement, —
it is further agreed that at the date for any adjustment of stumpage ©
rates the Chief may require such modification in the Sections numbered
2(f£), 2(€g), 4, 5(€a), 6, 7, 9, 12, 13, 14, 15, 16 and 17 in thilsvapmece
ment as are necessary, in his judgment, to protect the interests of the
United States. Such modifications shall be limited to requirements
that apply or are to be made applicable to the then current pulptimber
sale contracts in Southeastern Alaska. Any additional operating costs
entailed by such modifications shall be taken into cor: ideration as a
factor in reappraisals. :
201
Deposit
for
Stand
Im
provement
2(f). Payments for required deposits for Sale Area Bettewunent are
included in the nates established for stumpage.
2(g). For all timber included in this coittract for which stumpage
payments and required deposits have not been made in full by deposit
with bid, payments shall be made in accordance with (1) or (2) as
follows:
(1). Payments for stumpage and for required deposits shall be
made in advance of cutting as called for by the Forest Service
and, unless otherwise provided herein the amount requested at
any one time shall be not less than Twenty Four Thousand Dollars
($24,000), except that just before the completion of the sale
or before a period when cutting operations are to be suspended
for at least three (3) months, such amount may be reduced by the
Forest Service. If advance payment is not received within fifteen
(15) days of request therefor or if at any time the advance
balance is reduced to Eight Thousand Dollars ($8,000), the
Forest Service may suspend all or any part of the operations
under this contract until the requested payment is received.
The purchaser shall not be required to have an advance balance
of more than Seventy Two Thousand Dollars ($72,000) at any time.
(2). Payment for stumpage and required deposits may be made
subsequent to cutting if the purchaser furnishes an acceptable
bond in an adequate amount as detewnined by the Forest Service
guaranteeing payment for such stumpage and required deposits, or
in lieu thereof deposits in a Federal depository through the
Regional Fiscal Agent negotiable securities of the United States
having a face value in like amount of dollars and accompanied by
a power of attorney and agreement authorizing the bond-approving
officer to sell or collect such securities if payment is not made
within fifteen (15) days of request thereof, provided that the
timber cut in advance of payment under this authority shall not
exceed in contract price for stumpage and required deposits the
amount of the bond or deposited securities. Provided, that if
the rate of cutting is temporarily increased, timber in excess of
the bond amount may be cut if the purchaser makes deposit of
cash to cover the estimated value of such timber and required
deposit. Such bond or deposited securities shall for such pur-
pose be in lieu of the regular bond, cash deposit or negotiable
securities given to guarantee performance of the contract. When
such advance cutting is done, payments shall be made as called
for by the Forest Service in amounts equal to the contract price
of the timber scaled, and the required deposits due, subsequent
to that for which the last payments were made: sROVIDED, That
if at any time payment is not received within fifteen (15) days
of request therefor the Forest Service may suspend all or any
part of the operations under this contract until payments of
the contract price of all timber cut but not paid for, and the
202
required deposits due, are received, and may take such action
as is necessary to collect such payments from the surcty under
the bond or by sale or collection of the securities guaranteeing
payments. In the event the purchaser fails to make payment and
collection is obtained from the security or from the sale of
collection of the deposited securities, the Forest Service may
thereafter at its election require the purchaser to make pay-
ments in advance of cutting.
2(h). Payments for liquidated damages, pursuant to Sections 11 and
12, shall be made when requested by the Forest Service.
2(i). The Forest Service is hereby authorized by the purchaser to
make transfers currently of balances on deposit between the separate
accounts for stumpage, liquidated damages, and sale area betterment,
whenever necessary to avoid deficits in individual accounts.
2(f). Cooperative Deposits. On a basis of cooperation on assistance
(16 USC 572) and by a written agreement, Forest Service shall perforn
LE on portions of the work which purchaser is obligated to pergonm
urbe this contract, as well as fwurish other services in connection
UZth activities under tis contract. When Forest Service 1s to per-
forwn such work, purchaser shall make one on mone deposits to cover
the esturated cost of said work. On request of purchaser, Forest
Service snuck render monthly accounts as may be specified in such
agreement,
2(k). Use of Deposits. Forest Service shall receive and apply
deposits made under Section 2(j4) only to meet purchaser's obligations
under this contract, unless othewise authorized by purchaser.
2(£). Purchaser Credit. "Purchaser Credit" is a credit earned by
purchaser's construction of Specified Roads, bridges and other trans-
portation facilities, and 44 computed and recorded as provided an
35(f). "Purchaser Credit Linit" is the maximum anount of such credit
which shakl be recognized hereunder and shall never exeeed the Listed
totak estimated cost, based on survey and design of project segments
4n A2, attached heretd, which may be adjusted pursuant to 2(b), 2(c),
$5(6), 35le),. 351d), 3514); 35(g)s 351i) ands $5(4).
In addition "Purchaser Credit Limit" shake be further Limited to the
total value of the difference between cwmrent contract rates and
minimun adjusted nates as established in accordance with Section 2(d)
as applied to the renaining volwne of timber to be seated on the
sale area,
"Effective Purchaser Credit" means unused Purchaser Credit which
does’ not exceed cwrrent stumpage rate value minus infndmum adjusted
nate value.
203
,
4
|
7
(
J
"Minimum Adjusted Rate Vatue" is the sum of the products of mindnun
adjusted nates and estimated volume by species of cut but unsealed
timber. Effective Purchaser Credit shall be considered equivalent
to cash for advanced deposits Limcted to the prohibition on using
Purchaser Credit for minimwn adjusted nate charges.
Purchaser Credit earned but not credited in one 5-year operating
period will be credited in subsequent 5-year operating pertod:.
3(a). Period of Contract. The purchaser may begin the cutting
and removal of timber after the execution and approval of this
agreement and shall begin such operations not later than the date
of completion of the initial installation of the purchaser's pulp
manufacturing plant, as specified in Section l1(h) hereof, and
unless extension of time is granted, all timber which the purchaser
is obligated hereunder to cut and remove shall be cut and removed
and the requirements of this agreement satisfied on or before
June 30, 2004; PROVIDED, that the purchaser's rights shall not extend
to the timber on any logging unit on which operations have not been
started on June 30, 2004.
3(b) Unless such amounts are reduced in writing by the Regional Forester,
at least three-fourths of the pulpwood requirements of the pulp manu-
Periodic facturing plant and other processing facilities operated in connection
Cuts with this Sale shall be cut from the areas covered by this agreement
during the period prior to July 1, 1964, and during each 5-year period
subsequent to that date.
Ie) Unless such amounts are changed in writing by the Regional Forester,
the annual average amount of pulptimber or its equivalent in all forms of
material to be cut and removed from such areas during the period beginning
July 1 of the year following completion of the said pulp mill and ending
June 30, 1964, shall be a minimum of 5,000,000 cubic feet and a maximum
of 35,000,000 cubic feet and for each successive 5-year operating period
thereafter; PROVIDED, that if the pulp manufacturing plant mentioned in
Section 1(h) hereof shall have been installed and if in the judgment of
the Chief the purchaser shall have exercised due diligence in his logging
operations, but, because of some act or acts of an agent of the United
States or because of other circumstances beyond his control is unable
to cut the minimum amount of timber from the sale area or areas required
by the terms of this section, the Regional Forester shall reduce the
amount to be cut from that specified heretofore in this section to the
amount actually cut.
