Greater Southeast Alaska Conservation Community PO Box 6064

Sitka, Alaska 99835 !August 29, 2015 !SENT VIA EMAIL TO: comments-alaska-tongass-petersburg@fs.fed.us !Jason Anderson, District Ranger USDA Forest Service, Petersburg Ranger District PO Box 1328 12 North Nordic Drive Petersburg, AK 99833 !re. East Ohmer Creek Restoration Project !Dear Mr. Anderson, !Thank you for the opportunity to comment on the East Ohmer Creek Restoration Project. The following are scoping comments submitted by the Greater Southeast Alaska Conservation Community. These comments are timely because although the 30 day comment deadline falls on Saturday, August 29, federal regulations stipulate that if the deadline falls on a weekend, comments may be submitted the first day following the weekend day. !The Greater Southeast Alaska Conservation Community (“GSACC”) is a regional conservation non-profit corporation in Southeast Alaska. GSACC seeks to foster protection of southeast Alaska’s fish and wildlife and their habitat. GSACC’s membership uses public lands throughout southeast Alaska and the Project area for sport, commercial and subsistence fishing and hunting, professional scientific work, and a wide range of recreational activities. !The East Ohmer Creek Restoration Project proposes to implement stream and floodplain restoration on 0.6 miles of East Ohmer and Lumpy Creeks and 20 acres of associated floodplain. Approximately 8 acres of old growth would be logged and whole trees removed including roots to provide source material for the project. !I. Preliminary Concerns !GSACC generally supports genuine restoration activities on the Tongass that do not depend on the liquidation of other habitat to achieve improved conditions for the intended project. This project proposes to do just that - further diminish scarce and already fragmented old growth deer habitat on the south end of Mitkof Island in the Woodpecker area. Moreover, it is highly questionable whether perceived benefits to aquatic habitat in Ohmer Creek and its associated floodplain outweigh additional loss of deer habitat in the project area. !

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We sincerely applaud the Forest Service for the long overdue acknowledgement that past development activities have harmed Tongass habitats, including along and in the riparian habitat of a portion of East Ohmer Creek and have no doubt that this aquatic habitat has been degraded. However, given the apparent absence of serious public concern for the health of East Ohmer Creek and the associated 20 acre floodplain we are puzzled exactly what initiated your choice of this specific restoration project on the Petersburg Ranger District. This, despite the public’s overwhelming desire and the agency’s own public commitment during the 2012 Linde/Mitkof public workshops to improve aquatic habitat by repairing red pipes that impede fish passage on Mitkof Island and the Lindenberg Peninsula of Kupreanof Island. Further, this project is also proposed at a time when there already exists a backlog of PRD projects that are absolutely certain to benefit aquatic habitat including red pipe repair and road maintenance and closures. We are also concerned about allocation of scarce public funds toward a project of questionable benefit when more certain benefits could accrue by simply addressing the red pipe issue along the PRD road system. !We also find this proposed action disconcerting at a time when the Mitkof Island Project is under litigation, with loss of Sitka black tailed deer habitat in the Woodpecker area being a major issue in the complaint filed by GSACC et al. The 1

cumulative impacts of yet more timber removals on deer habitat must be analyzed and disclosed. Moreover, whether the project will indeed result in overall benefits to aquatic habitat are uncertain, when the benefits of culvert repair and replacement are proven and the need is urgent. We do not understand the agency’s reluctance to prioritize these activities above one that could yield far less habitat improvement and actually would result in loss of valuable OG habitat. The East Ohmer Creek Project appears to depend on the supply of logs from four units included in the Mitkof Environmental Analysis and under contact in your Mitkof Heli Stewardship Integrated Resource Contract and if so, is a connected action that should have been evaluated 2 3

under one analysis. !Finally, we might add that the project area for the restoration project needs to be expanded to include the 8 acre cutting unit that acts as one of two sources of logs intended to supply large wood for restoration activities. !I. Purpose and Need of the Proposed Project is Unclear !It is unclear what the Purpose and Need for the project is. According to the scoping document for this proposed project [at 4], “habitat quality is declining in the restoration reaches due to past activities and would continue to decline without

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GSACC et al vs. Jason Anderson, District Ranger and Earl Stewart, Forest Supervisor. Civ. Case No. 3:15-cv-00073-1

SLG.

