June 12, 2015
Ms. Terri Marceron
Chugach National Forest
101 E. 1st Avenue, Door 8
Anchorage, AK 99501
Re: Chugach National Forest Plan Revision
Dear Ms. Marceron:
The Resource Development Council (RDC) appreciates the opportunity to provide comments on the Chugach National Forest Plan Revision, including the Wild & Scenic River Evaluation and the Wilderness Area Inventory and Evaluation.
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.
Because of the broad interests represented by RDC, we have wide ranging concerns regarding future management of the forest. Our concerns can only be addressed through the continuation of the multiple-use mandate, which has been a cornerstone of Forest Service policy and set national forests apart from parks and refuges. Our national forests were established under a working forest model. Unlike the national parks that were created for preservation, the national forests were established under the authority of the Organic Administration Act of 1897 to conserve water flows and to furnish a continuous supply of timber and other resources for the American people. The notion of the working forest has been with us for over a century.
A working forest is one that recognizes the human component of our forest, incentivizes workforce development and local jobs, while providing opportunities to enhance wildlife habitat, recreation, and subsistence activities. A working forest provides many benefits to local communities and is a cornerstone of some economies.
As our nation grew and demands on our forests increased, additional acts of Congress refined but did not supersede the Organic Act. The 1960 Multiple Use Sustained Yield Act added outdoor recreation, range, fish, and wildlife to the balance of national forest uses. The 1976 National Forest Management Act (NFMA) established a framework for forest planning, however, nowhere did Congress alter the fundamental mandate to balance water, timber, mining, recreation, range, fish, and wildlife.
Multiple use means more than recreation, subsistence, and wildlife habitat. These uses are all important, but must go hand-in-hand with responsible resource development. The Chugach should be managed for multiple uses, including recreation, commercial tourism, mining, timber harvesting, and other resources, especially given the fact Alaska contains 70 percent of the nation’s national park lands, 80 percent of its national wildlife refuge acreage, and 53 percent of federal Wilderness. These units, like most of Alaska, are primarily roadless and wild. The Chugach should not be managed as a national park where preservation is an overriding management priority. RDC believes that true multiple uses as outlined above should be reflected in the plan revision if the Chugach is truly to be a land of many uses.
RDC is concerned the decision process for the plan revision is predisposed to non-development, pro-wilderness designations. Decisions should be grounded in good science, balancing economic and environmental considerations. Forest managers should resist decision-making based on aesthetics, misguided public opinion, and perceived impacts to the forest.
One of the original mandates of the national forest system is to provide a reliable source of timber to a domestic forest products industry. Yet in its Spring 2015 Forest Plan Revision Newsletter, the Forest Service did not even acknowledge timber harvests except for firewood as a multiple use. Timber harvesting is not discretionary, no more so than habitat preservation, ecosystem management, watershed protection, and recreation.
While we acknowledge there is a relatively small percentage of high quality commercial timber in the Chugach, the plan revision should allow for specific actions to restore forest health and reduce the risk of wild fire. The revised plan should include measures for ecological restoration on the Chugach, which has seen forest ecosystems convert to grass and sedge ecosystems in the wake of beetle outbreaks. There should be an opportunity in the plan revision to introduce an annual sales quantity (ASQ) to aid in restoration work and possibly support biomass production or other commercial endeavors in the region. A program of scheduled timber sales should be provided to meet predetermined allowable sale quantity.
The revision should also provide for modern silviculture practices to encourage natural regeneration. Forested portions of the Chugach should be managed toward a varied species composition and different age classes to reduce the risk of large beetle infestations in the future and help restore long-term forest health.
There are many areas within the Chugach National Forest that contain valid, active mining claims, and many more that may have moderate to high mineral potential. Areas with known mineralization or moderate to high mineral potential should be given a minerals prescription, and areas with valid mining claims should remain available for the prescribed use. It is important that access to these areas is not restricted. Moreover, no areas should be withdrawn from mineral entry unless they are in a specifically designated conservation system unit where mining is considered incompatible. Areas that are merely being considered for inclusion into a conservation system unit should not be closed to mineral entry. Much of the forest has yet to be adequately explored for its mineral values. Closing an area to mineral entry forecloses future exploration and development opportunities, even if the specific area is later found to be mineralized.
Currently more than 90 percent of the Chugach is roadless. Roadless areas, as well as Wilderness and Wild and Scenic River designations, make access permits more difficult, thereby resulting in greater restrictions. Despite future needs, Wilderness designations would prevent the Forest Service from providing additional access, whether for resource extraction, forest health, recreation, or tourism. Less access to the public lands essentially means less multiple uses for the public and industries that provide products for consumers.
