Copper Timber Sale by ert554898

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									        Copper Timber Sale Comments & Responses
        Department of Natural Resources, Division of Forestry
        December 2006
        The following comments were received during the public comment period on the Copper Timber Sale.
        Organization                                                                    Author                          Location
        Alaska Center for the Environment                                               Eric Uhde                       Anchorage
                                                                                        Lynda Barcombe                  Willow
                                                                                        Suzanne Bounds                  Willow
                                                                                        Joan Bryner                     Willow
                                                                                        Randy Carter                    Willow
        Cascadia Wildlands Project                                                      Gabriel Scott                   Cordova
                                                                                        Steve and Talyne Corlyn-Belka   Meadow Lakes
                                                                                        Mr. & Mrs. James Denison        Long Beach, CA
                                                                                        Mary Lou Frahm                  Willow
                                                                                        Doug Gualtieri                  Talkeetna
                                                                                        Pat Joensuu
                                                                                        Dave Korpi                      Willow
                                                                                        Richard Leo                     Trapper Creek
                                                                                        Yvonne Leutwyler                Willow
                                                                                        Becky Long                      Talkeetna
                                                                                        Erin McLarnon                   Willow
        OHMP, DNR                                                                       Tom Namtvedt                    Palmer
        OHMP, DNR                                                                       Mike Bethe                      Palmer
                                                                                        Linda Oxley                     Willow
                                                                                        Judy Price                      ?
                                                                                        Peter Pupator                   Anchorage
                                                                                        Scott Purkey                    Willow
        Willow Area Community Organization                                              Mary Shreves, P.E.              Willow
                                                                                        Pat Steige                      Willow
                                                                                        John Strasenburgh               Talkeetna
        Talkeetna Community Council                                                     Jok Bondurant                   Talkeetna
        Willow Area Community Organization                                              Linda Oxley                     Willow
        Y Community Council                                                             Tami Hamler                     Y Community
                                                                                        Vic Young                       Willow
                                                                                        Rudy Wittshirk                  Willow
        Matanuska-Susitna Borough                                                       Susan Lee                       Palmer
                                                                                        Dean Davidson                   Willow




Copper Timber Sale: Comment & Response                                                                                                   1
Abbreviations
ADFG: Alaska Department of Fish and Game
BMPs: Best Management Practices
DBH: diameter at breast height
DPOR: Division of Parks and Outdoor Recreation
DEC: Department of Environmental Conservation
DNR: Department of Natural Resources
DOF: Division of Forestry
FF: Final Finding (Forest Land Use Plan)
FLUP: Forest Land Use Plan
FRPA: Alaska Forest Resources and Practices Act
FYSTS: Five Year Schedule of Timber Sales
OHMP: Office of Habitat Management and Permitting
PD: Preliminary Decision (Forest Land Use Plan)
SHPO: State Historic Preservation Office
SFG: Susitna Forestry Guidelines




Copper Timber Sale: Comment & Response              2
Commenter         Comment                                                                          Response
                  General Support
Joensuu           Thank you for the opportunity to comment on the proposed Copper Timber           Comment noted.
                  Sale. NPI would like to go on record in support of this sale. We believe sound
                  forest management includes timber harvest, which promotes new, healthy
                  forests, as well as enhanced wildlife habitat, and wildfire mitigation.

                  We are pleased with the Division of Forestry's efforts to prepare economic
                  timber offerings for a forest industry based on fiber and bio-mass, instead of
                  board feet. We would like to encourage you to begin using green short
                  tons/acre as the unit for all forest products.

Young             Go for it! It will create jobs and makes good moose habitat.                     Comment noted.
                  Please proceed with timber sales.

                  Anadromous fish
OHMP              The Office of Habitat Management and Permitting (OHMP) has reviewed the          Changes made.
                  proposed Forest Land Use Plan for the Copper Timber Sale and we only have
                  minor comments. Please correct the following errors in text.

                  Page 16
                  and Stream 247-41-10200-2130- (Little Willow Creek) in the southwest corner
                  of Section 16, T21N, R3W.

                  page 17
                  Secondary roads will also cross two streams cataloged as anadromous
                  downstream of the crossings. A road will cross Stream 247-41-10200-2130-
                  3036, in the southwest corner of Section 34, T21N, R3W and is immediately
                  above the documented upper limit of rearing coho and king salmon.

                  The crossing across Stream 247-41-10200-2130-3044 in the northwest northeast
                  corner of Section 31, T 21N, R3W is over 4,500 feet east of the documented
                  upper limit of rearing coho and king salmon.