US Forest Service. Petersburg Ranger District. Mitkof Heli Stewardship Integrated Resource Timber Contract. 2

Mandatory stewardship work item #9, East Ohmer Creeek Restoration Project - Wood Collection & Stockpile.

CEQ Regulations at § 1508.25 define connected actions as those that are “closely related” to the proposal and 3

alternatives. Connected actions automatically trigger other actions, they cannot or will not proceed unless other actions have been taken previously or simultaneously, or they are interdependent parts of a larger action and depend on the larger action for their justification.

project implementation.” Indeed, this is true of numerous aquatic and landscape habits on Mitkof Island and across the Tongass in general. Factors that make this aquatic habitat unique, above the other numerous impaired Mitkof habitats have not been disclosed. The scoping document goes on to acknowledge that abundance of salmonid species is often closely linked to the abundance of woody debris (at p. 4), so is the goal to increase abundance of salmon? Why the Petersburg Ranger District scheduled this particular restoration project at this time is unclear. Is there an imminent threat to aquatic species or are fish returns to the watershed measurably diminished below historic levels? Is the goal to increase the return of aquatic species like salmon and trout and if so, what are the ultimate goals by species? If so, the purpose statement should include integration of measures that also would improve fish passage in the project area. We request that you provide a clear purpose and need statement. !Moreover, there is little assurance that as a consequence of restoration activities proposed in this project, greater habitat degradation would not result and similar future documents could also conclude, as this scoping letter did, that habitat quality in the East Ohmer Creek watershed is further declining in the restoration reaches due to past activities. !It seems the purpose of the project is to spend available dollars to improve salmon productivity in the Petersburg area. Therefore, the project should be considering a number of alternatives to improve aquatic habitat, including repair of red pipes and more. That is what the public should have been (an should be now) consulted on. Broader scoping should have been performed. !II. Please Reconcile the Schedule of Proposed Actions for the Project with it’s Scoping Letter. !We note that the project’s description contained in the Schedule of Proposed Actions 4

does not square with information contained in the scoping letter. For instance, the SOPA indicates that only .25 miles of East Ohmer Creek would be restored, not .6 miles as indicated in the scoping letter. Also, there is no mention of rare plants in the scoping letter, while the SOPA indicates one project purpose is “rare plants”. And, although the SOPA indicates “wildlife” as a project purpose, again there is not even one mention of wildlife in the scoping letter. If the intent is to improve conditions for wildlife, including deer, then there needs to be an analysis regarding wildlife. This analysis should compare net benefits accrued from the loss of 8 acres of valuable old growth habitat versus any perceived gains for wildlife from restoration activities. Most importantly, if habitat for deer is claimed to be improved through thinning exercises, then there must be an analysis of the purported benefits, including an acknowledgement that the benefits are minimal and temporary due to stem exclusion. Impacts to other various species also need to be analyzed and disclosed including goshawk and marten.

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USFS Petersburg Ranger District. Schedule of Proposed Actions 7/1/15-9/30/15. East Ohmer Creek Restoration 4

Project. “Project Description: Propose instream and floodplain restoration on approximately 0.25 mile of East Ohmer Creek. Construct wood structures for pool creation and cover. Perform maintenance on currently excavated rearing ponds. Project Purpose - Wildlife, Fish, Rare plants - Watershed management. Planning Status - Scoping Start 03/09/2015” http://www.fs.fed.us/sopa/components/reports/sopa-111005-2015-07.html

