April 25, 2007
Mr. Forrest Cole
USDA Forest Service
Tongass National Forest
Federal Building
Ketchikan, AK 99901
Attn: Tongass Forest Plan Amendment
Dear Mr. Cole:
The Resource Development Council (RDC) appreciates the opportunity to provide comments on the Proposed Tongass Land and Resource Management Plan. RDC encourages the Forest Service to adopt Alternative 7, with modification, as the Preferred Alternative.
RDC is a statewide non-profit business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, fisheries and tourism industries. RDC’s membership also includes Alaska Native corporations, local communities, organized labor and industry-support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.
A major goal of RDC is to build a more diverse and vibrant economy in Southeast Alaska through the restoration of a fully integrated forest products industry. The forest plan amendment can be the vehicle to achieve this goal by providing an adequate, reliable supply of economic timber to the industry. However, only Alternative 7 in the proposed forest management plan approaches the required volume necessary for a more diverse economy through a fully-integrated industry.
Alternative 6 updates the forest plan relative to the five-year review, but does not provide a large enough land base, suitable for timber harvest, to achieve full integration. Alternative 4 offers an opportunity to accommodate more integrated operations, but in reality, this alternative ramps up the timber volume too slowly and relies upon some unrealistic volume estimates from non-federal timber. Although Alternative 7 appears to supply an annual volume that could help rebuild the industry, modifications may be necessary to ensure it can be implemented as presented.
RDC strongly supports the restoration of a fully integrated forest products manufacturing industry in Southeast Alaska. It is essential that the forest products industry have the capability to manufacture every species, size and quality of commercial timber that is harvested in the region.
Since the closure of the Ketchikan pulp mill in 1997, there has been no facility in the region that can manufacture products from either the utility logs, which comprise about 15 percent of the timber stands, or the residual sawmill chips. As a result, the utility logs are either left behind to rot or are exported as unprocessed logs. Similarly, the sawmill chips are either wasted or barged south to one of the pulp mills in Canada or the Pacific Northwest.
Experts say a Medium Density Fiberboard (MDF) mill could utilize both chips and utility logs, but a harvest level of around 360 million board feet (mmbf) annually is needed in order to generate a reliable supply for a competitively-sized MDF facility. The volume of timber needed to amortize the cost of constructing such a facility must also be considered. No doubt, a prudent operator would require a portion of its fiber needs be ensured through a contractual agreement. This should be considered in the implementation of the Tongass timber sale program.
Similarly, there is a state-of-the-art veneer plant in Ketchikan, but the mill will remain idle until there is a reliable supply of veneer-quality logs available. The veneer mill is designed to peel small, rough sawlogs which comprise about 20 percent of the commercial timber stands. The mill was designed to utilize about 40 mmbf of timber annually, thus a total, uninterrupted timber harvest of about 200 mmbf would be needed to ensure the facility could operate and reliably supply its customers.
The Viking sawmill in Klawock has a new, small log processing facility incorporated in its mill. This facility utilizes logs similar in size and quality to the veneer logs. The facility is designed to process about 20 mmbf annually, so in order to supply both the veneer plant and the Klawock small log mill, an uninterrupted timber harvest of about 300 mmbf would be needed. Other sawmills also process the small sawlogs, thus more than 300 mmbf is realistically needed even without considering the MDF facility needs.
In addition to the volumes required for the mills, an economy of scale for the road construction and logging companies must be maintained. The timber industry, many of the local communities and several economists agree that the minimum harvest level needed from the Tongass is 360 mmbf. We concur. Only Alternative 7 in the DEIS satisfies this requirement. Alternative 7 has a total Allowable Sale Quantity (ASQ) of 420 mmbf, but only 360 mmbf is from economic timber stands.
Beyond the total volume needs, there are at least four parts of the 1997 wildlife conservation strategy that must be revised in order to make it possible for economic timber sales to be prepared:
- The beach fringe buffer was expanded from 500 feet to 1,000 feet in 1997. These beach fringe areas are some of the fastest timber growing sites in the region. Further, these sites are generally much less expensive to harvest than the higher hillsides. Returning to the 500-foot buffer would reduce the overall acreage needed to sustain the 360 mmbf harvest level and it would minimize the amount of roadless acreage that must be managed because the timber in the beach fringe areas grows faster than the average and much of that timber is already roaded.
- The 1997 Tongass Land Management Plan (TLMP) system of large, medium and small old-growth reserves, along with the connecting corridors, is both highly costly and unnecessary. Alternative 7 establishes a timber harvest base on only about 20 percent of the commercial old-growth in the Tongass. About a third of the commercial timberland is already preserved in congressionally-designated Wilderness, monuments and roadless areas. Additional vast acreages of high-volume, old-growth are preserved in the Class-1 and Class-2 fish stream buffers and in the 500-foot beach fringe buffer. Other, more specific buffers and research areas are also preserved. Even without all of these reserves, about 80 percent of the commercial old-growth timber is not scheduled for timber harvest under Alternative 7, leaving more than adequate habitat to ensure viability of wildlife populations.
- The marten and goshawk standard is also unnecessary since so little of the forest will be disturbed under Alternative 7. These two standards and guidelines require that “leave” trees be left standing in the harvest units, either individually or in clumps. Leaving trees in clumps is better than retaining individual trees, but both practices are dangerous for the loggers and are very costly. Further, the practice of leaving 30 percent to 50 percent of the timber in the harvest units means that less timber is harvested from each acre, requiring additional acres of roadless areas to compensate.