Copper Timber Sale: Comment & Response                                                                              3
Commenter         Comment                                                                            Response
Gualtieri         The impacts on the soil, and watersheds in the area, as well as the salmonid and   The Forest Resources and Practices Act (FRPA) was designed to protect
                  other fish in the adjacent rivers and streams are irreversible.                    soil, watersheds, and fish, with strict guidelines for riparian management,
                                                                                                     reforestation, and fish and wildlife habitat protection. The DOF is required
                                                                                                     by the FRPA to monitor timber harvest operations for compliance with the
                                                                                                     Act and its best management practices (regulations). The DOF will
                                                                                                     monitor the timber sale through regular inspections and through additional
                                                                                                     “as needed” visits to the site to ensure compliance by the purchaser with all
                                                                                                     aspects of the contract.
                                                                                                     All streams capable of supporting anadromous or resident fish are protected
                                                                                                     with 100 or 300 foot buffers. All anadromous streams identified by
                                                                                                     ADF&G in their Anadromous Waters Catalog were buffered 300 feet on
                                                                                                     each bank. In addition, any stream found in the field capable of supporting
                                                                                                     anadromous or resident fish were protected with 100 foot buffers on each
                                                                                                     bank. [continued in next row]




Copper Timber Sale: Comment & Response                                                                                                                  4
Commenter         Comment                                                                              Response
Cascadia          It is a very good thing that at least now there are regulations protecting           The FRPA was amended in the summer of 2006 to apply new riparian
                  anadromous streams in the Southcentral region. Please enforce these regulations      standards to streams in Southcentral Alaska (Region II). These new
                  to the maximum degree possible. The measures taken for fisheries are a great         standards are the result of an intensive analysis by DOF, DF&G, DEC, and
                  improvement over some past practices. Thank you in particular for protecting         OHMP for the protection of anadromous and high-value fish habitat
                  the uncataloged streams that, nonetheless, are likely to have fish present, the      specific to the southcentral region. The streams in the Copper Sale Area
                  same way as if they were cataloged. (p. 17) I suggest DoF not rely only on           fall into the II-C and II-D classifications.
                  OHMP to identify fish and wildlife concerns, but also exercise your own              • Type II-C waterbodies are anadromous or high-value resident fish
                  conservative judgement.                                                                    streams with:
                                                                                                                • Confined reaches of non-glacial waters >3’ wide.
                  As you know, BMPs and state regulations do not eliminate watershed impacts.                   • Unconfined reaches of glacial waters >3’wide and <50’ wide
                  Increased flooding and erosion are a likely consequence. The many small                       • Lakes
                  streams that aren’t protected will see their water quality degraded. The value of             • Kenai, Kasilof, and Lake Fork Crescent Rivers.
                  the cut trees is so low, it is easily worth it to forego logging whenever probable
                  negative impacts are identified.                                                     •   Type II-D waterbodies are anadromous or high-value resident fish
                                                                                                           streams that are less than or equal to 3 feet wide.
                                                                                                       For state land along waterbodies classified as Type II-C, harvest of timber
                                                                                                       may not be undertaken within 100 feet of the water body. For state land
                                                                                                       along Type II-D waterbodies, there is a 100-foot riparian area; harvest of
                                                                                                       timber may not be undertaken within 50 feet of the water body. Between
                                                                                                       50 feet and 100 feet from a Type II-D water body, harvest may occur, but
                                                                                                       shall not create flow paths or ruts that could channelize sheet flow or
                                                                                                       introduce sediment into the water body. In addition, along both Type II-C
                                                                                                       and II-D streams on state land, there is a special management zone from
                                                                                                       100 feet to 300 feet. Timber harvest in this zone must be consistent with
                                                                                                       the maintenance or enhancement of important wildlife habitat, as
                                                                                                       determined by the Office of Habitat Management and Permitting, and must
                                                                                                       be approved by them.
                                                                                                       Watershed impacts: BMPs cannot totally eliminate sediment entering
                                                                                                       waterbodies, but are designed to minimize the impact caused by sediment
                                                                                                       entering a waterbody. For example, 11 AAC 95.295(f) states: An operator
                                                                                                       shall to the extent feasible direct ditchline water away from unstable soils
                                                                                                       and surface waters, and onto vegetated areas. This allows the sediment
                                                                                                       collected in the ditch to filter out onto the forest floor before it reaches
                                                                                                       streams and ponds. [continued in next row]




