Defenders Submit Comments on Central Tongass Plan

North Kupreanof. Photo: Colin Arisman

North Kupreanof. Photo: Colin Arisman

In September 2019, the Alaska Rainforest Defenders submitted comments on the Central Tongass Project Draft Environmental Impact Statement to request that the USFS cease planning on this destructive project. Click below to download the full comment with citations, or read on for the introduction to our comments.

The Forest Service’s proposed action would remove 150 million board feet (MMBF) of old-growth timber and 80 MMBF of immature recovering forests (“young growth”) over the next fifteen years. The agency would then construct/reconstruct 175 miles of temporary and permanent system road, adding to the economic and ecological cost of the project.

These levels of timber extraction are unreasonable, particularly in light of the damaged ecological condition of Alexander Archipelago islands in central southeast Alaska. Further, the proposed volume – purportedly intended for local employment and local sawmills – is at best bizarre and at worst a blatant lie since there is no timber industry in southeast Alaska operating at even a small fraction of the proposed scale of the timber sale. This project continues the trend of mismanaging public old-growth forests around Petersburg and Wrangell as a subsidized federal timber colony that provides high value cedar to Viking Lumber’s de facto parent corporation in Washington state or other Pacific Rim wood processors far outside the region. The Forest Service would then manage its maturing second-growth forests as a plantation for some other out-of-state timber broker, delaying watershed recovery and permanently eliminating habitat for wildlife.

There has long been a concern for deer on many central southeast Alaska islands, particularly in the Petersburg Ranger District portion of the project area. The Forest Service authorized Viking Lumber to destroy much of the best remaining publicly owned winter deer habitat on Lindenberg Peninsula through the recent Tonka project. Additional clearcuts on Kuiu, Kupreanof or Mitkof Islands could cause local wildlife extirpations and force survivors into isolated patches of lower quality habitat.

There have been recent (2016 - 2018) severe declines in pink salmon harvests in Alaska Department of Fish and Game (ADF & G) regulatory districts in central southeast Alaska. In 2016 the pink salmon fishery was a disaster and in 2018 returns were far worse.4 ADF&G anticipated another weak harvest in 2019 of 18 million fish which slightly exceeded expectations with a total harvest of 19. million fish.5 However, northern southeast Alaska inside waters – the Central Tongass Project Area – yielded even poorer returns than expected and ADF&G closed these areas to seiners for most of the season.

These declines make it essential for the Forest Service to consider whether the need to provide aquatic habitat for fishery resources used by hundreds of local fishermen and processors should take priority over the interests of distant raw log exporters whose economic “contributions” to the region are negative given the massive public cost of the federal timber program. The Forest Service and other timber agencies have logged watersheds in the Wrangell and Petersburg Ranger Districts so intensively that less half of the project area watersheds provide intact salmon spawning and rearing habitat.

A Taxpayers for Common Sense analysis using Forest Service budget data calculated that the Petersburg and Wrangell Ranger Districts would have been responsible for a $89 million taxpayer loss had they fully implemented the recent Wrangell Island, Navy (Etolin Island) and Mitkof Island timber sales, which would have removed roughly 113 MMBF of federal timber. Taxpayers for Common Sense also calculated that implementation of Tongass Advisory Committee’s 2016 Forest Plan Amendment timber sales will generate taxpayer losses of $367.5 million over the next fifteen years. The Central Tongass Project will be the second largest timber sale program implemented pursuant to the Tongass Advisory Committee’s plan. The District Rangers for the Petersburg and Wrangell ranger districts as Responsible Officials will thus be Responsible for throwing away a significant portion of this staggering loss – as much as $172.5 million to support timber sales of 230 million board feet in two communities that lack any sizable timber industry. Forest Service reports indicate that the two island communities together processed 40 thousand board feet of federal timber in 2016.

Defenders acknowledges that the DEIS suggests a broad program that would include non-timber resource uses. But those materials also show that the Forest Service has allocated funding only for the timber component of the project or for project components that benefit plantation forestry such as thinning. All recreation components of the project require outside funding, private investment or volunteer efforts.

Defenders acknowledge that one of the Forest Service’s two primary timber sale program beneficiaries operates a small mill. But that operator, Viking Lumber, sends all of the high value timber – cedar, to its de facto (literally and operationally) “parent” corporation in Washington State. As a matter of business, Viking Lumber is primarily a timber exporter and it is reasonable to assume its primary interest in Central Tongass Project timber will be to high-grade high-value yellow cedar to send down south to Daddy.

This project is thus, in reality, a traditional timber sale with the administrative planning and other resources and infrastructure subsidies allocated for the purpose of providing Viking Lumber and an international timber broker with a long-term supply of a quarter billion board feet of federal old-growth and second-growth timber. The rest is fake news. Even if the Forest Service would mitigate some of the harm caused by its past and present mismanagement of southeast Alaska’s public lands, the adverse impacts of further federal logging will more than offset any small improvements in fish or wildlife habitat. Industrial activities associated with the removal of remaining old-growth forest and implementation of plantation forestry for recovering second-growth forests will also render the central southeast Alaska island shorelines and interior areas undesirable or even inhospitable for visitors from the region and beyond who come for recreation – particularly sport fishing and hunting.

Defenders of course thus requests that you encourage your superiors to cease planning on this project. The Forest Service has the authority and relevant planning material under the Petersburg Ranger District’s Access and Travel Management Plan to address the most critical fish habitat improvement needs. Although investments in recreation could provide additional economic stimuli, the visitor products industry economy is thriving even in the absence of federal funding.