4, Marking. Timber shall be designated for cutting as follows:
The exterior boundaries of each logging unit to be ct by the purchaser
Designation shall be marked on the cround by the Forest Service in advance of the
of Start of logging operations on the unit. All single seed trees and
_. Timber groups of seed trees selected by the Forest Officer in charge, timber
~~~" on recreation sites and strips and blocks of timber along thoroughfares,
10
204
Pefinition
of
Merchant-
able Tree
Definition
of
Merchant-
able Log
streams, and Lakes to be held intact, and interspersed patches of timber
within the logging unit which are classed as unmerchantable or in-
accessible shall be plainly marked for reservation from cutting and such
marking shall be done sufficiently in advance so as not to interfere with
or delay cutting by the purchaser. Within the areas to be thus delineated
and subject to exceptions set forth in this section, all Live trees
merchantable as defined in Section 5, and cull Live trees over 15 feet
4n height and 12 inches DBH, are to be cut, and the purchaser shall
remove all merchantable materntal from the sale area. PROVIDED, that
not more than ten percent (10%) of the merchantable volume on the
area to be cut over may be reserved for seed trees; and PROVIDED FURTHER,
that subject to the provisions of Section 1(d) of this agreement,
the Regional Forester may designate areas for cutting by tree selection,
on other methods, to promote growth, obtain salvage or to protect scenic
areas where tractor oA other methods of Logging are feasible.
5. Merchantability Standards. Definition of Merchantable Tree and
Product:
MINIMUM SPECIFICATIONS - ALL SPECIES
i Product Units: : : Diameter inside : Net Scale in
DBH : Per Tree : Length ; bark at small : % of Gross
Inches : Number 2 Feet) 7 end — Inches : Sales
12 : 1 log : 12 : 6 : 33-1/3
5(a). All logs are merchantable which are not less than 12 feet long,
at least 6 inches in diameter inside bark at the small end, and after
deductions for defect contain a net scale of at least 33-1/3 percent
of their gross scale.
6. Scaling. Material shall be so handled by the purchaser that it
can be scaled or measured economically by the methods in general use
by the Forest Service in Alaska, and the Forest Service shall so direct
the work of such scaling or measuring that it will hinder or delay
the operations of the putchaser as little as practicable under these
methods. The term "scaling" as used herein, may include scaling by
log rule, measuring, linear measuring, counting, weighing, tree
measuring before felling, or any other mutually satisfactory method
of volume determination. Unless other methods of scaling are mutually
agreed to in writing in advance, timber included in this sale will be
scaled as set forth herein.
Title to all timber included in this agreement shall remain in the
United States until it was been paid for, felled and scaled or measured.
6(a). All logs shall be scaled by the Scribner Decimal C log Rule,
in accordance with the Forest Service rules for scaling logs in the
Pacific Northwest Region and Alaska.
3):
205
6(b). Material presented for measurement as piling or poles shall
de measured in linear fect.
6(c). Any pulpwood cut in the form of cbrdwood instead of in logs,
Shall be measured in cords of 128 cubic feet of stacked wood, and
the number of cords converted into board feet at the ratio of one
cord equaling 500 board feet unless or until as the result of actual
measurements, the Regional Forester and the purchaser shall have
agreed on the use of some other ratio.
6(d). By mutual agreement in writing between the purchaser and the
Regional Forester the scale of logs may be determined by a designated
scaling bureau, PROVIDED, that either the Company or the Forest Service
reserves the right to check-scale the work of scaling bureau scalers
and when such check-scales show a variance in scale in excess of plus
or minus 5 percent, either party may request the designated scaling
bureau to make a rescale if logs are being scaled in assembled rafts
or a check-scale in all other cases; the parties agree to accept the
Bureau's rescale volume as the final volume for such Gatti nOE Gartes),
whenever the Bureau's rescale volume shows a variance in excess of
p'«S or minus 5 percent.
Determination of scale by the Bureau may be for all or part of timber
cut and nay be terminated by the Regional Forester whenever services
rendered are deemed unsatisfactory, or by the purchaser at any time
after thirty (30) days notice in writing to the Regional Torester.
During the period agreement to use Bureau scaling is in force, scaling
Shall be performed at places acceptable to the Bureau and the Forest
Service. The purchaser agrees to cooperate with the Forest Service
in providing conditions Satisfactory for making check-scales by a
Forest Service check-scaler, and to hold designated rafts containing
National Forest logs for rescaling or check-scaling by the Bureau
whenever a Forest Service scale of said raft indicates a variance in
excess of 5 percent from the Original Bureau scale. Methods customarily
employed by the Scaling Bureau may be used to signify the completion
of scaling in lieu of stamping by the Forest Service.
6(e). All logs cut under this agreement shall be branded with a log
brand registered with the State of Afaska, or shall be otherwise plainly
marked in such manner as directed by the Forest Service for easy identi-
fication and shall not be removed from the place agreed upon for scaling
until scaling has been completed. Any log brand assigned to logs of
this sale area will not be used on logs from any other sale area or
on logs from any area in other ownership until such brand has been
released in writing by the Forest Service.
12
206
6(f). Log rafts shall be identified in a manner satisfactory to
the Forest Service and the purchaser or his subcontractors shall
execute log raft receipt forms, or provide other records as required
by the Forest Service to account for log rafts in transit or
storage.
6(g). The purchaser agrees to provide the Forest Service at
approximately monthly intervals, statements showing the identi-
fication, and location of log rafts in storage or in transit and
log rafts which have been consumed by the mill during that period.
6(h). When scaling is performed at locations other than on the
sale area, the purchaser shall be responsible for loss of logs
from the time of removal from the sale area until scaled, and
unless any resultant loss as determined by the Forest Service in-
volves small amounts and is justified by existing conditions, lost
logs shall be paid for at the current price including stumpage and
special deposits. Determination of volume and species for any
gach log losses shall be made by applying the average net volume
Peh log and percentage species distribution as determined by the
Fokest Service to be equitable.
Ti. MaxiMux Scaling Length. The maximum scaling length of logs
Scaling shall be 4U feet; greater lengths will be scaled as two or more
Length logs. There shall be allowed for trimming not more than 12 inches
for logs 40 feet and under in length and not more than 2 dneches
for each additional 10 feet in length.
8. Logging. As far as may be deemed necessary for the protection
of National Forest interests, the plan of logging operations on each
of the logging units of this sale area or areas shall be approved by th
Forest Officer in charge. When operations are begun on any logging
unit, the cutting on that unit shall be completed to the satisfaction
of the Forest Officer in charge before the logging equipment is
removed from the unit, unless a suspension of operations on and the
temporary removal of logging equipment from the unit are authorized
in writing; PROVIDED, that such authorization will be granted for
suitable periods of time on any area and in any season having con-
ditions which substantially impede or preclude logging operations
or when necessary to permit the purchaser to obtain a suitable assort- ©
ment of ‘log sizes for efficient use of his plant facilities. After ,
decision in writing by the Forest Officer in charge that the purchaser
has complied with thc contract requirements as to specified units,
the purchaser shall not be required to do additional work on such
units.
