Wrangell Island Project EIS

January 24, 2011

317 Forest Park Drive
Ketchikan, AK 99901

Attn: Wrangell Island Project EIS

To Whom It May Concern:

The Resource Development Council (RDC) is writing to offer its perspective on the Wrangell Island Project Environmental Impact Statement, which is being prepared for the proposed multi-year stewardship project involving a variety of timber harvest, road construction, and forest restoration and enhancement activities. Frankly, the proposed action is terribly inadequate and falls far short of what is truly needed to restore the health of the Southeast Alaska timber industry and rural economies.

RDC is a statewide, non-profit, membership-funded organization founded in 1975. The RDC membership is comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism, and fisheries industries, as well as Alaska Native corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to link these diverse interests together to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

The Forest Service’s preliminary analysis of the Wrangell Island project shows that up to an estimated 91 million board feet (MMBF) of timber could be made available to industry for harvest over a period of years. However, the proposed action does not even remotely resemble the original intent of the project. Initially, four 10-year timber sales, each with an average volume of 15-20 MMBF per year, were to be offered as part of an effort to support the forest products industry and the region’s struggling economy. These sales would have resulted in a significant volume of timber over an extended period of time – critical elements in attracting the necessary investment in infrastructure to prevent demise of the timber industry. Such investment is needed to expand or originate timber operations in the Wrangell area.

The approach envisioned under the proposed action will not provide the incentives for new investment in timber operations and the many jobs that would come from such investment. The current scope of the project is insufficient and will do little to restore the industry, meet the need for economic timber, and make a meaningful contribution to the economy.

The project must be designed as a ten-year timber sale with an economic harvest volume of 150 MMBF to 200 MMBF. The Wrangell Island logging system transportation plan has over 10,000 acres of forested land with the potential to contribute more then 200 MMBF of economic timber. Prescriptions in the Tongass Land Management Plan (TLMP) can be modified to make the project economic. Modifications, however, may not be necessary, if the Forest Service would honor the Roadless Rule exemption for the Tongass by including some roadless harvest in the project. Other activities included in the project should occur and be sited as to not interfere with the economics of the timber sale.

In regard to roadless areas, approximately 90 percent of the Tongass is off-limits to timber harvesting, including wilderness areas, refuges, wild and scenic river corridors, and inventoried roadless areas. Of the remaining land opened to resource management activities, six percent is comprised of previously roaded areas that are not scheduled for harvest under the current TLMP. Another two percent consists of previously roaded areas that are scheduled for harvest over the next 100 years, but half of this acreage is young forest that will not reach maturity for another 50 years. The remaining two percent is in roadless areas that are scheduled for harvest over the same period. It is essential that timber from this small portion of the roadless forest be made available for harvest, as originally intended.

It should be recognized in the EIS what is necessary to truly restore the economic health of local communities in Southeast Alaska and reverse the decline in rural employment and population in the region. While the intention and goals of the Wrangell Island project are worthy, restoration projects, trail construction, and other activities envisioned for the project will not replace year-round, well-paying timber jobs, and rejuvenate the economy.

Since 1997, the Southeast Alaska population has steadily declined and this downward trend is forecasted to continue in coming years. While Alaska’s population has grown, Southeast Alaska has lost nearly 4,500 people since 1997. A new TLMP was issued in 1997, and it sharply reduced allowable harvest levels. Today, logging and wood products employment remains a mere shadow of its recent past, falling from 4,600 jobs in the early 1990s to approximately several hundred in 2009. A new Wrangell Island project designed to conform with the original intent of the ten-year timber sales with volumes of 150 MMBF to 200 MMBF would be a significant step in the right direction in reversing the region’s population and economic decline. Moreover, such harvest levels over a ten-year period would help sustain the remaining industry infrastructure in the region that will eventually be needed to process second-growth timber.

While the Wrangell Island project is intended to facilitate the transition to a sustainable forest products industry based on second-growth timber harvests, the length of the transition period needs to be acknowledged, and recognized through better second-growth inventories so that stakeholders can recognize and reach agreement on the transition period. Meanwhile, economically viable harvests of existing mature timber stands should continue in both roaded and roadless areas, accompanied by appropriate harvest prescriptions that encourage second-growth propagation. While second-growth timber will be the future foundation of the timber industry, the transition will take decades. In the meantime, it is imperative significant volumes of economic timber in roaded and roadless areas be released over a tenyear period to sustain the forest products industry and rural economies.

In summary, the Forest Service can revitalize the forest products industry and the Southeast Alaska economy by packaging the Wrangell Island project as a single sale releasing an economic timber volume of 150 MMBF to 200 MMBF over a ten-year duration. Breaking the project into a variety of activities is the wrong approach and will fall far short of the original intent of the project. Thank you for the opportunity to provide scoping comments on the Wrangell Island project.

Resource Development Council for Alaska, Inc.