2016 TLMP Comments

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2016 TLMP Comments

February 18, 2016

Forest Supervisor, Tongass National Forest
Attn: Forest Plan Amendment
648 Mission Street
Ketchikan, AK 99901

Subject: Comments on 2016 TLMP

The Greater Ketchikan Chamber of Commerce is a diverse community-based organization comprised of over 200 members, including private sector businesses, non-profit organizations, and local governments. The Ketchikan Chamber of Commerce believes that progress is best made through unity. We bring businesses, investors, and customers together, and work towards the common goal of encouraging a sustainable economy which can preserve the socioeconomic well-being of our community, and the families who call it home.

Approximately 90% of southeast Alaska is subject to federal ownership. The majority of this land is the Tongass National Forest, which comprises 16.9 million acres of Southeast Alaska. The Tongass is endowed with a wealth of timber and mineral wealth which helped support the initial development of Alaska Territory, the development of Ketchikan and many other rural communities, and the economic case for eventual statehood.
The Ketchikan Chamber of Commerce supports management of the Tongass in a manner which sustains the economic well-being of the region. In light of the limited economic and population growth in Southeast Alaska, it is essential that additional timber, mineral, and renewable energy resources within the Tongass be developed to grow the region’s economy, and strengthen rural communities like Ketchikan. Our comments on the US Forest Service’s Draft EIS for the proposed Tongass Transition Plan Amendment, which follow below, reflect this need.

The Ketchikan Chamber of Commerce comments incorporate by reference the comments made on this Transition Plan Amendment by the Alaska Forest Association (AFA), the Alaska Miners Association (AMA), Southeast Conference, and the Resource Development Council (RDC).

Comments on the DEIS for the USFS’s Proposed Tongass Transition Plan Amendment to the Current 2008 Amended Tongass Land Management Plan (TLMP)

Management Practices in General

The Forest Service should re-delegate to the Forest Supervisor and District Rangers the authority to make permitting decisions within IRAs.
Logging roads constructed during initial timber harvest activities can be very beneficial to subsequent harvest rotations. The practice of road decommissioning is expensive, wasteful, unnecessary, and reduces ancillary community benefits such as access for tourism, hunting, fishing, hiking, wildlife viewing, subsistence activities, and more.

Generally, the Ketchikan Chamber of Commerce concurs with the comments of the AFA. In addition, the following issues are of particular concern.