Finally, the SOPA indicates scoping began 3/9/15 however, we are unaware of any scoping being accomplished until the 7/27/15 scoping letter was issued. The project did not even appear in the 01/01/2015 to 03/31/2015 SOPA for the PRD. !The SOPA and scoping letter need to be reconciled with actual project activities, dates, and objectives. The public relies on the SOPA for critical project information that need to be an accurate reflection of the proposed activities. !III. Level of Analysis !There was no mention of the level of analysis your agency intends to pursue for this project. Has this factor been decided upon at this time? Due to the potential impacts of the proposed project, at a minimum an Environmental Analysis is necessary. !IV. Public Notification of Comment Deadline is Confusing and Untimely !The scoping document provides confusing and inconsistent information regarding comment deadlines and during a time most inconvenient to local interested parties who wish to participate. !

A. Comment Deadlines Are Confusing and Inconsistent Documents associated with the East Ohmer project contain conflicting and confusing information regarding the comment deadlines and to whom comments should be submitted:

If your agency truly desires public input, then there should be greater care taken to provide consistent and clear information regarding these important facts, regardless whether the legal notice for the project is the final word. This is particularly so, and a simple courtesy, to the general public who may wish to participate but is not savvy to the fact that the legal notice is the ultimate authority. In the past, we are aware that others, confused with inconsistent addresses supplied in planning documents, submitted comments to the wrong address which were consequently rejected. !

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Please take greater care to insure all public notification documents contain the same deadlines, contact information and mailing addresses. ! B. The Comment Deadline Occurs at the Busiest Time for Local Respondents. !The comment deadline for his proposed project occurs toward the end of the busy fishing and work season in Southeast Alaska and impacts those who are most likely to submit comments, but simply have little time to do so right now. Your agency’s indifference to the inability of local residents to comment during this time, is demonstrated by repeated comment deadlines that occur during times most disadvantageous to interested publics. We wonder why the rush to begin restoration activities when this creek and floodplain have been in a state of degradation for decades. Certainly project planning could wait another month to insure a better public response. We note that even the Borough of Petersburg wisely extended the draft comprehensive plan comment deadline for the exact reason cited above. 5!In view of the two above factors, we request an extension of the comment period to allow commercial fishermen and other interested individuals to effectively participate in project planning. !V. Direct Relation of the Mitkof Heli Integrated Resource Timber Contract (IRTC), Mandatory Stewardship Projects #9 to this Project and Impacts Must be 6

Disclosed and Analyzed. !Only one of two sources of logs intended for the East Ohmer Creek project was clearly identified in the scoping letter and the second was only vaguely mentioned. The first source, identified an 8 acre logging unit, approximately 12 miles out the Woodpecker NFS mainline road 6245 which would supply 130 logs. The unidentified second source, which would supply 260 logs and tree tops to be used for this project was included in a different project document, specifically, the Mitkof Heli Stewardship Integrated Resource Timber Contract (hereafter “the Contract”), a partial timber offering under the approved Mitkof Island Project EA and currently under litigation. That project area is located on Mitkof Island, approximately 12 air miles south of Petersburg, Alaska, within the boundaries of the Petersburg Ranger District of the Tongass National Forest. !The Contract includes ten mandatory and four optional stewardship projects. Twelve of the mandatory and optional projects are are labeled as “Deer Habitat Enhancement

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KFSK. July 14, 2015. http://www.kfsk.org/2015/07/14/comment-period-extended-for-petersburg-planning-5

documents/!“Shelly Wade of the consulting company Agnew Beck said the planners recognize the two draft documents were released in June at the start of Petersburg’s busy summer fishing season. A public comment period extension will give people more time to comment. “We definitely recognize that and understand that so we wanna give folks more time,” Wade said.”

USDA Forest Service. Petersburg Ranger District, Tongass National Forest Service Petersburg, Alaska . East 6

Ohmer Creek Restoration Project - Wood Collection and Stockpile, Mandatory Project #9.