Access to timber, mining, recreation, and inholdings should not be precluded. The revised plan must explicitly acknowledge congressionally guaranteed rights of access to surface and subsurface lands conveyed to Alaska Native Corporations within the forest boundaries. The revised plan should be abundantly clear that the Alaska Native Claims Settlement Act (ANCSA) and the Alaska National Interest Lands Conservation Act (ANILCA) guarantee access to these lands to achieve the goals of ANCSA, a fair and just land settlement that addresses the real economic and social needs of Alaska Natives.
Moreover, improved access for destination tourism opportunities must be provided for in the plan revision. The plan should place a growing emphasis on how to accommodate a larger number of visitors, not just on how to limit or block access.
Since much of the forest is roadless, helicopter overflights and landings should be allowed in a variety of areas. Statistics show helicopter flightseeing and landings are among the most popular and highest-rated activities for Alaska visitors. Helicopters often afford the only viable access to remote areas. It is often the only way for the physically impaired, aged or a traveler on a tight time schedule to experience remote, rugged lands up close.
Wild & Scenic Rivers and Wilderness Designations
RDC opposes new Wild and Scenic River designations as they are overly restrictive and would diminish multiple use, access, and potential mining activity in the forest. These single-purpose designations are not needed in the Chugach and could very well be used as a tool to block economic development, including activity on Native corporation land.
RDC also opposes Wilderness designations in the Chugach National Forest and believes strict management for Wilderness is neither appropriate or necessary. ANILCA was intended to resolve the issue of what lands in Alaska should be designated Wilderness. Beyond the Nelle Juan – College Fjord Wilderness Study Area, additional wilderness suitability studies and recommendations are not allowed in Alaska under the ANILCA Section 708(b).
Alaska already contains 57 million acres of federally-designated Wilderness – 53 percent of all federal Wilderness in the U.S. In addition, the state contains vast national park and refuge lands that remain in their original state. Alaska also includes vast acreage of state parks, putting it at the top of the list for acreage preserved under state conservation units.
Further, consideration of federal conservation system units, including Wilderness and Wild and Scenic Rivers, is not consistent with ANILCA. Section 101(d) states that the need for future conservation system units in Alaska has been obviated by the ANILCA withdrawals and Section 102(4) includes Wilderness in the definition of a CSU. In addition, Congress recognized that for Alaska to “satisfy the economic and social needs of the State of Alaska and its people” access is essential. This point is acknowledged in Section 1326(a), which states that administrative closures, including the Antiquities Act, of more than 5,000 acres cannot be used in Alaska. Section 1326(b) adds emphasis to the “No More” clause in noting that federal agencies must first seek the permission of Congress before even studying lands in Alaska for Wilderness consideration.
The Forest Service should not proceed in revising the plan as if no Wilderness, national parks, or refuges exist in Alaska. The areas of the Chugach that are currently being managed as Wilderness should be re-evaluated and a more flexible management regime applied. Wilderness designations severely limit recreational and multiple use opportunities, impair access, and prohibit resource development. They would also hinder access for future generations and restrict tourism. These designations represent an economic opportunity cost. It is important that the cumulative effects of such lost opportunity be studied before each new Wilderness designation is proposed.
What RDC finds particularly troubling in the Wilderness Area Inventory and Evaluation is that the Forest Service has included land with existing valid mining claims, approved mining activities, and legal access routes to valid mining claims within areas that it concludes are suitable for Wilderness designation. These lands are not suitable for Wilderness and such a designation would preclude future mining and other multiple use activities that are not compatible with the Wilderness Act. The Forest Service has essentially ignored mining as an allowed use in the forest’s multiple use lands in making its Wilderness suitability determinations. All forest lands that are open to mineral location and entry under the federal mining law should not be considered suitable for Wilderness, nor should they be proposed for Wilderness designation.
Furthermore, the Forest Service has included existing intensive motorized recreation areas such as snow machine corridors in Turnagain Pass as suitable for Wilderness. This area has a long history of allowing motorized uses and has attracted thousands of snow machine enthusiasts over the years.
The cumulative socio-economic impacts of numerous withdrawals and proposed withdrawals of land from multiple use management must be addressed in the revised plan. There should be a no net loss in the economic resource base. The Forest Service, in its revised management plan for the forest, should balance increases in land withdrawals with increases in resources available for multiple use.
RDC appreciates this opportunity to submit comments and share viewpoints on the future management direction of the Chugach National Forest. We look forward to more – not less – opportunities for multiple use opportunities for the nation’s second largest national forest.
Resource Development Council for Alaska, Inc.