Copper Timber Sale: Comment & Response                                                                                                                    5
Commenter         Comment                                                                            Response
                                                                                                     Another example is 11 AAC 95.365(g) which requires skid trails, at the
                                                                                                     completion of operations, to be water-barred or otherwise stabilized to
                                                                                                     prevent eroded soil from entering surface waters.
                                                                                                     These BMPs and many other forestry-specific standards in the Alaska
                                                                                                     Forest Resources and Practices Regulations were approved by the Alaska
                                                                                                     Department of Environmental Conservation to control nonpoint source
                                                                                                     pollution as outlined in Section 319 of the Clean Water Act.
                                                                                                     In addition, the requirements of the Susitna Forestry Guidelines further
                                                                                                     reduce the potential of introducing sediments to the area’s waters. The 330
                                                                                                     foot leave strips required between harvest units provide an additional
                                                                                                     undisturbed forest floor, which allows any sediment to settle out of the
                                                                                                     water, if it was not intercepted by the best management practices during
                                                                                                     logging operations. The 100-foot buffers along wetlands serve the same
                                                                                                     function.
Barcome           Additionally, I am concerned for the waterways in this area. What protective       The Kashwitna Management Plan (KMP) requires a ¼ mile (1,320 feet)
                  measures are in place to protect Little Willow Creek and other fresh water         vegetation management zone along Little Willow Creek. Any management
                  sources? Are these to also be a part of the sacrifice?                             activities allowed within this zone are for the maintenance or enhancement
                                                                                                     of wildlife habitat, recreation, or to control outbreaks of insects, disease,
                                                                                                     wildfire, or hazards to public safety. Any vegetation management activities
                                                                                                     by DOF will be reviewed by DPOR and ADFG with due deference given to
                                                                                                     ADFG. The DOF is not planning on harvesting within the ¼ mile corridor
                                                                                                     other than what will be necessary for clearing the right-of-way for safety
                                                                                                     and operational reasons during the construction of the Willer-Kash Road.
                                                                                                     The KMP stipulates that the road not be located parallel to the Little
                                                                                                     Willow creek within ¼ mile of the stream where prudent. The Division of
                                                                                                     Parks and Outdoor Recreation (DPOR) and ADFG are also required to
                                                                                                     perform a recreational analysis prior to DOF constructing the Little Willow
                                                                                                     crossing. The findings of the analysis will be incorporated into the final
                                                                                                     design to accommodate and mitigate the likely increased use in the area.
ACE               The proposed timber sale also identifies a number of high value anadromous         The sale was designed using an iterative process. The DOF initially looked
                  streams that will potentially be impacted including Little Willow Creek.           at harvesting quite a number of additional areas. The units were modified
                  Although buffer strips will be utilized pursuant to the Forest Resources           extensively to protect resources, and in some cases were completely
                  Practices Act several of the streams will be crossed by bridges as part of the     dropped from the plan due to cost or risk to the state’s resources.
                  logging infrastructure. The FLUP claims that the road networks will have
                                                                                                     The timber sale was designed to be economically harvested using the
                  minimal impacts on water quality and wherever possible the plan avoided routes
                                                                                                     capabilities and equipment of local operators. Different logging systems
                  that would cross surface drainages. FLUP at 9, 18. However, this is impossible
                                                                                                     would not accomplish the proactive forest management and habitat
                  to determine since there were no other alternatives that considered a different
                                                                                                     objectives described in the Forest Land Use Plan.
                  logging infrastructure. It is in the state’s best interest to protect anadromous
                  streams thus potentially less invasive alternatives should properly be reviewed.   Local operators use various ground-based systems which include hand or
                                                                                                     mechanized felling, tracked or wheeled skidders, and forwarders. Operators
                                                                                                     using cable, balloon, and helicopter logging systems are not available
                                                                                                     locally. These systems are much more expensive to operate and would not
Copper Timber Sale: Comment & Response                                                                                                                  6
Commenter         Comment                                                                              Response
                                                                                                       be economical given the value of the timber.
                                                                                                       These other systems would either not reduce the number of roads or, if they
                                                                                                       did, would not provide access to the harvested areas for post-harvest
                                                                                                       scarification. Scarification is accomplished using machinery to expose
                                                                                                       soils and provide ideal conditions for the establishment of birch seedlings.
                                                                                                       Without scarification, the DOF would not achieve the objectives of
                                                                                                       replacing mature birch stands with new healthy stands of regrowth and
                                                                                                       provide early successional stages for wildlife.
                  Moose
ACE               Here the FLUP states that moose are found in the area and extensively use the        The adjacent CHA does support a high density moose population, as noted
                  Little Willow Creek as a migration corridor. FLUP at 15. While the FLUP              on page 17 of the Kashwitna Management Plan.
                  claims that this area does not represent ideal overwintering habitat for moose, it
                                                                                                       Change made: We have added this information to the FLUP.
                  says nothing about the use of the adjacent critical habitat area by moose.
                  Furthermore, it fails to analyze the effect that the permanent extension of the      When the Kashwitna Plan was written, the CHA was already in place. In
                  Willer-Kash Road may have on wildlife in this area and the adjacent WMCHA.           fact, the Kashwitna Plan was written precisely because there are high
                  In fact, more access routes may lead to a decline in the moose population which      values for both wildlife and forestry in this area. The Willow Subbasin
                  bears directly on hunting and subsistence activities in the region. As the FLUP      Area Plan stated that “a management plan will be necessary to design
                  asserts, timber harvest may enhance moose habitat in the short term, however         roads, schedule timber and farm sales, and develop detailed management
                  this must be balanced against the disturbances that will occur and the impacts       guidelines to minimize conflicts among land users.” The Kashwitna Plan
                  on overwintering moose now and in the future. Thus, the FLUP’s cursory               fulfills that requirement, to allow multiple uses to occur, while still
                  overview of the benefits that moose will experience if the timber harvest occurs     protecting wildlife habitat. The Susitna Forestry Guidelines provide rules
                  utterly fails to analyze the negative impacts.                                       for timber management on state lands throughout the Susitna Valley,
                                                                                                       precisely because of the high-value wildlife habitat in the area. These plans
                                                                                                       together provide for a mix of uses, while protecting wildlife habitat.
                                                                                                       Even after the harvest, there will be many forested acres left in the area.
                                                                                                       The total gross acreage of the Copper sale area is 4,575 acres. Of that, 519
                                                                                                       acres are wetlands and another 21 acres have been harvested for wildlife
                                                                                                       habitat; leaving 4,035 forested acres or 88 percent as forested lands. 1,203
                                                                                                       acres or 30% of the forested acreage is proposed for harvest and roads.
                                                                                                       2,832 forested acres or 70% will remain for recreation, wildlife, and other
                                                                                                       forest uses.
                  Willow Mountain CHA
Strasenburgh      As an important side point, please note that I do not see where the FLUP             The FLUP does not require a buffer around the Willow Mountain CHA.
                  requires a buffer between the cut area and the Willow Mountain Critical Habitat      The CHA itself provides for moose and other wildlife, and a buffer around
                  Area. I think there should be a minimum of a ¼ mile buffer.                          it was not specified in the plans for the area. When the Kashwitna Plan was
                                                                                                       written, the CHA was already in place. In fact, the Kashwitna Plan was
Shreves           Regarding the proposed Copper Timber Sale, I am adamantly opposed to this            written precisely because there are high values for both wildlife and
                  idea. Why harvest timber from an area so close to a critical habitat area?           forestry in this area. The Willow Subbasin Area Plan stated that “a
                                                                                                       management plan will be necessary to design roads, schedule timber and


