Comments Regarding the Forest Plan EIS for the Tongass National Forest
June 20, 2014
Forrest Cole, Forest Supervisor
Tongass National Forest
ATTN: Forest Plan Amendment
648 Mission Street
Ketchikan, Alaska 99901
Re: Ketchikan Chamber of Commerce Comments Re: Scoping Process for Tongass Forest Plan Amendment
Dear Forest Supervisor Cole:
The purpose of this letter is to provide the Greater Ketchikan Chamber of Commerce’s comments regarding the scope of work for the Forest Plan Amendment EIS for the Tongass National Forest and revision of the Tongass Land Management Plan (TLMP).
- The Greater Ketchikan Chamber of Commerce appreciates the inclusion of mention of hydropower within the USFS’s proposed scope of work for the TLMP revision and associated Forest Plan Amendment EIS, and urges the USFS to proceed to develop mechanisms which make hydropower development feasible within the Tongass National Forest. The Ketchikan Chamber urges the USFS to modify the TLMP in a manner which allows for hydropower development within the Tongass National Forest, in a manner which provides equal treatment of hydropower development proposals regardless of market location or funding source. This course of action would be consistent with federal policy emphasizing development of affordable domestic energy from clean and renewable sources.
- Hydropower is but one renewable energy resource within the Tongass National Forest, which is also host to significant wind, biomass, geothermal, and tidal renewable energy potential. The scope of work for the TLMP revision and supporting Forest Plan Amendment EIS should be expanded to include development of a Renewable Energy Plan and Renewable Energy Land Use Designation (LUD) inclusive of all clean energy technology and associated transmission and access roads. The Ketchikan Chamber of Commerce is fully supportive of Southeast Conference’s public comments and proposed Renewable Energy LUD submitted to the USFS in the summer of 2013 in association with prospective revision of the TLMP.
- The TLMP should be revised to include mechanisms allowing synchronization of the TLMP with emerging federal policies and executive orders emphasizing domestic energy production, national renewable energy goals, and energy security/independence. At present, land management restrictions that hinder renewable energy resource development are immediately incorporated into the Tongass Forest Plan, while Federal law and Executive Orders that require renewable energy resource development are not considered for implementation until a land management policy requires an amendment to the Tongass Forest Plan. The Ketchikan Chamber of Commerce urges that the scope of the Tongass Forest Plan amendment EIS be expanded to include analysis of a reversal of this policy.
- The scope of the Forest Plan Amendment EIS should be revised to include a Mineral and Strategic Mineral LUD that would be added to the 2008 Forest Plan to accommodate proposals for new mine development in the Tongass National Forest. Such a LUD would promote and support mineral and strategic mineral development and related access roads consistent with National Security and National Strategic Mineral Policies, while also creating local employment opportunities for southeast Alaska’s economically distressed communities.
- The scope of the Forest Plan Amendment EIS and its alternatives should include a discussion of the Obama Administration’s Executive Orders requiring federal agencies to accelerate permitting processes. Executive Order 13580, dated July 12, 2011, Executive Order 13604, dated March 22, 2012, and the May 17, 2013 Presidential Memorandum to the heads of Executive Departments and Agencies entitled “Modernizing Federal Infrastructure Review and Permitting Regulations, Policies, and Procedures” all have the same purpose: to achieve modernization of the Federal Government’s review and permitting of infrastructure projects, which the Presidential Memorandum asserts will reduce “aggregate timelines for major infrastructure by half.”
- Neither the 2001 Roadless Rule nor the 2008 Amended Forest Plan considered the adverse economic costs or the opportunity for jobs related to the development of renewable energy resources to rural Southeast Alaska communities, nor did it consider the direct economic impact on Southeast Alaska residents caused by their inability to access and develop renewable energy resources in rural Southeast Alaska. The Forest Plan Amendment EIS and all other analysis conducted in regard to rulemaking within the Tongass National Forest should incorporate socioeconomic analysis, consistent with US Executive Order EO 12866, which requires federal agencies methodically consider all costs and benefits of regulation, including economic opportunities, job opportunities, and social impacts.
Thank you for your consideration.
Chelsea J. Goucher, Executive Director
Greater Ketchikan Chamber of Commerce
O: (907) 225-3184
C: (907) 220-2133