13
207
9. Except as provided in Section 2(g), no timber shall be cut until
No cutting paid for, nor removed from place or places agreed upon for scaling
Before until scaled or measured by a Forest Officer. The purchaser shall
Payment cut all designated live trees, and shall remove all merchantable
material from the sale area. No undesignated live trees shall be cut
except those trees unmerchantable because of small size which occur
within established cutting areas not designated for tree selection
may be cut and removed at the option of the purchaser. The cutting
and removal of dead trees shall be optional with the purchaser except
as such cutting may be required by the Forest Officer in charge for
fire protection and safety.
9(a). The foklowing dead timber shall be felled concurrently with
Logging operations: ALL dead trees over 15 feet in height and
over 12 Anches in diameter breast height inside the exterior boundaries
of cutting untts.
10. The methods of logging used by the purchaser, including high
Logging Jead and skidder logging, shall be such as will permit of leaving
Metnods unjnjured the seed trees and groups of seed trees provided for in
Section 4 of this agreement. No unnecessary damage shall be done
te young growth or to trees left standing. Undesignated trees which
are badly damaged in logging shall be cut if required by the Forest
Officer in charge.
Purchaser's operations shall be conducted reasonably to minimize
04k enosien. Equipment shall not be operated when ground conditions
ane Such that excessive damage will result. The kinds and intensity
Of erosion control work shake be kept cwurent immediately preceding
expected seasonal periods of precipitation or runogs.
Mave On those portions of the sale area on which felling has been
or is being done, marked or designated trees left uncut, and unmarked
or undesignated teees which contain merchantable material and which
are cut, injured through carelessness, or killed by fires which the
purchaser, his employees, contractors, or employees of contractors
caused, or the origin or spread of which he or they could have
prevented unless such cutting, injury or killing involves small
amounts of material and in the judgment of the Forest Officer in
charge is justified by existing conditions, shall be paid for at
double the current price including stumpage and special deposits
except slash disposal deposits fixed by the terms of this agreement,
for the class of material said trees contain: PROVIDED, that such
payment shall not release the purchaser from liability for any damage
to the United States other than the value of said trees. ‘Timber
wasted in tops, marked er designated timber broken by careless felling,
and any other timber merchantable according to the terms of this
agreement, which is cut and not removed from any portion of the cutting
area when operations on such portion are completed, or before this
14
208
Stump
Height
Top
Diameters
Slash
Disposal
agreement expires or is otherwise terminated unless such wastage or
nonremoval involves small amounts of material and in the judgment o
the Forest Officer is justified by existing conditions, shall be paid
such material. The amounts herein specified shall be regarded as
liquidated damages. Unless extension of time is granted by the Forest
Supervisor the right, title, and interest to any timber for which pay
removed from any portion of the sale area accepted by the Forest Offi
in charge within the six months next succeeding the date of such
acceptance, or from the remainder of the sale area during the same —
number of months next succeeding the date of expiration or termination
of this agreement. a
12, Stumps shall be cut so as to cause the least practicable waste
and not higher than twenty-four (24) inches on the side adjacent to
the highest ground for all trees with a diameter of twenty-four (24)
inches and under at a point 4-1/2 feet from the ground, and for lar;
trees the height of the stump on the side adjacent to the highest
gfound shall not exceed the diameter of the tree at the point of
cutls.ig, except when this requirement is impracticable in the judgment
of the Forest Officer he may authorize. and accept higher stumps: 4
PROVIDED, tka & all stumps which are not cue in accordance herewith q
than 24" in diameter and $0.25 per stump for all stumps 24" and ee
in diameter. Such payment shall be regarded as liquidated damages
in view of the difficulty of determining the actual damage to the
United States through wastage of the quantity and quality of the
material involved.
13. All trees shall be utilized to as low a diameter in the tops |
as practicable and to a minimum diameter of six (6) inches when q
merchantable. The log lengths shall be varied so as to secure the ©
greatest possible utilization of merchantable material.
14. Slash Disposal. The Regional Forester may require that all
tops shall be lopped and all brush scattered so as to lie close to ~
the ground and away from standing trees and clumps of reproduction,
or any other methods of disposal the estimated cost of which shall —
not be in excess of this method.
J5. Fire Precautions. During the time that this agreement remains
in force, the purchaser shall both independently and (n cooperation —
with the Forest Service do all in his power to prevent and suppress |
forest fires on and within the vicinity of the sale area, and shall
require his employees, contractors, and employees of contractors to-
do likewise. Unless prevented by circumstances over which he has —
no control, the purchaser shall place his employees, contractors,
15
209 *
and employees of contractors at the disposal of any authorized
Forest Officer for the purpose of fighting forest fires on or
within the general vicinity of the sale areas, with the under-
standing that unless the fire-fighting seryices are rendered on
the areas embraced in this agreement or on adjacent areas within
one mile, payment for such services shall be made by the United
States at rates to be determined by the Forest Supervisor, which
rates shall not be less than the current rates of pay prevailing
in the said National Forest for services of a similar character;
PROVIDED, that the maximum expenditure for frre fighting without
Aenwneration in any calendar year wrll depend upon the following
type of fire:
(a) Operation frre. An operations fire 446 a fire originating
dn the sale area caused without negligence or fault in purchaser's
operations. The purchaser's operations include activities or use of
equipment of purchaser, his employees, agents, contractors, sub-
contractors, thecr employees or agents, acting in the course of
their employment in operations hereunder (unless acting under the
nmediate supervision of the Forest Service, as in skash disposak) .
Mtknum expenditures to the purchaser for this type fire will be
$1u,.J0 per operations fire.
(b) YNegligently caused fires. The cost of suppressing fires
caused by negligence or fault in the purchaser's operations shall
be borne bu purchaser. Such fires shall include but not be Limited
to those resulting fom smoking by perso engaged in purchaser's
operations hereunder during the course of their employment, on
NEAL or Lunch periods.
(c) Other fires. For services by purchaser at the request of
Forest Service on any fire other than an operations fire or a pire
caused by negkigence or fault in purchaser's operations, Forest
Service shall pay purchaser at nates for fire fighting common <n
the area.
And, PROVIDED FURTHER, that except in grave emergencies such employees
of the’ purchaser who are needed to prevent unnecessary damage to the
purchaser's plant from sudden shut-down will not be called for fire-
fighting services.