Copper Timber Sale: Comment & Response                                                                                                                    7
Commenter         Comment                                                                              Response
Carter            The fact that the proposed logging area is adjacent to the Willow Mountain           farm sales, and develop detailed management guidelines to minimize
                  Critical Habitat Area just adds insult to injury!                                    conflicts among land users.” The Kashwitna Plan fulfills that requirement,
                                                                                                       to allow multiple uses to occur, while still protecting wildlife habitat. The
                                                                                                       Susitna Forestry Guidelines provide rules for timber management on state
Bounds            The Willow Mountain Critical Habitat Area will be adversely affected
                                                                                                       lands throughout the Susitna Valley, precisely because of the high-value
                                                                                                       wildlife habitat in the area. These plans together provide for a mix of uses,
                                                                                                       while protecting wildlife habitat.
                                                                                                       Even after the harvest, there will be many forested acres left in the area.
                                                                                                       The total gross acreage of the Copper sale area is 4,575 acres. Of that, 519
                                                                                                       acres are wetlands and another 21 acres have been harvested for wildlife
                                                                                                       habitat; leaving 4,035 forested acres or 88 percent as forested lands. 1,203
                                                                                                       acres or 30% of the forested acreage is proposed for harvest and roads.
                                                                                                       2,832 forested acres or 70% will remain for recreation, wildlife, and other
                                                                                                       forest uses.
                  Wildlife
Wittshirk         Frankly, this plan will pock-mark the area, facilitate further haphazard             See response to comments on Moose by ACE, above. The plans governing
                  development, and will have wildland wildlife impact far beyond this area. Little     the land use in the area provide for multiple uses, protecting wildlife habitat
                  Willow Creek will have it's upper reaches invaded. These changes are not even        values and providing for timber harvest at the same time.
                  addressed in this desperate plan.
                                                                                                       See the Trails section for a response to the comment about eliminating
Price             The Copper Timber Sale proposed for the Willow area is NOT the best use of
                                                                                                       human uses of the land.
                  these lands. As a resident of the upper valley, I am opposed to this timber sale
                  as it would diminish wildlife, eliminate the present human uses of the land,         See the Anadromous Fish section for a response to the comment about
                  cause detrimental effects to the soils and waterways within and downstream of        effects on the aquatic species.
                  the area thereby affecting aquatic species, and encourage the future use of
                                                                                                       See the Invasives section for a response to the comment about invasive
                  herbicides (for site preparation and for plant "invasives" that would tend to
                                                                                                       species.
                  colonize the disturbed ground).
                                                                                                       The DOF worked with ADFG, specifically, the Division of Wildlife
ACE               Moreover, while the FLUP makes reference to moose populations in the harvest         Conservation, on this sale, not only by providing them with a copy of the
                  zone it fails to analyze impacts in the adjacent WMCHA. The SFG requires             FLUP, but also by bringing them out to the sale area, and talking to them
                  that before a timber sale is offered “DFG will identify winter moose                 about protecting specific species. In terms of the moose, ADFG biologists
                  concentration areas in individual subunits.” SFG at 20. Furthermore, the SFG         stated that a timber sale in this area will allow better moose browse,
                  states that where practical, the ADF&G “should complete site specific habitat        improving the quality of moose habitat. For marten habitat, ADFG
                  evaluations” of the sale unit for moose before harvesting. SFG at 21. Thus,          biologists stated that the birch forest in the sale area is not the type of
                  both habitat evaluation and identification of wildlife locations are important and   habitat frequently used by marten. Bears were also discussed during the
                  required not just for moose, but also for the protection of marten and bear. See     fieldtrip, and the ADFG biologists had no concerns about bear habitat in the
                  SFG at 21, 37. This is particularly relevant since the adjacent WMCHA                sale area.
                  supports one of the largest concentrations of moose in the state, and provides
                  ample habitat for bear, fox, marten and other fur bearing mammals.