Pre-Commercial Thinning projects (M1-8, and 11-14)” , one requires aggregate supply 7

for a nearby trail restoration project (M10), and the remaining mandatory project is the “Woodpile Collection and Stockpile for the East Ohmer Creek Restoration Project (M9)”. The direct relation of M9 to the newly proposed East Ohmer Creek Restoration Project was undisclosed in your scoping letter. If the substantial amount of old growth timber volume yet to be removed via this contract, is indeed intended to be used for the East Ohmer Creek Restoration Project, then its impacts must be disclosed and analyzed under one analysis. If the PRD has abandoned hopes of securing wood from this area for the restoration project, then that fact also must be made known in further analysis. That your agency dedicated timber volume from the Mitkof Island Project Heli-contract for the East Ohmer project, far in advance of any planning for it, is a classic case of putting the cart before the horse and is wasteful at best - not only in terms of habitat loss, but also the taxpayer funded cost of heli-logging old growth to be “stockpiled” for a future and uncertain project. ! A. Location of Logs Purported to be Currently Stockpiled for the Project Should be Disclosed ! Although the scoping letter discloses that, “the wood necessary to complete this project, including whole trees with rootwads still attached and cut logs, would be sourced from an 8.0 acre area, approximately 12.0 miles from Mitkof Highway along Forest Service (FS) road 6245,” there is only vague mention of the other source of logs intended to be used for the project and which are purported to be stockpiled in a nearby rockpit. Recent inspection as of about a month ago, revealed no logs 8

stockpiled at the rock pit on NFS road 6246 (also previously designated for M9 in the Contract), so we are curious exactly what stockpile you are referring to. Can you please identify the location of the existing stockpile, when the logs were placed there, from what source, and the document their removal was analyzed under? !In fact, we believe the already stockpiled wood you are referring to is currently tied up in litigation and has not yet been logged. If so, reliance upon this volume as a source of logs for the proposed project is unreliable at best and at worst could waste valuable funds in planning for a non-starter. !

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The primary intent of these thinning projects are to increase timber growth and volume. Any benefits to wildlife - aka 7

”Deer Habitat Enhancement” are incidental and transitory, a widely accepted fact by Tongass wildlife biologists. Claims to improve wildlife habitat over the long term with thinning treatments are unsupported by scientific fact. Moreover, none of the thinning projects will actually restore logging related impacts other than “release” existing trees from competition by their neighbors and presumably accelerate growth for optimal timber production and eventually more logging. Any benefits to wildlife are temporary at best. Moreover, under Forest Service timber management objectives, these thinned stands will never be allowed to attain old growth conditions favorable to wildlife.

US Forest Service. Petersburg Ranger District East Ohmer Creek Restoration Project. Scoping letter. July 27, 2015. 8

p.5. “The majority of the wood would be considered high defect, low value hemlock and would come from from an existing stockpile located in a nearby rockpit.”

The M9 Contract was completely unbeknownst to the general public, and had the bid document for the heli-contract not been coincidentally inspected it would likely have slipped by undetected. 9!Although the East Ohmer Creek Restoration Project appears on the agency’s SOPA website and scoping documents are now available, it is in a very preliminary stage of planning and far from a decision. The agency included Mandatory Project 9 - the Ohmer Creek Restoration Project - Wood Collection and Stockpile, in the Mitkof Heli Contract, far in advance of any planning for the project for the sole purpose of facilitating the East Ohmer Creek Restoration Project - a project in its early genesis at the time the IRTC was developed. It is a “connected action” since the proposed 10