16. Except in serious emergencies as determined by the Forest
Release Supervisor, the purchaser shall not be required to furnish more
of Fire than 100 men for fighting fires outside of the area above specified
Fighters and any employees furnished shall be relieved from fire fighting
on such outside areas as soon as it is practicable for the Forest
Supervisor to obtain other labor adequate for the procection of
the National Forest,
16
210
Fire
Prevention
and
Suppression
Logging
Improvements
Con
struction
Timber
Sanitation
1 a The purchaser shall abide by all such further rules a
for the prevention and suppression of fire on sale areas and
logging camps and logging operations as may be currently rec
the Regional Forester of logging operators’ working on the same
Division of the Tongass National Forest and using comparable logging
methods. facilities, and equipment. os
18, Occupancy and Improvements. The purchaser is authorized
build on National Forest land plants, camps, roads, and other
provements necessary in the logging or manufacturing of the
included in this agreement: (It is contemplated that the pur
will obtain patent to the site for his main plant under suitabl
acts permitting the patenting of public lands and that permanent
town-sites will be excluded from the National Forest.) PROVIDED,
that all such structures and improvements as shall be located
operated subject to such regulations as may be deemed necessar
the Regional Forester for the protection of National Forest int
PROVIDED FURTHER, that the Forest Officer in charge may require be
construction work is undertaken for any structures intended for
eR occupancy of labor outside of the main plant site and incor- |
phokrted towns, that plans for such structures shall be submitted |
to him for approval in writing including such reasonable requi
as he deems necessary as to their design, adequacy and locati
continuante or operation of such improvements on National Forest |
after the need for them in connection with purchaser's operatio
has terminated shall be subject to authorization by permit or e
ment under United States laws, and unless such authorization is
secured all improvements not removed shall become the propert
the United States at the expiration of six months from the te 1
ation of their actual use in connection with the purchaser's operé
under this agreement.
19. Construction Timber. Purchaser is authorized to cut and ;
for constuction, without charge, construction timber designate
by agreement> zi
Trees ‘and products meeting Utilization Standards used as puncheor
conduroy, or otherwise buried in roadway fiLL shall not be cons.
construction timber without charge unless authorized cn wrcting |
Forest Service.
20. The purchaser shall keep all logging camps, mills, and ot
structures used in connection with this sale and the ground ti
vicinity, in a clean sanitary condition, and rubbish shall be remo
and burned or buried. When camps or other establishments are mo
from one location to another or abandoned, the purchaser sha
or otherwise effectively dispose of all debris and abandoned
Al] camp buildings and structures used {in connection with this
shall be located and operated as may be required by the Fores:
in charge to prevent the pollution of the water in any strea
toilets, and garbage pits shall be constructed and maintal
prevent, so far as Ls posalble, the breeding, of files or
opment of unsanitary conditlous,
a
21
21(a) Salmon Protection. Purchaser's operations shall not be per-
mitted to interfere with the passage of salmon to their spawning
Other grounds or to injure the spawning grounds in any way. Any logging
Conditions debris accidentally or necessarily thrown into any stream used by
salmon shall be removed therefrom as soon as practicable and in any
event before the logging equipment is moved from that portion of the
sale area,
21(b) Bald Eagle Protection. In compliance with the "Bald Eagle
Act" of June &, 1940 (16 USC 668), and Subject to Forest Service
policy exceptions, purchaser shall not cut 4nees, oh aneas, desig-
nated by the Forest Service as containing an eagle nest, and will
not willfully molest on disturb any American bald eagke, nest, on
eggs thereof.
22, The purchaser agrees to exert every reasonable effort to obtain
the installation of a well balanced forest products industry for
erated utilization of the various kinds of primary forest products developed
Utijization for CuEtIng in the salle’ area. Tt dis contemplated that provision
will be made for such processing of primary forest products as is
proven feasible and desirable in connection with other comparable
ful P and paper manufacturing enterprises in Alaska, but the purchaser
She. not be obligated to make any plant installation or contractural
arrangement which would impair the efficient supply of pulptimber
to his pulp enterprise. :
738} SO)far as itjis\ practicable) todo so labor for the conduct of
Local logging operations, mills, and manufacturing plants conducted by
Labor the purchaser, its affiliates, subsidiaries, or contractors within
Pulptimber Allotments E, F, and G will be recruited from residents
of Southeast Alaska.
24, At all times when logging Operations are in progress the pur-
chaser shall have in Alaska a representative in general charge of
Purchaser's such operations, who shall be authorized to receive, on behalf of
Repre- the purchaser, any or all notices and instructions in regard to work
sentative under this agreement given by Forest Officers, and to take such
action thereon as is required by the terms of this agreement. On
each logging operation, or group of operations placing logs in the
water at points not more than 5 miles apart, the purchaser shall have
on the ground a representative who will be authorized to receive
and to take the required action on any and all notices and instructions
Siven him, under the terms of this agreement, by the Forest Officer
in charge.
Bi Complaints by the purchaser as to any action taken by a Forest
Complaints Officer respecting this agreement shall not be considered unless made
by in writing within sixty 60) days of such action to the Forest Officer
Purchaser having jurisdiction. ‘The decision of the Secretary of Agriculture
shall be final in the interpretation of the regulations and provisions
governing the sale, cutting, and removal of the timber covered by this
agreement,
18
Zale
Suspension
of
Operations
Inspection
of
Keceurds
"Officer
in
Charge"
Defined
Act of
March 4,
1909
Anti
discrim-
ination
26. The Regional Forester, or hts delegated representative, shall
notify the purchaser in writing of any violation of the terms of th
agreement on any logging unit or units within the sale area and allow |
a reasonable and definite period of time to comply with such terms, _
If satisfactory compliance is not made within the time allowed, theme
Regional Forester may suspend, by notice in writing or other means of
transmitting written messages, all operations, including the remova
of scaled or measured timber, on such unit or units, such suspensio
to continue in effect until the purchaser complies with such terms
in a manner satisfactory to the Regional Torester. i
27. All records pertaining to the purchaser's logging operations ©
in Alaska, including the production and sale of all primary forest
products, shall be open to inspection at any time by a qualified
logging engineer or accountant employed by the Forest Service and —
designated by the Regional Forester to make such inspection with |
the understanding that the information obtained shall be regarded
as confidential. During the period from January 1 to July 1, 1964,
and for similar periods at subsequent 5-year intervals all records
centage rate specified in Section 1(d) of this agreement.
28. The term "Officer in Charge" whenever used in this agreement _
by the proper Forest Supervisor to supervise the timber operations
in this sale. a
29. No member of or Delegate to Congress, or Resident Commissioner,
shall be admitted to any share or part of this contract or to any —
benefit that may arise therefrom, but this provision shall not be Ee
construed to extend to this contract if made with a corporation for
its general*benefit. (41 U.S.C. Sec. 22, and 18 U.S.C. Sec. 199) am
any employee oA applicant for employment because of nace, color,
aeligtion, sex, or national origin. Purchaser will, in all soliet-
tations or advertisements for employees placed by or on behalé of
purchaser, state that all qualified applicants will neeeive cun-
sideration for employment without regard to nace, color, neligcon, |
ex, on national origin, (Executive Onder No. 11246, on September
24, 1965, as amended by Executive Order Nu. 11375 of October 13,1
19.
213 ss
a
Prelimli-
ary
Award
Authority
to
Modify
31. This agreement may be transferred to the successor in interest
of the purchaser provided the transferee is acceptable to the United
States as a purchaser of timber under the conditions and requirements
then in effect for similar timber sales and provided the transfer is
approved by the Forest Officer who approved this agreement, or by his
successor. authorized deputy, or superior officer.
SV This agreement is entered into in accordance with the public
sale of the timber described herein on August 2, 1948, and the pre-
liminary award granted purchaser on said date including extensions
thereof and modification as stated herein.
33% The conditions of the sale are completely set forth in this
agreement, and none of its terms can be varied or modified except
in writing by the Forest Officer approving the agreement, or his
successor or superior officer, and in accordance with the regula-
tions of the Secretary of Agriculture.
