Southeast State Forest Management Plan

April 24, 2015

Mr. Jim Schwarber
State of Alaska Division of Forestry
3700 Airport Road
Fairbanks, AK 99709

Re: Southeast State Forest Management Plan

Dear Mr. Schwarber:

The Resource Development Council (RDC) appreciates the opportunity to provide comments on the Southeast Alaska State Forest draft management plan.

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.

RDC was a strong supporter of the legislation creating the Southeast State Forest (SESF) in 2010 and subsequent legislation, which added additional units to the forest in 2011. Although we recognize that the 48,472 acre SESF is too small to provide for the timber supply needs for the region’s struggling forest industry, the state timber sale program from the forest has helped sustain what remains of the industry and its well-paying jobs ¬ given the lack of adequate timber from the adjacent Tongass National Forest. The state has done a good job with its timber sale program and we are pleased to see the Division of Forestry (DOF) continue with its “working forest” approach through the new management plan for the SESF.

RDC supports the state’s efforts to increase the size of the new state forest. As noted in the draft plan, critical to the success of present and future timber production from state forest lands is the efficient transfer of harvested timber from the uplands to shoreline or ocean-based modes of transportation, such as log rafts, barges or ships. We agree with the draft plan’s recommendation that key uplands, tidelands and submerged lands – many adjacent to SESF uplands – be considered for legislative designation as additions to this state forest. Key tideland areas include log storage, both long-term and short-term (on land and in water), log transfer facilities, rafting grounds, ship mooring buoys, and other areas where harvested timber must cross state tidelands to reach processing facilities. These same tideland areas may also support the transportation of timber harvested from other state lands, as well as from federal and private lands.

RDC agrees with DOF’s assessment in the draft plan that there are additional state-owned upland parcels located in southern Southeast Alaska that should be considered for inclusion into the existing state forest. These additions would add existing managed young growth timber stands to the forest land base, and reduce future use conflicts.

In 2012, the Governor’s Alaska Timber Jobs Task Force made multiple recommendations concerning additions to the SESF, including adding two million acres of national forest lands from the Tongass. Successful implementation of the task force recommendations would help ensure a vibrant forest industry in Southeast Alaska, resulting in a much stronger regional economy. If this Task Force recommendation comes to fruition, then additional state tidelands and submerged lands would need to be added to the state forest to ensure the efficient management of all the forest’s resources.

RDC would also like to commend the DOF’s efforts of coordinating its activities with other land owners in the region, including the Mental Health Trust Authority, the University of Alaska, Sealaska Corporation, and the U.S. Forest Service. These landowners will play a major role in diversifying the timber supply and meeting the needs of both the forest industry and the local economy. Opportunities to coordinate timber sales and transportation infrastructure with other land owners and timber managers should continue.

A major long-standing goal of RDC is to build a more diverse and vibrant economy in Southeast Alaska through the restoration of a sustainable forest products industry. The economic benefits of a healthy forest industry to residents, local communities, and the State of Alaska are significant. While the SESF does not have the timber base to fully support the industry, it can provide a stable supply of timber to local mills and supplement declining timber harvests on the national forest. It can also provide relief to the industry while it waits for increasing second-growth harvests from the Tongass in coming decades.

Further, RDC supports a sustainable and productive working forest concept for the SESF. Such an active management approach is necessary if the forest is to furnish a continuous and sustainable supply of timber to the industry. 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 can be a cornerstone of their economies.

For decades, the Tongass was managed as a working forest. The Southeast Alaska economy thrived and the forest industry was one of the largest economic sectors in Alaska with 4,600 jobs, mostly spread throughout the Southeast Panhandle. Other industries, including tourism and fishing, coexisted with the industry. Fish and wildlife populations remained healthy and actually increased in two of the most heavily logged watersheds. In addition, logging roads greatly improved access for recreation and other uses.

However, the industry has undergone a major transformation in the past 25 years with new land withdrawals and adverse federal public policy decisions sharply curtailing the timber supply to local mills. Today, only four percent of the entire Tongass is available for harvest, while about 85 percent of the forest’s largest old-growth remains untouched.

Given so much of Southeast Alaska is preserved in land management classifications that preclude logging, it is most appropriate that timber production and utilization is the primary use of the SESF (AS 41.17.200). As a result, we agree the primary focus of the new management plan should be the establishment of a reliable, long-term supply of economic timber to the industry to ensure the long-term viability of the region’s timber-based economy. Since much of the new state forest was inherited from the Forest Service with young second-growth, these stands should be actively managed to provide for more timber volume per acre on shorter rotations. The shift to second-growth harvesting can be accelerated and timber volume increased on state land by active forest management. Thinning is a long-term investment, but it is justified, given the pressing need for a stable, long-term supply of timber.

RDC also supports other multiple uses of the state forest, including access to other economy-building opportunities, such as mineral exploration and development, should future prospects arise or access across the state forest be required to reach projects elsewhere. The mining, timber, fishing and tourism industries coexist across Alaska and can do so in the Southeast Alaska State Forest, too.

As acknowledged in the draft plan, the Alaska Forest Practices Act will serve as the standard to protect water quality and fish habitat in the state forest. The Best Management Practices under this program are overseen by the diverse Board of Forestry, which has concluded that these are effective standards based on scientific compliance and monitoring.

In conclusion, with an adequate long-term supply of timber, the forest industry can make new investments in manufacturing and other operations. These investments can be made by private industry without government funding. All that is needed is an adequate supply of suitable, economic timber.

RDC is pleased to see the draft management plan for the forest acknowledge that the primary purpose for the SESF is timber production as a working forest. The draft plan correctly acknowledges these lands serve as an important source of timber for meeting the needs of the region and that timber production should be emphasized within the plan.

RDC appreciates the opportunity to comment on the Southeast Alaska State Forest draft land management plan.

Resource Development Council for Alaska, Inc.