Tongass ROD

Attachment A - RDC Objections

August 25, 2016

Mr. Earl Stewart
USDA Forest Service Tongass National Forest Transition Plan Amendment
648 Mission Street
Ketchikan, AK  99901  

Re: Objections to June 2016 Tongass National Forest Record of Decision  

Dear Mr. Stewart:
The Resource Development Council for Alaska, Inc. (RDC) is writing to outline its objections to the June 2016 Tongass National Forest Draft Record of Decision (ROD). Our comments also apply to the Final Environmental Impact Statement (FEIS) and the Amended Land and Resource Management Plan (Amendment) for the Tongass National Forest.   

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.  
Summary of issues  

• The purpose and need for the Amendment is too narrowly addressed, resulting in a violation of the National Environmental Policy Act, the Alaska National Interest Lands Conservation Act (ANILCA), the Tongass Timber Reform Act (TTRA), and other laws.  

• The range of alternatives in the FEIS is too narrow, resulting in an inadequate analysis of the proposed transition to young-growth harvests.  

• The demand analysis for the proposed transition is seriously flawed and based on false assumptions.  

• A complete inventory of young-growth stands is needed in order to arrive at an accurate financial feasibility analysis of the proposed transition to young growth.

• Manufacturing of young growth in Southeast Alaska at this time is not economically feasible or competitive with operations elsewhere. Young-growth stands are too small and too few to support a manufacturing facility, let alone an entire industry. The Draft ROD itself acknowledges that there is no current market for young-growth timber.  

• The previous commitment to a three-year supply of economic timber sufficient to support an integrated industry is abandoned without mention.

• The 2008 harvest constraints are not adequately addressed and the projected timber volumes are grossly overstated.
• The overestimation of non-federal timber supply is a major error that the Forest Service has relied upon in determining the 46 million board feet (MMBF) per year of timber supply under the Amendment to meet “residual” demand under TTRA and to otherwise maintain a viable forest industry and infrastructure in Southeast Alaska. 
Clearly, the Draft ROD fails to provide sufficient volume for an integrated timber industry.
The FEIS, like the Draft EIS, presumes an average of 70 MMBF of annual timber harvest from Native Corporation lands as well as 20 MMBF annually from State land for the first decade after the Plan Amendment. As pointed out in the comments of Sealaska Corporation, the Alaska Forest Association (AFA), and others on the FEIS, these estimates are substantially too high. Sealaska lands, which are the primary source of private timber in Southeast Alaska, will average less than a maximum of 45 MMBF per year for the next 20-25 years, and the harvest from village corporation lands will be far less. The State of Alaska has indicated that the estimate of 20 MMBF from State land is erroneously high. The AFA notes in its comments on the FEIS that the estimate of 90 MMBF average annual volume from Native Corporation and State lands during the next 15 years is overstated by up to 40 MMBF per year. 
• The decision to protect certain watersheds known as the “Tongass 77” was made without complying with the “no more clause” – Section 1326 (a) of ANILCA. Moreover, the restrictions on timber harvest in the Tongass 77 and “conservation priority” areas were not proposed or discussed in Alternative 5 or other alternatives in the Draft EIS. As a result, the additional restrictions have not been adequately analyzed and supported in the EIS for their impact on the available timber base and timber supply for a viable forest industry. The existing land and resource use restrictions on the forest are already burdensome for a forest with a multiple use mandate. Given the large number of watersheds and areas of federal lands in Southeast Alaska where timber harvest and resource use are prohibited, and the small fraction of area remaining open for harvest, the additional restrictions for the Tongass 77 and “conservation priority” areas should be deleted from the final Amendment.
• The Forest Service should propose amendments to the Roadless Rule to allow for renewable energy development and access to mining claims. Provisions in the Draft ROD concerning renewable energy development and mining are lacking, representing a missed opportunity to further diversify the region’s economy.
These deficiencies and others lead RDC to strongly object to the Draft ROD. Our arguments objecting to the Draft ROD are outlined in detail in Attachment A and relate to our February 22, 2016 comments regarding the Draft EIS. Moreover, RDC supports the August 2016 comments of the Alaska Forest Association, the Alaska Miners Association, and Sealaska Corporation and urges the Forest Service to rescind and significantly revise the Draft ROD to address the concerns in our letter.
Thank you for the opportunity to provide comments objecting to the Draft ROD.
Resource Development Council for Alaska, Inc.