34. And as a further guarantee of a faithful performance of the
conditions of this agreement, the purchaser delivers herewith a
hond in the sum of fifty thousand dollars ($50,000) to cover the
°riod prior to July 1, 1964, and further agrees to deliver to
t... *egional Forester at least ten days before June 30, 1964, the
date the bond delivered herewith is to expire, and likewise at least
ten days before the date of expiration of any other bond hereafter
delivered _.. connection with the sale a new bond in such sum, and
under such conditions as the Regional Forester may require, but
not to exceed $50,000 in amount. The purchaser further agrees that
upon failure on his part to fulfill all and singular the conditions
and requirements herein set forth or made a part hereof, all moneys
paid under this agreement may be retained by the United States to
be applied to the satisfaction of his obligations assumed hereunder
without prejudice whatever to any other rights and remedies of the
United States. The purchaser further agrees that should the sureties
on the bond delivered herewith or on any other bond delivered here-
after in connection with this sale become unsatisfactory to the
Officer approving this agreement or his successor, the purchaser
shall within thirty (30) days of receipt of demand furnish a new
bond with sureties satisfactory to the approving officer.
35. Transportation Facilrities and Authorization. In accordance
with Section 18, purchaser is authorized to construct and maintain
noads, bridges, and other transportation facilities, as needed for
harwesting timber included in this contract, on National Forest
and odhiern Lands where Forest Service has such authority. As used
in this contract "construct" dictudes "reconstruct".
35(a). Location and construction vf such Specified Roads shatl be
4n accordance with 35(b). Unless otheuise provided herecn, con-
struction may be progressive diring this contract. Maintenance shale
be governed by specification 53, Road Macnitenaiee, as es tablashed
by dhe Regional Forester and Section 18. The tucatéion and clearing
widths of att Temporary Roads on facikitivs shall be agreed to be~
hore. construction <s started, "Temponmiy Roads" ave roads other
than Specified Roads which ane cons ducted by purchasen fon the
purpose of harvesting ténber dnceluded in this contract.
214
35(b). Speergied Roads. -"Specified Roads" are roads, inckuding
related transportation facilities and appurtenances, shown on 5-
year operating pertod map and Listed tn Table Al, attached hereto
and made a pant herneog for which purchaser shall be given purchaser
eredit when constructed. Purchaser shall construct Specigied Roads
used under this contract. Construction initiated by purchaser on
any Such Spectfied Road shall be completed to an agreed terminus
that meets purchaser's needs and prevents unnecessary injury to
National Forest resources. The construction to such terminus shall
be in full accordance with plans, Specifications, designs, and
drawings developed under 35(c), and the regulations as established
by the Regional Forester pursuant to Section 18, except for agreed
adjustments needed to accommodate such terminus. The cost, as
estimated by Forest Service for the portion constructed, shake be
Sepanateky recorded as a segment tn a nevised Table A2.
A Temporary Road shall not be constructed substantially on the
Location for a Specified Road, except by agreement.
In event of agreed addition on deletion of those roads shown on 5-
Year operating period map and Listed in Table Al, a revised table
designated Al-1, Al-2, etc., shall supersede any prior table as Al
wher 4t 48 dated and signed by purchaser and Forest Supervisor.
Tn event oF agreed substitution or revision of construction design,
Specifications, on pergsormance responsibility under contract Secticns
35(c), 35(h), and 35(x4), a revised table designated A2-1, A2-2,
etc., shell supersede any prtor table as A2 when it 45 dated and
6igned by purchaser and Forest Supervisor.
35(c). Engineering. Survey and design for Specified Roads shall
be performed by the Forest Service unless othewiUse specrsied rn
Al. Survey, design, and construction staking of Specrgied Reads to
be engineered by purchaser shall be performed by purchaser in
accondance with specifications supplied by the Regtonal Forester.
Based upon the quantities developed by such design as approved by
the Forest Service, the estimated costs and Purchaser Credit Lamct
stated in A2 shall be revised by the Forest Service.
On those roads for which the design 44 completed by Forest Service,
the design quantities shall be used as the basc¢s for revising
edtimated costs and Purchaser Credit Limct stated cn A2.
The methods of computing such revised costs shall be consuftent
with the methods that would have been used had the engcneercig been
performed prion to the beginning of the 5-year operating percod.
On on before January 1 of each year, at the time of submésscon of
the annual Logging plan, the purachasern wikk fuwirdsh the Forest
Service with a tentative schedule for those roads to be constructed
for the following year's Logaing operations. 16 the purchaser
proposes a change tn the construction schedule that results cr Less
than one year lead time for survey -and desiqn, the purchaser shall
be responsible for the suwey and design unless otheuecse agreed.
gy! Revised vaae 7/15/75
25
35(d). Estimated Costs. Estimated costs by constuction phases
for specific roads to be constructed during each 5-year operating
period are stated by segments in A2. Such, costs are subject to
revision under 2(b), 2(c), 35(b), 35(c), 3516), 351g), 35(g), 35(h),
and 35(x).
Appropriately adjusted 204ts shall be made a part of a revised A2
which will be designated A2-1, A2-2, ete. The revised A2 shake
Supersede any prior A2 herein when it-4s dated and signed by pur-
chaser and Forest Supervisor.
35(e). Difference in Rock Costs. 14 there is advance written
agreement on changes in source, average haul mileage, type, or
dimensions shown on drawings, affecting cost estimates for em-
bankment rock from "designated sources", surface rock, or rock
nipnap, A2 will be revised to reflect these changes. Forest Service
will prepare nevised cost estimate which will be the sun of:
(1) unct rates consistent with the Table of Unit Costs times the
rstimated quantities used in computation of cost estimates in the
"At necent AZ, (2) unit rates in current use tones the amounts
by whtch the revised quantity estimates exceed estimated quantities
used to compute the most recent A2, (3) the estimated cost of any
development work perfouned at specified sources abandoned as un-
satis fact..y, at rates consistent with the Table of Unit Costs in
effect at the time the work was done.
35(f). Digference in Culvert Installation. 1 the actual approved
amount, s4ze or type of culvert or drainage accessories installed
hereunder differ from those estimated in drawings and specifications
under 35(b), the Table of Unit Costs shall be revised to reflect
these changes and appropriate changes made to A2. The revised cost
estimate will be prepared by Forest Service and will be the sum Ch:
(L) unit rates in the current Table of (nit Costs tines the nevised
estamated amounts for those sizes or types Listed in the Table of
Untt Costs, and (2) unit rates in current use tones the racvised
a outa amounts of 44zes or types not Listed in the Table of Unit
os%s.-"
35(g). Cost Adjustment for Physical Change. The estimated costs
an A2 shall be revised if prion to acceptance, a major plysceal
change, caused by a single event and not due to neglrgence of pur-
chaser, results in additional work by purchaser cnvolvaig an addi-
tional estinated cost of more than $3,000. Such costs shatt in-
clude the cumulative estinated costs of hepacr(ng damage from slides
washouts, Landslips, fire, ete., caused by said event.