project depends on this source of wood in addition to the old growth timber volume identified in the scoping letter. Its impacts should be analyzed under one environmental analysis. We discuss the relationship of M9 to the currently proposed action due to its interconnectedness, and do not believe such discussion is outside the scope of the analysis and must be considered, analyzed and included in this analysis. B. Please Disclose the Impetus to Restore East Ohmer Creek at This Time, Above Other Degraded Watersheds and Red Pipe Repair. !While we have no doubt about the degree of degradation of the creek and floodplain - a common situation on previously logged PRD and other forestwide areas, there does not appear to be prior public concern regarding the health of Ohmer Creek and its floodplain. In the absence of such concern we are puzzled with the selection of this aquatic habitat for restoration activities when there exists a backlog of dozens of red pipes on the PRD that the public has urged your agency to repair for many years and to also be in compliance with the Clean Water Act. Repair of these pipes would likely improve aquatic habitat far greater than this proposal seeks and should be included as an alternative. !Please disclose the specific chain of events that led the PRD to conclude the Creek was such a high priority for restoration and whether other aquatic habits were also considered. Also please identify the funding sources for this proposed project. Did an organization approach your agency with the promise to fund a specific aquatic restoration project on the PRD following a search for a specific watershed to restore? If so, please identify the organization, when the PRD was approached, the amount of funds attached to their proposal, and whether those funds are adequate to complete the entire project including agency time and monitoring. We also request that due to the dependence of M9 on the proposed project, the cumulative environmental impacts of M9, including full monetary costs of the project and to the taxpayer, be fully disclosed.

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As a consequence of this discovery, the need to inspect bid documents generated on the PRD has become a 9

necessity, thus our recent interest in obtaining PRD bid documents.

According to the Council on Environmental Quality regulations for implementing NEPA, "connected" actions refer to 10

actions that are closely related and therefore should be discussed in the same impact statement. Connected actions automatically trigger other actions, they cannot or will not proceed unless other actions have been taken previously or simultaneously, or they are interdependent parts of a larger action and depend on the larger action for their justification.

!Prior to July 27, 2015 no documents existed for the restoration project and according to project leader Heath Whitacre, in a June 5, 2015 email exchange , "I am currently 11

developing the project proposal. Once a proposed action is developed, I will send a scoping letter to receive project feedback from various agencies and the public.”  As implied by this communication, there were no expressed prior public or agency fishery concerns about the creek, so apparently, the impetus to restore Ohmer Creek was not a result of recent public or agency concern. !Despite there previously being no documents to support the project at the time (and therefore no figures to support log quantities and lengths required), according to the Mitkof IRTC M9 , 260 trees and tree tops are to be supplied and stockpiled for the M9 12

project [for future use] mostly in lengths up to 60 feet, the majority with minimum diameters (DBH) of 28 inches. This is a large volume of logs representing a 13

significant loss of critical habitat which those trees support. Consequently, it is questionable how the agency could make an informed decision whether the number of trees to be cut for this purpose are adequate or excess. Please disclose whether root wads are also intended to be sourced from the Mitkof EA heli-contract cutting units. C. Restoration of East Ohmer Creek Will Inappropriately Come at the Expense of Liquidation of Important Old Growth Habitat on Mitkof Island. !According to M9, the source of the logs for the project originate in Mitkof Island’s Woodpecker area, and from planned logging units described in the Mitkof Island Project Environmental Analysis (EA). An 8 acre cutting unit specified in the 7/27/15 scoping letter is also a source of volume. These logging units contain some of the best habitat remaining on the island for Sitka Black-tailed deer and it is this habitat that is in very short supply. Game Management Unit 3, which includes Mitkof Island and 14

the Lindenberg Peninsula of Kupreanof Island (Tonka Project Area) has the most

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USFS Email exchange between Heath Whitacre and Rebecca Knight. East Ohmer Creek Restoration Project. June 11

6, 2015. [The Scoping letter for the project appeared on the SOPA website July 27, 2015.]

Id. #5.12

The Mitkof Island Project “Mandatory 9” Integrated Resource Project Contract mandates old growth volume from 13

four Mitkof EA cutting units will be used as a source of material to provide stream stability under the East Ohmer Creek Restoration Project. Two hundred old growth trees and sixty old growth tree tops from these units are intended as the source of logs for this project. These trees are to be stored in a rock pit Milepost 0.131 on FS Road 6246 in anticipation of the East Ohmer Creek Restoration Project. The 200 small, medium, and large logs must have minimum diameters of 20/24/28 inches diameter at breast height, respectively and the sixty tree tops must have minimum butt diameters of 16 inches.