The DEIS erroneously blames the closure of pulp mills on poor markets. In fact, it was the USFS’s changes to timber supply contracts which undermined the economic viability of the pulp mills, and led to their closure. Similarly, southeast Alaska’s timber industry and employment has constricted severely over the last decade due to the USFS’s inability to provide a reliable, meaningful, and consistent supply of timber.
Southeast Alaska’s communities and businesses did not seek the transition to a young growth-based timber industry. The concept was not locally-generated in support of commonly-held community socioeconomic goals. The DEIS acknowledges that the Transition strategy originated from the Secretary of Agriculture, who imposed this concept upon the region. The DEIS fails to mention that the Transition strategy has met with significant opposition by the timber industry, the State of Alaska, the Alaska Congressional Delegation, and many communities in the region due to the fact that it has strong potential to undermine existing industry, and result in economic harm to communities, businesses, and families. The Ketchikan Chamber is concerned by the fact that the Transition seems motivated by political opportunity, rather than by economic opportunity, or commonly-held community values, goals, and objectives.
An expedited transition to a young growth-based industry is a highly speculative, risk-laden decision. There is a strong chance the transition may not be financially, economically, or technically feasible, and that it might fail. Ketchikan and other communities throughout southeast Alaska would bear the consequences of a failed experiment. The USFS is betting southeast Alaskan jobs and livelihoods upon a successful outcome. It would be far less risky for the USFS to follow-through on its existing commitment to meet demand and sustain businesses and families through a reliable, adequate supply of old growth timber. The DEIS does not analyze the potential impacts and costs to businesses and communities if the USFS’s proposed experiment fails.
Alarmingly, much of the analysis which supports the USFS’s gamble is inadequate, insufficiently developed and/or flawed, which sets up the proposed transition for failure, and southeast Alaskan communities for significant harm.
• The DEIS fails to acknowledge that the USFS does not have an adequate inventory of existing young growth stands which produces the sound information necessary to inform a Transition strategy, and support economically responsible decisions which can maintain the economic well-being of communities like Ketchikan. The agency’s timber growth model appears to significantly overstate young growth timber volumes.
• A credible financial analysis is necessary to meet the Secretary of Agriculture’s Memorandum 1044-009, which directs the USFS to “maintain the existing industry.” The USFS has not completed a credible financial analysis of the feasibility of manufacturing timber products, exporting logs, or biomass manufacture/utilization under the proposed Transition. Instead, the DEIS relies heavily on a 2009 Nature Conservancy report to assert that young growth manufacturing in southeast Alaska is currently feasible. The DEIS fails to mention that the Nature Conservancy’s report indicates that current manufacturing of young growth would require federal subsidies.
• Timber and forest products businesses have identified a wide variety of very credible flaws and errors within the USFS’s draft, revised demand analysis. These concerns are detailed within the AFA’s comments. The Chamber is concerned that faulty assumptions and errors in the demand analysis result in flawed economic benefit and job creation benefit projections within the DEIS.
• There is a need for higher quality “investment grade” information, including detailed stand-by-stand analysis for all young growth stands within the identified young growth timber base, and bankable feasibility studies for suggested harvest and manufacturing operations. The private sector should conduct a peer review of this information, including detailed business plans with financial pro formas. The USFS should not attempt to invest in a transition to new industry sectors / business lines without “investment grade” analysis, and bankable feasibility information.
• On page 3-2, the EIS includes a brief paragraph on nonrenewable resources, which asserts that the gradual decline of old-growth habitat may be considered irreversible. This is incorrect; trees are considered renewable because they will regrow.
• There are 9.765 billion acres of forests on the earth. The 1.7 million acres of timber within the Tongass which were dedicated in the 1980s for timber harvest are equivalent to 0.017% of the earth’s forests. The 23,000 acres of old growth scheduled for harvest over the next 25 years is equal to 0.00023% of the earth’s forests.
• From a global carbon / climate change perspective, harvesting this timber has nearly inconsequential impacts on climate change – particularly because these trees will regrow. The cycle of regrowth is not considered within the analysis.
• Moreover, timber is a global commodity; if demand for timber is not met by the Tongass, it will be met by a supply from other sources. From a global perspective, saving a tree within the Tongass only means loss of a tree (and job creation) elsewhere. Thus, saving Tongass timber results in little to no net global climate change benefit; only displacement of Alaskan jobs to other regions.
• The USFS could maximize potential carbon reduction benefits through utilization of renewables and clean hydropower in the Tongass as an alternative to coal and natural gas-fired generation in the lower 48 States. However, this opportunity is not examined or even discussed within the DEIS.

The DEIS should be updated to reflect the fact US Fish and Wildlife Service found that the so-called Alexander Archipelago wolf is not a subspecies, and denied the petition to have it listed as threatened or endangered. (Ex: statement on page 3-222). The DEIS should utilize the term “grey wolves” or “timber wolves” in place of the term “Alexander Archipelago wolves,” which is technically inaccurate, and misleading.

The DEIS contains statements suggesting that southeast Alaska’s tourism industry is dependent upon the presence “undisturbed forest lands.” This is grossly inaccurate; the vast majority of tourists visiting southeast Alaska visit via cruise ships. The limited areas of the Tongass which they view have already been impacted by prior timber harvest activities. The few tourists who visit the forest by alternatives to cruise ships do so primarily by driving road systems which were constructed by the timber industry.
The DEIS should be updated to reflect the fact that southeast Alaska has supported a robust tourism industry that has grown over time despite the presence of previously-harvested areas.

The DEIS should also be updated to reflect the fact that road systems constructed by the timber industry have helped to support tourism by providing access for a wide variety of activities, including hunting, fishing, hiking, birding, wildlife viewing, photography, recreational vehicle use, boating/kayaking, and more.