Pravings and specif<ceations shall be revised when necessary to
meet the naw conditions. Such racvised drawings and speechceatcons,
together with the catimated cost of work abandoned, shall be the
hasit for nevised cost estimates,
22
216
The difference in estimated quantities for the portion of the road
affected by physical change shark be detewntned by Forest Service
by comparing the most recent previous quantity estounates wrth the
total of quantity estimates for construction perforuned prcor to
physical change plus quantity estimates for construction to be per-
founed following physccak change. Where the quantity dcfference
an dnerease, Such inerease times the cwurent unit rate shakk constitute
the inerease in cost estimate to be added to A2. When the quantcty
difference 45 a decrease, such decrease times the nate on nates used
dn prepartng the most recent previous cost estimate for the road
portion shall constitute the decrease tn cost estumate to be sub-
Atnacted from A2.
35(h). Design Change. Tf purchaser and Forest Service agree in
writing on a design change, appropriate and related changes shall
be made in drawings and (unigonn and/or poe ene eta) spect fications
and estimated costs shall be revised to neglect such design change.
A design change is a change of other than a minor nature in Location;
noad cross Section; quantities of unsuctable on excess material to be
“emoved; on structures, other than culverts, described tn draucigs
' spect{ications. Changes of a minor nature are those such as
Ai accnement nomnakly considered as necessary to maintain eartluork
quantities substantially as designed. The dcfference in estinated
quantiti: ‘2 the portion of the road affected by each design change
shall be determined by Forest Service by comparing the most recent
previous quantity estunates with the totak of quantity estonates for
the proposed design change, plus quantity estimates for construction
performed but abandoned because of design change. Where the quantcty
difference 44 an Anerease, such increase tunes the current unt rate
Shall consitute the increase in cost estimate to be added to A2.
Where the quantity difference 4s a decrease, such decrease times
the nate or nates used in preparing the most necent previous cost
estimate for the noad portion shakl constitute the decrease <h cost
estimate to be subtracted from A2, A2 shall be revised penodicatly
to racglect the total change in cost resulting fom design changes
effected during the pertod. 14 a design enange requined adjus dnents
an nock costs or culvert installation such adjustments wil be made
4n accordance with 35(e) or 35(4).
35(4). Alternate Facilities. 14, during the 5-year operating
period, roads needed for the nemoval of timber included cn thes
contract differ substantiatly from surveyed and des(gned Speecgced
Roads, other roads may be added to Al. The road nouting, Location,
design, and needed easements shat be such as will make other roads
arceptable as parts of the National Forest transportatcon system,
Survey, descgn, and construction staking for such other rnvads shall
be provided by purchaser,
23
207
Based on design quantities from such engineering, Fonest Service
shall estimate construction costs of alternate facilities Us 411g
methods consistent with those used in the orginal comructation —
0f A2. Purchaser Credit Limit for acceptable alternate facilities
shall not exceed the estimated costs of facilities based on survey
and design estimates, Listed in A2 which purchaser does not con-
Struct except that Purchaser Credit Limit may be adjusted as
desceribed in 35(b), 35(c), 35(d), 3516), 35(g), and 35(h).
35(f). Purchaser Credit Computation. Forest Service shall make
tonely estimates of purchaser's progress in Spectfied Road con-
struction. On the basis of such progress estimates and the cost
estemates in A2, Forest Serwice shall credit purchaser's Timber
Sale Account each month as such work proceeds. Materials gwurrcshed
and delivered by purchaser shall be included in estunatiiig work
POGNLSS .
Such crediting of purchaser's Timber Sale Account shall be at
95 percent of the estimate of cost of work accomplished until
the project segment Listed in A2 is accepted as completed or is
“andoned under 35(4). At such time, purchaser's timber sale
a. ut shakl receive full credit up to Purchaser Credit Limct.
35(k). Control of Erosion After Logging. After Logging operations
have been completed on any unit of the sale area, necessary work
to prevent undue erosion on all noads shall be pergoruned by the
purchaser as follows:
(1). On noads that are not to be kept on a pewnanent bas i,
obliteration shakk be in accordance with Section 18 (and
such regulations as estabLished by the Regional Forester) .
(2). On Specified Roads, al work necessary to restore
culverts, ditches, and other diainage structures to standard
agreed on for that road in accordance with Section 35(b).
(3). On cut and file slopes, waste and Spork areas susceptible
to enosion on on along roads and skid tnails com tructed or
used by the purchaser, purchaser shall nevegetate all such
areas by seeding with grass. Revegetation work may énclude
fertilization.
35(£). Use of Partially Constructed Road. Portions of Specified
Roads shatk be Substantiatey Completed prior to their use fOr
hauling timber from each established Landing, except that pur-
chaser may be relieved in wri ting of this rcquireme.t 46 there
As justification under exas ting conditions. When necessary tu
fackkitate construction and protect bridges and nvads from damage ,
Aimben felled in construction and limber logged directly to the
noad from areas Ammediateky adjacent there ty may be hauled be fore
24
218
noad construction 44 Substantially Completed. Such hauling sharl
be confined to periods when abnormal sort, erosion and damage to
National Forest Lands will not result,
"Substantialtky Completed" means completion of grading and in-
stallation of drainage strwcetures 50 they will function efsectively.
Unless agreed othewise, specified rcconstrmction shall be completed
on any portion of road prtor to hauling on that portion.
35(m). Designated Sources. Those sources of Local matertak shown
on the drawings and deseribed in the pit development plans are
"Designated Sources". ALL other sources shall be considered unde-
Aignated, The Forest Service assumes responsibility for the quakcty
and quantity of material in the Designated Source. It 44 agreed
that it 45 not feasible to determine from samples the Limct for
an entire deposrt, and that variations in materials shall be con-
sidered as usuak and are to be expected.
. surchaser shakk utilize the material in the Designated Source
tu 1.2 fullest extent possible. Should the "Designated Source",
due to causes beyond the control of the purchaser, contain in-
Augficie: .cceptable material, the Forest Service shall provide
another source with an equitable adjustnent in accordance with 35(e).
The purchaser shakl promptly and before such conditions are disturbed,
notify the Forest Service of the unsuctabi(lity of the "Designated
Source".
25
219
Signed in triplicate this Ll day of ht Pa ey AID.
(Corporate Seal) Zs a & ag
BY. . .
Witnesses:
Approved at Washing ae es » under the
abor conditions, Nw (Aol OS > 19S \.;
rx Acting Chief, Forest =e
220
OPERATING GUIDELINES
FOR TIMBER SALE
LAYOUT
KPC LONG-TERM CONTRACT
4979 — 19:84
OPERATING PERIOD
Recommended By: oe mee -4 PLILLZO
Timber Program Manager. ate
Forest Supervisor
Approved By:
221.
10) EBs
VII.
TABLE of CONTENTS
Meu MEN Li ete seherer etexehstaye. aiaye Ria) atte) aie. aie shal aioitia Soles Bie aici klewic
RECLEALAON te. aware aatihes clonic ste Ne
sileioleleisisieieieleia levee 3
Vesial eRe sounces ce dee eae
Dishie).e/.e) ese enalielapene ini (a\(s,(8lieie1 6) 1 eo. el/ever a) Lk
Log Transfer and Raft SE OMAR wratailcrarerepeias<ipysin ver wviasiaiarer ee 2
Soil and Watershed
OIC OCS TOSChC POCO iO) 0 DEO CC DONC CHOIEND Conn Ge
Pele BME eres a oes ote eer he fl )6 a 55) 0h: a, SeageyAinks falstors easier te crinine al O)
222
TIMBER
The timber management objectives are:
Develop and maintain healthy, vigorous commercial forests by
harvesting overmature and decadent stands prior to the harvest
of younger stands of timber.