US Forest Service. 2002 Woodpecker Project Area Record of Decision. "Issue 1: Deer Hunting. This issue centers 14

around the popularity of the Woodpecker Project Area for deer hunting by the residents of Mitkof Island, and the concern that any timber harvest on the island will affect deer populations. Mitkof Island has traditionally been used by residents of Petersburg for subsistence deer hunting. The Woodpecker Project Area is the most heavily used part of Mitkof Island for deer hunting, due to the accessibility provided by the road system that connects to Petersburg, and the higher numbers of deer inhabiting the area. The number of deer is higher in the Woodpecker Project Area because of good forage and less snow accumulation found on the southfacing slopes near saltwater."

restrictive deer season in southeast Alaska largely due to habitat loss induced, low 15

abundance of Sitka Black-tailed deer. In fact, twelve of the thinning projects contained in the heli-contract are described as “deer habitat enhancement,” an implicit acknowledgement that deer habitat in the project area has been degraded. !Again, it is obtuse logic that perfectly good deer habitat should be liquidated, and the old growth timber which supported that habitat be used to restore Ohmer Creek. The need for this restoration project seems to be an invention of the agency in the absence of public concern over the status of the creek. This, despite there being significant concern regarding the loss of local deer habitat as well as the need for red pipe repair on Mitkof. 16!If a source of logs is required for habitat restoration on Ohmer Creek, the Forest Service could make use of the hundreds/thousands of logs on Mitkof that were left behind in older cutting units because they failed to meet industry utilization standards:

Local Wanton Waste - Tongass Old Growth !This project inappropriately depends on liquidation of already fully utilized and perfectly good, standing old growth, and provides what remains of scarce habitat on Mitkof Island for old growth dependent species including Sitka black tailed deer, marten and goshawk. Although the scoping letter indicates that the majority of the wood would be considered “high defect, low value hemlock” we find no mention of this fact in contract stipulations under M9. Will the use of Sitka spruce be prohibited for this project? Also, the so-called high defect, low value hemlock may be described as

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KFSK. Board of Game shortens deer season near Petersburg. Joe Viechnicki. January 15, 2013. http://15

www.kfsk.org/2013/01/15/board-of-game-shortens-deer-season-near-petersburg/

USDA Forest Service. Petersburg Ranger District Access and Travel Management Plan. July 2009. Table 3.2.1-1. 16

Total counts of red fish culverts by road system. [At the time of the report, six years ago there were 33 Mitkof Island NFS red pipes.]

such from a timber industry perspective, but certainly provides valuable benefits for old growth habitat for dependent species. !VI. Inconsistent Treatment of Logging Methods Between NEPA Approved Logging Plan and Mitkof Island Project Mandatory Contract M9. !It is also inconsistent that the Mitkof Project EA cutting units cards 330, 301, 316, and 312 all specify ground based cable or shovel logging, however the Contract M9 project calls for much more expensive heavy-lift, helicopter logging. There is no explanation for the inconsistency in the required logging methods between the unit cards and M9. Helicopter logging is by far more expensive than ground based systems and reportedly runs in the thousands of dollars per hour. Please explain the shift to 17

the more expensive means to yard logs from cutting units when less expensive means were mandated in the original NEPA approved unit cards for the Mitkof EA. Was the decision to use this method related to your agency’s desire to award stewardship credits for the purchaser? Please disclose the NEPA approved process that led to this significant change in logging methods as well as the rational that led to the change. !VII. Please Disclose the Impacts to Trail Users from Removal of Timber from Mitkof EA Cutting Units 330, 301, 316, and 312. !The Ohmer Creek trail is in direct proximity to and largely in full view of the cuttings units for the wood stockpile source for M9. Specific visual impacts to trail users from the cutting units 330, 301, 316, and 312 should have been analyzed and disclosed but only garnered one brief mention in the Mitkof Island Project EA. Again, consideration 18