Generally, the Ketchikan Chamber of Commerce concurs with the comments of the AMA. In addition, the following issues are of particular concern.
• 36 C.F.R. Part 228 provides for “reasonable access” to locatable minerals in both Wilderness Areas and Inventoried Roadless Areas. Due to the nature of equipment and processes involved in typical mining operations, the TLMP amendment must interpret “reasonable access” to mean road access. Rock is heavy and voluminous. Helicopters are oftentimes prohibitively expensive, and incapable of transporting heavy equipment required for mining exploration and development under standard industry practices. The DEIS should be updated to include clear guidelines requiring that “reasonable access” for mining operations in the Tongass be interpreted to mean “road access.”
• While the 2001 Roadless Rule allows “reasonable access” to locatable minerals, it denies access to new leases subject to the Mineral Leasing Act of 1920, as well as leases for geothermal energy resources “because of the potentially significant environmental impacts that road construction could cause to inventoried roadless areas.” There is no explanation in the 2001 Final Roadless Rule and ROD why the access impacts to IRAs associated with locatable minerals is different from the access impacts associated with leasable minerals.
• Prohibiting road construction to access future mineral leases and renewable geothermal resources constitutes a “withdraw” under ANILCA. Yet the USDA did not notify Congress, or seek a required Congressional joint resolution approving the withdraw, as required by law. Thus, the Mineral Leasing Act withdraws made by the Roadless Rule are illegal, and should terminate consistent with ANILCA § 1326.
• The alternatives examined in the TLMP Amendment should include a specific requirement for timely (30 day turnaround) issuance of Forest Service Special Use Permits for those holding mining claims.
Renewable Energy (Including Hydropower)

Generally, the Ketchikan Chamber of Commerce concurs with the comments of the AMA. In addition, the following issues are of particular concern.

• Consistent with National Energy Policies, the TLMP Amendment should include alternatives with a clear, consistent, enforceable Renewable Energy Development LUD which promotes and supports renewable energy development and related transmission lines within the Tongass. The currently-proposed forest-wide standards and guides are too vague to be enforceable, and do not provide adequate direction to the USFS, or assurance and certainty to developers. The Ketchikan Chamber advocates use of the Renewable Energy Development LUD recommended by the AMA’s comments.
• The USFS should ensure that renewable energy developers are able to construct roads required in support of renewable energy project development. Roads are needed to transport heavy equipment, supplies, and materials in accordance with standard renewable energy sector construction practices. Attempting to develop renewable projects via helicopter neither technically nor economically infeasible.
• There is no renewable energy project in southeast Alaska that is “without benefit to Southeast Alaska communities.” Even if power is not utilized locally, renewable energy projects in the Tongass create rural “green jobs,” local expenditures, and local tax revenue in southeast Alaska – all of which are meaningful “benefits.” Benefits of this type are particularly important given the facts that southeast Alaska has lost many timber sector legacy jobs, has experienced anemic economic growth, and is at heightened risk of economic contraction due to the State of Alaska’s ongoing fiscal crisis.
• The USFS should provide for equal treatment of developers, and abandon language that prioritizes or deprioritizes projects based upon their intended market or user.
• The Ketchikan Chamber of Commerce agrees with the concept of prioritizing access to renewable energy (including hydropower) in all LUDs, whether they are an “avoidance LUD” or not.
• Despite the DEIS’s emphasis on climate change and carbon offset in regard to abstaining from cutting Tongass timber, there is no credible analysis or even discussion of the much greater carbon reduction benefits which can result from using renewable energy and clean hydropower in the Tongass as an alternative to fossil fuel-based generation in the lower 48 States. The benefits of this course of action are significantly greater than benefits of timber harvest avoidance and even displacement of remaining diesel-based generation in Alaska. These potential benefits should be identified, and quantified under Interagency Working Group for Social Cost of Carbon standards, consistent with EO 12866, and federal energy / environmental policy.
The Ketchikan Chamber of Commerce requests a detailed response to its comments as NEPA requires. As the Court observed in Earth island Institute vs. U.S. Forest Service, 697 F.3d 1010, 1020 (9th Cir. 2012): “In the context of environmental impact statements, NEPA requires agencies to respond explicitly and directly to ‘responsible opposing view[s]’.” See also Greenpeace vs. Cole Fed. Appx. 925, 928 (stating the Forest Service must discuss in the final statement “any responsible opposing views”).

Thank you for the opportunity to comment. Please let me know if you have any questions regarding the Ketchikan Chamber’s comments and proposals.