--Establish and maintain a balanced distribution of age classes
by area and productive capability.
--Use regeneration systems which will result in adequate natural
regeneration.
--Enhance the quality and quantity of timber production by rotatior
age.
--Achieve and maintain optimum productivity in all managed stands
by:
a. Minimizing adverse impacts from diseases.
b. Obtaining and maintaining optimum stocking in stands
that are under rotation age through cultural treatment.
Coxe Reduce forest losses from insects to levels commensur-
ate with resource values involved.
The transportation system will be planned to harvest all the
commercial forest. land in the given area, even though all CFL areas
will not be harvested by one entry. The only roads that will be
built will be those that are needed to harvest the approved units.
Logging systems used must be compatible with silvicultural and
other resource objectives.
Even-aged management by clearcutting will be the preferred system
for regeneration of the hemlock-Sitka spruce type.
Uncut. stands of commercial timber will be planned so they are
suitable for subsequent commercial logging.
Windfirmness will be a major consideration in unit boundary
location.
(1)
223
Factors to consider when planning entries adjacent to existing
cutover areas are:
uke Effect of new logging activities on reproduction in
existing cutover area.
"de Visual impact of new clearcut in combination with existing
clearcut. In areas of high visual sensitivity previous
cutting areas should be "greened up" before second entry
planned.
3. Attainment of a balanced distribution of age classes
of good and poor sites.
4, Soundness of stump anchors in adjacent clearcut.
Dis The impact on wildlife in key habitat areas.
The time range for these factors can vary from five to fifty
years depending on specific site conditions. Therefore, when-
ever clearcutting is planned adjacent to less than pole-sized
timber the reasons will be documented in the E.A.R. or E.I.S.
For additional information refer to FSM 2471 R-10 Supplement
#126.
(2)
224
RECREATION
There is a wide variety of existing and potential recreational opportun-
ities which make up the recreation resource of the KPC sale area. Much
of the Ketchikan Pulp Company long-term sale lies within the Prince of
Wales Planning Unit and is covered by Management Units of the Tongass
Land Use Plan. Generally the recreation guidelines contained in this
document give direction for protection of this resource.
Additional direction is:
1.
Each recreation cabin and inventoried cabin site will be identified
on the visual resource management overlay. The landscape architect
will analyze each cabin and assign landscape management units
commensurate with the appropriate sensitivity level.
Provide access free of logging debris along those lakes and streams
identified on the 1" = 1 mile recreation overlay.
Proposed roads which will be retained for public travel should be
located so they provide the user with a varied and interesting ex-
perience.
Where appropriated funds are available, provide overnight parking
along roads which will remain open to public travel.
Known historical and archeological sites are identified on the
overlays and will be protected in accordance with the Antiquities
Act and its related legislation and Executive Orders.
Plan activities so that anchorages identified on overlays are not
exposed to the wind.
Sensitive areas such as streamsides, lakeshores, saltwater shore-
lines, and roadsides identified on visual resource overlays will be
managed in accordance with landscape management units assigned to
them.
(3)
225
FISH STREAM HABITAT
The following are operating guidelines for timber harvest planning
involving fish streams in the sale area. Guides to minimize sedimen-
tation are covered in the Watershed Requirements.
ie
When laying out units adjacent to designated fish streams
use the stream as a yarding divide to prevent damage to
streambank and introduction of debris into stream.
Where necessary to yard across a designated fish stream, logs
must be fully suspended to protect streambanks and streambank
vegetation.
Locate and design roads to eliminate the introduction of
construction debris into fish streams.
Streams not shown on the overlays or in the Alaska Department
of Fish & Game catalog but which are affected in any way by
logging or construction activities should be reported to the
Area Biologist with information of fish species, whether adult
or juvenile, water temperature, and date of observations. Such
streams will receive the protection outlined in these guidelines.
Drainage structures will be lccated and installed to minimize
impact on all resources. All bridges will be designed to
prevent spillage of road material into the stream. Culverts
on designated fish streams will be designed to insure fish
passage at normal streamflows. Normal flow will be based on
a flow duration analysis and defined as those flows which
occur between 10 and 80 percent of the time on the duration
curve.
Roads and rock pits will be located and designed to minimize
introduction of silt and other impacts to streams.
Streams will not be diverted from their natural channel to
accommodate road location without recommendations of the area
hydrologist and fishery biologist and approval of the Forest
Supervisor.
Temperature-sensitive streams are identified on the overlays
and have the following requirements for timber harvest along
their banks:
a. No more than 25 percent of the streamside overstory
canopy should be removed in the initial entry.
(5).
226
Where timber is harvested near streambanks, no more
than 20 chains adjacent to the streams should be
cut on the N, NE, E, and SE side of the stream and
10 chains on the S,SW, W and NW side.
Protect the brush and understory, including shrub
trees, adjacent to the stream during timber harvest
operations.
Normally, streams shown on the overlays require
tree cover to provide necessary shading from direct
sunlight; however, streams not shown on the base
Maps or overlays, but which are tributaries to
streams in the above category, generally are small
and may be shaded adequately by streamside brush,
grass, or high banks (topographic shading). In
these cases it may not be necessary to avoid cutting
of timber adjacent to these streams as outlined in
guideline "b" above.
(6)
227
Log Transfer Sites and Raft Storage Areas i/
Those people responsible for selecting transfer sites, booming
grounds, and log storage areas should try to:
le Maximize the distance between the mouths and intertidal
channels of anadromous fish streams and the sites.
De Maximize the distance between tide flats and subtidal beds of
aquatic vegetation and the sites.
Se Use the steepest shores having the least intertidal and
subtidal zone.
Other objectives relate to the reduction of certain activities in
conjunction with transfer sites. These objectives include efforts
to:
i Minimize disturbance of the shoreline as a result of clearing,
road building, and other activities that might produce silt or
otherwise disrupt the estudrine environment.
7B Minimize storage time for rafted logs before transport to the
mill.
S15 Minimize the number of active transfer sites and log storage
areas in any given bay or bay complex.
4. Minimize the filling of intertidal and subtidal areas for the
construction of log transfer sites, fuel transfer facilities,
equipment loading ramps, etc.
Dis Minimize the use of intertidal areas as a source of borrow.
6. Minimize interference with other established uses such as
commercial and sport fishing, hunting and anchorages for
commercial and recreational boats.
With regard to impact on fishery resources in general, selecting
the following alternatives will probably serve to minimize adverse
effects:
1 Whenever pos-ible locate sites outside bays, along straits and
channels.
(7)
228
Ya Locate transfer sites in deep bays rather than in shallow
bays. Select bays without sills or other natural restrictions
to tidal exchange.
Be Locate transfer sites near mouths of bays rather than at heads
of bays unless the environment at the mouth of the particular
bay in question has some special significance.