of this important impact is not outside the scope of the planning process for the East Ohmer Creek Restoration Project, since old growth timber removals in these Mitkof EA units are slated for use in this project and are a connected action. Finally, it is obtuse reasoning that the agency would provide only brief mention of impacts to trail users and with no analysis, and nonetheless dismiss those impacts as minimal. This, at a time when your agency is performing upgrades to the trail by using very expensive helicopter transport of aggregate. With such an expensive public investment, the 19

agency must ensure that all trail attributes, including nearby scenic values are not degraded. !VIII. The Project Area Needs to be Expanded to Include the Identified “Wood Collection” Cutting Unit and It’s Old Growth Removals Must be Analyzed and Disclosed. !

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Helicopter Logging website. http://www.vannattabros.com/iron32.html [for example].17

USDA Forest Service. Petersburg Ranger District. Mitkof Island Project. Environmental Assessment, Draft Decision 18

Notice and Finding of No Significant Impact. July 2014. p.78. ”Popular recreation sights such as…Ohmer Creek Trail…are expected to see little to no effect from implementation of either action alternative, with the majority of effects being indirect, caused by the sights and sounds of timber harvest operations.”

That the aggregate for this project is to be transported using costly helicopter transportation is entirely wasteful, 19

when agency-owned track vehicles with beds designed to hold aggregate loads were, as recently as July, 2015 , already being used to transport aggregate on a portion of the Ohmer Creek trail currently under reconstruction.

The scoping letter inappropriately limited the project area to only a segment of the East Ohmer and Lumpy Creeks and the 20 acre floodplain. It needs to be expanded to include the 8 acre “wood collection area as well, since timber volume will be removed to supply logs for the project and significant heavy machinery will be used to obtain whole tree. According to the scoping document (at 1), one identified source for 130 logs will be from this cutting unit along the Woodpecker 6245 road system that also provides what little remains of valuable deer habitat on the island. There is no indication if this unit has been NEPA cleared. If so, please identify and provide the document it was analyzed under. If not, please analyze and disclose the impacts (including cumulative) of old growth removals on Mitkof Island and in the WAA. A unit card should also be included in the analysis including timber volume removed. The total timber volume for the entire project must also be disclosed, using board foot volume measurement, not numbers of logs and tree tops. !IX. Please Analyze and Disclose the Condition of NFS Road 40010 and Any Other Older Access Roads in the Area. This costly amelioration program is necessary because of past logging activities, road construction being one. No mention is made regarding the condition of Forest Service road 40010 that transects the project area. The condition of this road needs to be evaluated and disclosed including a road/ stream connectivity analysis for this and all/former roads in the environmental document. Provisions need to be made to remove and/or repair any culverts that impede fish passage and properly maintain or put to bed roads (not “vegetative” closure) in the project area. Because the project area needs to be expanded, this request includes all roads in the expanded area. It makes no environmental sense to restore aquatic habitat in the creek and associated floodplain while ignoring the impacts of prior upstream road construction which could negate the overall benefits of the project. This includes the impacts of stream sedimentation due to road runoff. !X. Cumulative Impacts of Logging this Unit Must be Analyzed and Disclosed. !As mentioned above, the Woodpecker Area is an important area for subsistence use of deer and the cumulative impact of additional logging in the project area (expanded) must be analyzed and disclosed. !Also, please include the cumulative impacts of all logging that has taken place on Mitkof Island including the numerous small sales that have slipped by, with no cumulative analysis, under Categorical Exclusions. These timber sales, when added together likely amount to significant loss of old growth habitat. !XI. Topsoil Collection Areas Need to be Identified and Their Removal Must be Analyzed and Disclosed. !The scoping letter asserts that, “Topsoil additions would only occur if a source of weed-free forested soil could be found in the vicinity of the project areas.(at 6) “Organic matter in the form of nurse logs and preferably topsoil is needed to fully restore the area where gravels were excavated and dense till remains.(at 4) !