Cascadia          Please protect the two raptor nests. (p.15) Accepted practice elsewhere (e.g.        During the fieldwork for the Copper timber sale, DOF staff found the two
                  Forest Service) is to automatically buffer nests, and cut them down only after       raptor nests in question. The FLUP mistakenly referred to the two nests as
                  non-use has been confirmed for several consecutive years. That you didn’t            being within Copper Timber Sale area. However, the nests are actually
Copper Timber Sale: Comment & Response                                                                                                                     8
Commenter         Comment                                                                                Response
                  notice a bird isn’t a strong indication of anything. What, exactly, is meant by        within the Tin Timber Sale area, not the Copper Sale area. We apologize
                  “the nests will be monitored…” (p.15) Monitored how? By whom?                          for the confusion.
                                                                                                         Change made: the paragraph about the two raptor nests has been deleted.
                  Timing
Oxley             I am praying that a change in governor and hopefully enough of the elected             DOF started this process with the fieldwork last fall, based on demand for
                  officers this upcoming election that this type of waste to satisfy special interests   timber in the area. The sale will not be offered until all the comments have
                  will be a thing of the past. Could you drag your heels a bit? Maybe we can do          been responded to, the final finding of the FLUP has been issued, and the
                  what is right for once for the communities and living that will be so negatively       30-day appeal period has ended, which will be in January, 2007.
                  affected.
Carter            Why the rush to award a contract before the November elections? The current
                  governor's policies were met with a resounding & humiliating defeat in the
                  recent primary. Whoever the next governor is will LISTEN to the will of the
                  people regarding logging in the midst of the WACO area! -- Palin because she's
                  from the Mat-Su valley & Knowles because of his previous track record.
                  Traffic
Carter            Local traffic on Hatcher Pass road (Willow side) has noticably increased over          The contractor will be required to submit a traffic management plan to
                  the past few years as have the number of houses along the road. This raises            address local traffic. Signs will be posted on the road during harvest
                  serious local issues about road condition, safety and noise that would result          operations to advise the public of the added traffic on the road. The
                  from heavy logging equipment traveling the route from Willer-Kash road to the          contractor will also be responsible for entering into road maintenance
                  Parks highway & south to Point MacKenzie daily for 2-3 years. The first                agreements necessary to maintain existing road conditions of the Willer-
                  casualty would be the Hatcher Pass road surface which is already in bad need of        Kash Road and the Shirley Towne Drive. The Department of
                  repair. I can only imagine what locals will think about DNR & NPI (the likely          Transportation and Public Facilitites and the Mat-Su Borough uses truck
                  sole bidder) when they are disturbed daily by the resulting potholes, cracked          weight restrictions as a tool to manage road deterioration caused by large
                  pavement & windshields, and the relentless noise from operations & increased           trucks on all state and Borough maintained roads . Trucks will be required
                  traffic -- we moved out here to get away from all that.                                to follow weight restrictions while operating on state and Borough
                                                                                                         maintained roads.
Bounds            and the traffic of huge machinery on our roads will be both dangerous and              During operations, there will be some disruption to the normal activities of
                  annoying.                                                                              some user groups and neighbors. The Copper Timber Sale is expected to be
                                                                                                         harvested in 3-4 months. Portions of the sale, however, will be harvested in
                                                                                                         the winter, while the remainder will be harvested during the summer and
                                                                                                         fall months, which will break up the operations into smaller periods during
                                                                                                         each season.
                  Road closure and ATV use
Cascadia          A major concern is unmanaged ATV use of the area after roads have been                 The area proposed for timber harvest is already used heavily by ATVs, as
                  punched in. Likely problems range from junk cars, wetland disturbance,                 evidenced by the many trails crisscrossing the area. Using ATVs on state
                  poaching and overhunting. This is a special threat for the Critical Habitat Area,      land does not require a permit; it is a generally allowed use, as long as the
                  as new roads would draw users to that area.                                            vehicles do not break through the vegetated mat.
                                                                                                         Currently, ATVs already access the sale area off of the Willer-Kash Road.
                                                                                                         The ATV trails cross both uplands and wetlands, with most of the ATV
Copper Timber Sale: Comment & Response                                                                                                                       9
Commenter         Comment                                                                           Response
                                                                                                    activity occurring in the fall during the hunting season. One trail is used
                                                                                                    extensively to access the Willow Mountain Critical Habitat Area which is
                                                                                                    also accessed by the established Willow Creek Mountain Trail 4 miles to
                                                                                                    the south.
                                                                                                    The Kashwitna Management Plan anticipated the expansion of ORV use as
                                                                                                    a result of improved access and directs the DNR to establish a special use
                                                                                                    area. The intent of the special use area is to identify routes that can be used
                                                                                                    by ORVs year-round without causing environmental damage and routes
                                                                                                    that can only be used when winter conditions sufficiently protect
                                                                                                    vegetation. Public notification and comments will be required prior to the
                                                                                                    establishment of the special use area, and the area has not yet been
                                                                                                    established.
                                                                                                    As directed by the Kashwitna Management Plan, secondary roads not
                                                                                                    designated as permanent roads will be closed to highway vehicular traffic
                                                                                                    after harvesting. However, DNR, in cooperation with ADFG and the
                                                                                                    Matanuska-Susitna Borough, may designate some secondary roads to
                                                                                                    remain open for ORV trails as part of the Kashwitna Special Use Area, if it
                                                                                                    is created. Adequate funding will need to be allocated for the inspection
                                                                                                    and maintenance of these ORV trails. The winter roads over muskegs and
                                                                                                    wet soils, though, will not be capable of supporting sustained traffic by off-
                                                                                                    road vehicles during non-frozen ground conditions without causing
                                                                                                    degradation of the road bed.
                                                                                                    As mandated by 11 AAC 95.320:
                                                                                                    •   Roads and ditches will be left in a condition that will control erosion.
                                                                                                    •   In areas accessible to highway vehicles, the road is blocked so that a
                                                                                                        four-wheeled highway vehicle cannot pass the point of blockage.
                                                                                                    •   Bridges, culverts, and fills are removed from surface waters.
                  Kashwitna Plan
Wittshirk         It's a great deal for NPR---a lousy deal for us. This cutting down, grinding up   As described in the FLUP, the decision to offer the Copper Timber Sale
                  and shipping out of our wilderness areas should not be done. We need a            was based on a long series of planning decisions, made with public and
                  comprehensive land use plan and full, long-term involvement of local residents    agency input every step of the way. There has been a comprehensive land
                  in any consideration of such a drastic change to this area.                       use planning effort, with full involvement of local residents. The Forest
Purkey            Before any logging is done or lands transfered or put up for sale the Kashwitna   Land Use Plan (FLUP) for the timber sale is one of the final steps in this
                  Management plan has to be reopen so the Willow residents have a say in what       long planning process. The planning for where timber harvest is
                  happens in our community not someone living in Anchorage or Wasilla.              appropriate, and where it is not appropriate, is done at a much broader scale
                                                                                                    than the FLUP. The framework for how management decisions are made