- Requiring class-3 (non-fish) stream buffers on all class-3 streams is another costly practice. Buffers on class-3 streams should be required on a stream-by-stream basis, only when there is a real need. The State of Alaska’s stream buffer requirements and best management practices for road building and timber harvesting are sufficient to protect fish habitat. The Forest Service’s requirements are unnecessarily more protective than Alaska’s Forest Practices Act.
These four parts of the 1997 TLMP conservation strategy should be eliminated. The additional habitat created by these four requirements is unnecessary in a forest where 90 percent of the old-growth timber is still undisturbed. Alternative 7 would utilize most of the existing young-growth and, after a hundred years, there would still be some 80 percent of the old-growth timber undisturbed.
The Forest Service presale foresters have repeatedly told the Alaska Forest Association that the negative economic impact of these four requirements are the primary reason the agency has been unable to implement its timber sale plans. The economic harm caused by these elements to the forest products industry and local communities far outweigh the unfounded benefits to fish and wildlife. In fact, the Forest Service’s own DEIS indicates that fish harvests have increased, indicating fish habitat has been adequately protected from past timber harvest activities.
The Tongass provides multiple use opportunities beyond timber harvesting. There are 52 areas totaling 589,000 acres within the national forest containing identified mineral resources. Of the identified mineral tracts, 377,000 acres have a high potential for being developed. In addition, there are 6.6 million acres of potential, but undiscovered mineral resources within the Tongass. Alternative 7 would improve the economics of new mineral exploration and development in the forest by lowering the cost of entry in some land use designations in each of the categories stated above. This could help diversify the economy and provide opportunities beyond forest products, especially when litigation prevails over timber sales.
With Southeast Alaska experiencing a significant economic downturn due to the sharp reduction in federal timber, any new economic activity, such as mining, that promises to bring in high-paying jobs and responsible development should be actively encouraged by the Forest Service. The Forest Service should take proactive steps to ensure that potential exploration activities will not face unnecessary roadblocks and complications.
The Niblack area has a high potential for minerals development and was the site of a historical mine. Niblack Mining Company (NMC) is involved in significant exploration activities and permitting. The likely zone of mineralization at Niblack extends to areas off of NMC's patented lands. NMC will need reasonable access to these areas for exploration, as well as the potential development of mine infrastructure, should a mine prove feasible.
Specifically, RDC opposes the proposed Old Growth LUD for the Niblack area. This LUD is unnecessary and would burden and potentially preclude exploration and development activities. The Forest Service should instead impose the Modified Landscape LUD with a Minerals LUD overlay.
RDC also opposes the "Wild River" designation under the Wild & Scenic Rivers Act (WSRA) for the Lake Luelia area. NMS has existing claims near Lake Luelia and this area may be critical to the development of a mine. Lake Luelia has been inappropriately bootstrapped onto the Kegan Lake and Creek system. Lake Luelia and the areas upstream of it are not eligible for designation under WSRA and the Wild River designation should be removed and replaced with a Modified Landscape LUD with a Minerals LUD overlay.
NMC has interest in other mineralized areas in the vicinity of Niblack Anchorage. These areas should be managed to encourage minerals exploration. The Modified Landscape LUD or Timber Production LUD with a Minerals Overlay LUD should be instituted for the following areas on eastern Prince of Wales Island: Aiken Creek; Ruby Tuesday; Moss Point/Inner Point/Mossy Creek; and Khayyam/Stumble-On. These areas and their mineral potential are described in NMC's comments.
In concluding, RDC supports Alternative 7, although modification is likely necessary to achieve implementation as intended. It is the only alternative that truly strikes a balance among multiple uses in a forest that is mandated to be managed under the multiple use principle, as opposed to the more restrictive uses of a national park. It is the only alternative that provides a sufficient volume of timber to restore full integration in the timber industry and improve the economics of potential mineral development.
The goal of many Alaskans is to seek a more diverse and strong economy in Southeast Alaska. The forest products and mining industries are key to reaching that goal. For the forest products industry, an adequate long-term supply of economic timber from the Tongass is absolutely essential if the industry is to play a major role in rebuilding the region’s economy. The volume identified in these comments is sustainable from a small portion of the forest. Thousands of direct and indirect year-round jobs would result and local communities would receive significant, ongoing economic stimulus.
The economic benefits of a fully integrated timber industry to residents, local communities and the State of Alaska should be more thoroughly covered in the DEIS. Full integration should be a cornerstone of any Preferred Alternative, given the pressing economic needs of the region and local residents, and the fact that industry has demonstrated it can coexist with wildlife and fish.
Thank you for the opportunity to comment.
Sincerely,
Resource Development Council for Alaska
cc:
Mark Rey
Department of Agriculture
Undersecretary for Natural Resources
1400 Independence Ave. SW
Stop Code 0108, Wash. DC 20250
Governor Sarah Palin
PO Box 110001
Juneau, AK 99811
Senator Ted Stevens
522 Hart Building
Washington D.C. 20510
Senator Lisa Murkowski
709 Hart Building
Washington D.C. 20510
Congressman Don Young
2111 Rayburn Building
Washington D.C. 20515