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Clearly, plentiful supplies of topsoil are hard to come by in this region. Please disclose the location of topsoil removals and the impact of those removals on soil stability and productivity from the removed sites. !Also, please provide maps of the area that depict the location of equipment access trails as well as their impact on water quality. We are concerned that care be taken to ensure that new disturbance to the floodplain does not actually set back decades of recovery, however slow that recovery has been. !Also, please describe the process of “harvesting” whole trees as described by Landwehr 2009, cited in the scoping letter. Is this the only location where an excavator will be used? XII. Please Develop a Monitoring Program and Address Mitigation Measures Contained in the Analysis. !Please provide specific details regarding how the Forest Service intends to plan for maintenance, decommissioning and proper road storage to mitigate effects to stream flows and to minimize sediment impacts from past road construction. The discussion should include a review of maintenance backlogs in the project area and present a cost to budget ratio for those backlogs. The public and decision maker should be able to review more than just the good intentions of fixing past and prospective damage. To make a fully informed decision, the draft document should discuss whether or not there is budget to support those good intentions. !This information is critical, particularly if this project involves the assumption that Best Management Practices (BMPs), road closures and Standards and Guidelines will minimize effects to water quality and fish habitat. If there is not an adequate record of funding for fixing existing problems, the draft document should disclose that in its discussion of mitigating measures. !XIII. Please Disclose Proposed Riparian Thinning Procedures !The scoping letter implies that riparian thinning will be conducted under this proposal: !"Red alder and Sitka spruce currently occupy the site, but both species are small in height and diameter when compared to other young-growth stands on floodplain soils where gravel extraction did not occur.”(at 4) !"Vegetation management, including riparian thinning of the young-growth stand within the floodplain would continue [even under the No-action]. (at 5) !"Selectively thin 20 acres of riparian area to speed the growth of large trees as a future source of wood recruitment to the channel for natural creation of fish habitat.” (at 6).

Does this mean that Red alder, Sitka spruce, or both will be targeted for thinning?

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We understand from experts in the field that cutting alders to release spruce does 20

not appear to be effective, despite there being a long history of doing so on the Tongass. According to them, the condition of the soil, not shading out future spruce recruits by alder seems to be the real problem. Often after floodplain logging, the topsoil is lost in subsequent flood events and this is more likely the cause of slowed spruce colonization and growth rates.

! XIV. Thank you for Finally Addressing the Problem of Trash and Logging Debris Left Behind from Previous Operations. !We appreciate that the PRD will undertake removal of logging related trash and debris in the project area. This has been a common, decades long problem, endemic to logging operations in the region - and should have been addressed long ago. We hope you continue this most basic but necessary exercise on the PRD and that it extends to other areas on the Tongass. It is never too late to take out the trash. But, better yet, logging operators must be required to remove ALL logging equipment, prior to the agency signing off on completion of any contract. !XV. Please Ensure that the Planning Record Is Available Concurrently with the Notice of Availability of the Analysis Document !The planning record should be compiled and available to the public at both the draft environmental document stage and the final decision stage. Availability of the planning record will be necessary in order to meaningfully review the draft document. !!  ______________________________________________________________________________ !!!!!The purpose of NEPA is to “insure that environmental information is available to public officials and citizens before actions are taken.” The recent efforts to streamline 21

environmental impact documents have forced the public to take extra steps to request important site specific information. Please ensure the availability of the additional materials in a timely manner in order to be consistent with NEPA’s goals for public participation in agency decisionmaking. 22

 

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Personal Communication. Bob Christensen. August 30, 2015.20

40 C.F.R. °◊ 1500.1(b).21

See, e.g. 40 C.F.R. °◊ 1502.21(requiring federal agencies to make reasonably available all material!22

incorporated by reference within the time allowed for comment).

Thank you in advance for addressing our scoping comments. We look forward to reviewing the Draft document. !Sincerely, !!!!Rebecca Knight for the Greater Southeast Alaska Conservation Community

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