Copper Timber Sale: Comment & Response                                                                                                                  10
Commenter         Comment                                                                            Response
ACE               The Kashwitna Management Plan (KMP) was developed in 1991 with the                 for timber sales in the Susitna Valley is as follows:
                  intention of updating the plan periodically as “new data and new technology
                  become available and as changing social or economic conditions place different     1.   Area plans, management plans, and land use plans (in this case, the
                  demands on state lands.” Kashwitna Management Plan at 69. While the                     Willow Sub-basin Area Plan and the Kashwitna Management Plan)
                  Kashwitna Management Plan (KMP) does amend a portion of the older Willow                determine where timber harvesting is allowed.
                  Sub-basin Management Plan for the Kashwitna Management Area and for the            2.   The Susitna Forestry Guidelines and the Forest Resources and
                  Little Willow Creek subunit, the KMP has not been updated in 15 years. This is          Practices Act and Regulations determine how timber will be managed
                  particularly pertinent in light of the enormous social, economic, and                   within areas where harvesting is allowed by the area plan.
                  environmental changes that have taken place since 1991 in the Mat-Su Valley.       3.   The Five-Year Schedule of Timber Sales proposes when timber sales
                                                                                                          will be offered, and approximately where and how big each sale will
                  Currently, the Mat-Su Borough is experiencing a population explosion that               be.
                  makes it the fastest growing region in Alaska. Mat-Su Comprehensive                4.   Next, a Forest Land Use Plan is written for each individual sale, which
                  Economic Development Strategy 2006 at 11. This fact alone places severe                 contains more detailed decisions about each sale.
                  demands on the environment not to mention State land and resources. In
                  addition, a substantially larger population often correlates with increased
                                                                                                     The Kashwitna Plan was written because this area has high values for both
                  demands on land designated for other and/or different uses such as recreational,
                                                                                                     wildlife and forestry. The Willow Subbasin Area Plan stated that “a
                  subsistence, and fish & wildlife rather than forestry. These changes, new data,
                                                                                                     management plan will be necessary to design roads, schedule timber and
                  plans, and planning efforts should be taken into account in a revised KMP.
                                                                                                     farm sales, and develop detailed management guidelines to minimize
                  [continued on next row]                                                            conflicts among land users.” The Kashwitna Plan fulfills that requirement,