4. Use the deepest water possible for booming grounds and log
raft storage areas.
5% Select sites that accommodate future timber development without
requiring continual relocation.
If a choice must be made, protect fishery resources in the order of
their importance. For example, protecting anadromous fish runs and
streams has a higher priority than protecting clams and clam beds,
because salmon are more important economically at this time. Such
trade-offs may change from time to time as local and regional needs
change. Usually, when conflicts arise that require trade-offs between
fishery resources, decisions regardimg resource values should be soli-
cited from biologists after an on-site examination of the particular
situation.
1/ Log transfer and Storage Area Guidelines are adopted from:
Department of Commerce
National Oceanic and Atmospheric Administration
~ National Marine Fisheries
Juneau, Alaska
(8)
229
“a
SOILS AND WATERSHED
To maintain soil productivity and lessen sediments to streams from
yarding activities, soil disturbance should not exceed 30 percent.
Exposed bare mineral soil or rock should not exceed 10 percent of a
unit, and these areas must be small, scattered, and discontinuous
sites which are separated from live stream or river channels by
areas with undisturbed surface organic matter layers. The other 20
percent disturbance may consist of a mulch condition which could
include a mixture of organic and mineral horizons or a mixture of
organic horizons.
Units, regardless of soil types, may not be selected for tractor
yarding unless field review shows that the maximum ground dis-
turbance in recommendation one will not be exceeded. Approved
units may not exceed 10 percent slope gradients.
To maintain soil cover and minimize slope failure, partial or full
suspension should be obtained when yarding downhill on slopes
between 60 and 75 percent (31 to 37 degrees).
On slopes 67 percent or greater, an investigation will be made by
the watershed, soils, or materials specialists to determine feasi-
bility of logging. If logging is approved on slopes 75 percent or
greater, full suspension will be required for nearly the entire
length of the external yarding distance. See FSM 2470.
When logging units, where V-notches are present, adhere to the
recommendations and hazard ratings in the paper titled: The
Development of a V-notch Classification System for Southeastern
Alaska, to minimize soil disturbance and mass soil movement.
(9)
230
WILDLIFE
The following guidelines are primarily for protection or enhancement
of deer winter range and are based on a series of wildlife overlays
in the Ketchikan Area Wildlife Atlas available at the Ketchikan
Area Office. ;
Black - These are areas that have been heavily cut. Emphasize thinning
in the second growth, but no clearcutting will be allowed in
the remaining old growth during the 1979-84 operating period.
Red --Significant wildlife areas such as
--specific key winter deer range
--escape cover along salmon stream
--estuarine areas for waterfowl, big game,
furbearers, and nongame species _
--small islands under 50 acres
Any activity within these areas during the 1979-84 operating
period will be designed to maintain or improve wildlife
habitat. Such activity will be based on recommendations of
the Forest Service biologist.
Blue - Beach areas adjacent to F4 ecosystems are considered to be
the best potential winter range for deer in southeast Alaska
under average winter conditicns.
1. Beach zone is one-quarter mile deep.
26 No clearcut should cover more than one-eighth mile width
of the beach zone defined above or extend completely to
the beach, Generally, a 100-200 foot buffer is required
between the clearcut and the beach. Guidelines to minimize
blowdown should be applied. Distances between cuts should
be at least one-half mile unless salvage needs dictate
otherwise.
Green - Beach areas adjacent to Fl ecosystems:
1. Beach zone is one-quarter mile deep.
Zi. No clearcut should cover more than one-quarter mile
width of the beach zone defined above or extend
completely to the beach. Generally, a 100-200 foot
buffer is required between the cuiearcut and the beach.
Guidelines to minimize blowdown should be applied.
Distances between cuts should be at least one-half
mile unless salvage needs dictate otherwise.
(10)
231
Remaining (uncolored) - Beach front areas of general but unknown
wildlife importance.
ibe Clearcut size should be as small as practical.
Average size should be 25 acres.
Ze Leave areas should be as large as adjacent cutover
areas.
Other wildlife requirement not necessarily species oriented
Ibs On catalogued salmon streams, no more than 25 percent of the
streamside timber will be harvested along the first one-half
mile of the stream from saltwater.
Pe Beaver ponds need protection by limiting cutting to removal of
maximum of one-half shoreline for each entry.
Si Some importance has been given to protection of the borders of
muskegs, possibly by leaving a strip of timber. Protection of
these borders should be a standard practice in areas of few
muskegs. The result will be more diversified habitat with
increased edge within a given area.
4. Eagle nest trees, regardless of whether currently active, are
to be protected. Roads, cutting or other disturbance activities
will be kept a minimum of five chains away to insure a windfirm
stand around the nest. Refer to FSM 2613.0la R10 Supplement
#26 and FSM 2633 Supplement #14.
De Existing camps and facilities should be utilized where practi-
cable, and new developments in high wildlife use areas should
be avoided.
(Oe Roads should be located to minimize conflicts with high
wildlife use areas and should be routed outside deferred
cutting areas where practicable.
(11)
2377,
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ty
INCE OF WA
ISLAND
5
SAN JUAN.
BAUTISTA ISLAND
EXISTING LOGGING CAMPS
LEGEND
PROPOSED LOGGING CAMPS
TOWNS AND VILLAGES
EXISTING HARVEST UNIT
EXISTING ROAD SYSTEM
PROPOSED HARVEST UNIT
PROPOSED ROAD SYSTEM
SALE BOUNDARY
LOG TRANSFER SITE
ROADLESS AREA
ALTERNATIVE
The Louisiana-Pacific Corporation,
Ketchikan Division,
Timber Sale Plan for 1979 - 84
Final Environmental Statement
Tongass National Forest
INCE OF WALES
~ ISLAND
REVILLAGIGEDO ISLAND
SAN JUAN
BAUTISTA ISLAND
LEGEND
EXISTING LOGGING CAMPS
PROPOSED LOGGING CAMPS Sarre.
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PROPOSED HARVEST UNIT
PROPOSED ROAD SYSTEM
SALE BOUNDARY
LOG TRANSFER SITE
ROADLESS AREA
ALTERNATIVE 3
The Louisiana-Pacific Corporation,
Ketchikan Division,
Timber Sale Plan for 1979 - 84
Final Environmental Statement
Tongass National Forest
PRINCE OF WALES
ISLAND
REVILLAGIGEDO ISLAND
SAN JUAN
BAUTISTA ISLAND
LEGEND
EXISTING LOGGING CAMPS (
PROPOSED LOGGING CAMPS e A
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LOG TRANSFER SITE
ROADLESS AREA
ALTERNATIVE 4
The Louisiana-Pacific Corporation,
Ketchikan Division,
Timber Sale Plan for 1979 - 84
Final Environmental Statement
Tongass National Forest
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EXISTING ROAD SYSTEM 7
PROPOSED HARVEST UNIT
PROPOSED ROAD SYSTEM
SALE BOUNDARY
LOG TRANSFER SITE
ROADLESS AREA
ALTERNATIVE 5
The Louisiana- Pacific Corporation,
Ketchikan Division,
Timber Sale Plan for 1979 - 84
Final Environmental Statement
Tongass National Forest
ee i,
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