Copper Timber Sale: Comment & Response                                                                                                                   11
Commenter         Comment                                                                             Response
                  In addition, the proposed timber sale area is adjacent to the Willow Mountain       allowing multiple uses to occur, while still protecting wildlife habitat. The
                  Critical Habitat Area (WMCHA). Legislatively designated in 1989, the area           Susitna Forestry Guidelines provide rules for timber management on state
                  was set aside specifically to “protect fish and wildlife habitat” and provide       lands throughout the Susitna Valley, precisely because of the high-value
                  recreational opportunities. FLUP at 12. As such the designation required a          wildlife habitat in the area. These plans together provide for a mix of uses,
                  corresponding management plan which has still not been adopted. AS.                 while protecting wildlife habitat.
                  20.620(b). Of particular importance is the lack of any management plan to
                                                                                                      The planning staff in the Division of Mining, Land and Water has begun to
                  address disturbances on adjacent lands and management strategies to minimize
                                                                                                      update the Willow Subbasin Plan, which will incorporate the management
                  negative impacts on wildlife, especially moose and bear. No plan, including the
                                                                                                      plans within its boundaries, including the Kashwitna Management Plan.
                  FLUP, adequately analyzes these issues. Therefore, the timber sale should not
                                                                                                      The Division of Forestry will work with the planning staff on updating the
                  take place until management strategies are developed so as not to frustrate the
                                                                                                      Willow Subbasin Plan, but in the meantime, we will continue to abide by
                  legislative intent behind creating the critical habitat area.
                                                                                                      the existing guidelines.
                  The KMP also dedicated its planning area largely for multiple uses. Among its       See also responses to comments on Willow Mountain Critical Habitat Area.
                  other deficiencies, the FLUP does not adequately take into account the value of
                  all uses, including fish and wildlife, habitat, and recreation, and weigh them in
                  the balance with the economic and other values associated with cutting timber.
                  An adequate analysis requires a level of quantitative and qualitative data that
                  reflects the current situation that is missing from the FLUP. In the meantime,
                  the timber sale should not occur since a timber harvest may otherwise prejudice
                  the outcome of a revised KMP and any other plan that may decide the area
                  should be devoted to non-forestry uses.
                  …
                  Furthermore, the alternatives section in the FLUP fails to meaningfully consider
                  any alternative. For instance, the rationale behind Alternative 1, the selected
                  alternative, purports to comply with all management plans, goals, and objectives
                  but it fails to consider that the Kashwitna Management Plan has not been
                  updated in 15 years. For a meaningful analysis to occur the proposed timber
                  harvest should properly be based on an area management plan that considers
                  current environmental, economic, and social dynamics in the region. The
                  preferred alternative analysis fails to meet this standard. Thus, due to the
                  outdated nature of the material for which this preferred alternative relies, it
                  should not be considered until the KMP is revised and current information is
                  integrated into the analysis.
                  Tourism
Denison           We are not Alaskan residents, but we have visited Alaska five times for the         Please see reponses to comments above, in the Kashwitna Plan section.
                  same reason millions of other tourists visit Alaska--for its wilderness quality     Even after the harvest, there will be many forested acres left in the area.
                  and its wildlife! We travel thousands of miles at great expense to see true         The total gross acreage of the Copper sale area is 4,575 acres. Of that, 519
                  wilderness and the wildlife ALIVE in their natural habitat! We don't go to all      acres are wetlands and another 21 acres have been harvested for wildlife
                  this trouble and expense to see tree stumps and no wildlife!                        habitat; leaving 4,035 forested acres or 88 percent as forested lands. 1,203
                  We were very concerned on our last few visits to see more clearcut forests, and     acres or 30% of the forested acreage is proposed for harvest and roads.
                  nary a wolf or bear!                                                                2,832 forested acres or 70% will remain for recreation, wildlife, and other
                                                                                                      forest uses.
                  This plan states that this logging serves "the best interest of the state". We
                                                                                                      In addition, the Willow Mountain Critical Habitat Area is located adjacent
Copper Timber Sale: Comment & Response                                                                                                                   12
Commenter         Comment                                                                               Response
                  strongly disagree with you; we believe clearcutting old growth forests serves the     to the sale, which provides additional lands for wildlife habitat.
                  interests of the timber corporations and provides more browse area ( moose
                                                                                                        For an explanation of the impacts of timber harvest on moose and other
                  targets for hunters), but, in the long term, it will not be in the best interest of
                                                                                                        wildlife species, please see the responses to comments in the sections above
                  Alaskans or tourism, a very important source of revenue.
                                                                                                        on “Moose.” The management plans that guide activities in the area allow
                                                                                                        for a mix of uses in the area, including timber harvest, while protecting
                  It matters little whether the road building and clearcutting is done piece-by-
                                                                                                        wildlife values.
                  piece or in huge tracts, the ultimate result is the same; fragmentation and
                  devastation of wilderness areas--the ones so many of us travel thousands of           Visual impact from the sale will be nonexistent from the Parks Highway or
                  miles--at great expense- to see and experience--and the vanishing wildlife we         the Willow-Fishhook Road (Hatcher Pass Road). The closest harvest unit
                  hope to see. .                                                                        will be over 4.5 miles from the Parks Highway and 3.5 mile away from the
                                                                                                        Willow-Fishhook Road. It may be possible to see some of the higher
                                                                                                        harvest units on the eastern edge of the area from the Parks Highway, but
                                                                                                        they will be over 7.5 miles away. Furthermore, the harvest units were laid
                                                                                                        out with uneven edges to benefit wildlife, which will make the harvest
                                                                                                        areas look like natural muskegs and meadows from a distance.
ACE               Likewise, although scenic viewing is one of the protected uses in the area, the       In terms of specific scenic values, the areas that have been particularly
                  FLP fails to adequately analyze the impacts the sale would have on ORV and            noted in the Susitna Forestry Guidelines for protection are along roads and
                  other recreational users. FLUP at 19, 20. While three state trails will have a        along the popular recreational boating rivers: the Susitna, Kahiltna, and
                  150 foot buffer on each side, lesser used trails will not. The FLUP specifically      Deshka rivers. Timber harvests in these units must be designed to minimize
                  identifies a network of lesser trails made by hunters and ORV users that also         adverse impacts on visual quality there. Other areas that have scenic values
                  cross the proposed sale site. FLUP at 18. These trails will not be buffered and       that must be protected are views along the Parks Highway, the Talkeetna
                  thus recreational users will be impacted by the timber harvest. This is not           Cutoff, Petersville Road, and the Alaska Railroad. The timber harvest will
                  addressed in the FLUP.                                                                not be visible from any of these roads, except that it may be possible to see
                                                                                                        some of the higher harvest units on the eastern edge of the area from the
                                                                                                        Parks Highway, but they will be over 7.5 miles away. Furthermore, the
                                                                                                        harvest units were laid out with uneven edges to benefit wildlife, which will
                                                                                                        make the harvest areas look like natural muskegs and meadows from a
                                                                                                        distance.
                                                                                                        These scenic resources guidelines are intended to protect scenic values that
                                                                                                        are used by many people—for example, along highways and popular
                                                                                                        boating rivers. Even so, ORV users riding far off the highway will
                                                                                                        experience a relatively small impact because of the small size of each of the
                                                                                                        harvest units and the uneven edges of the cuts, which will reflect natural
                                                                                                        vegetation patterns.
                                                                                                        The sale area consists of 46 cutting units, with an average size of 25 acres.
                                                                                                        Unit sizes range from 4 to 50 acres. In the few units that are larger than 50
                                                                                                        acres, islands of timber will be included in the final layout of the unit, so
                                                                                                        that the harvested area in the unit will be no larger than 50 acres. The
                                                                                                        proposed units have been properly buffered between themselves with 330
                                                                                                        foot no-cut areas as required by the SFG. The SFG also limits cutting
                                                                                                        openings: “Cutting openings generally shall be no wider than
                                                                                                        approximately 660 feet to allow access to cover for bears and moose and to
Copper Timber Sale: Comment & Response                                                                                                                      13
Commenter         Comment                                                                               Response
                                                                                                        encourage full utilization of browse.”
                                                                                                        The roads that will be built for the timber harvest will add to the network of
                                                                                                        trails already in place in the area, and are unlikely to have a negative impact
                                                                                                        on the trails currently in place. DOF will work with trail users to determine
                                                                                                        which trails can be connected with new forest roads as the timber harvest
                                                                                                        occurs.
                  Recreation
Gualtieri         The impact on the local economy from a recreational standpoint can't be               The planning documents that guide land use in this area were developed to
                  calculated as once the habitat is gone, it can't be replaced. Please leave OUR        provide a mix of uses, so that high timber values and wildlife habitat values
                  forests alone, or at the very least manage them in a RESPONSIBLE manner               could both be accommodated. The Kashwitna Management Plan and the
                  that, as our Constitution mandates, benefits us all.                                  Susitna Forestry Guidelines were designed to ensure balanced land
                                                                                                        management. See the section for “Kashwitna Plan” for more information on
                                                                                                        the comprehensive public planning process.
                  Cultural sites
Mat-Su            The Cultural Resources Division finds that there are no recorded sites in the         The FLUP addressed this issue on page 20:
Borough           immediate area of the proposed timber sale. This conclusion was derived
                                                                                                        “During the course of activities associated with this timber sale, cultural
                  through research of the documented sites on file in the MSB Cultural Resources
                                                                                                        and/or paleontological resources may be inadvertently discovered. Should
                  Division and sites documented in the State Office of History and Archaeology.
                                                                                                        such a discovery occur, the site shall be protected from any disturbance,
                  The records are not complete and areas such as this with numerous waterways
                                                                                                        and DOF will contact SHPO and the Mat-Su Borough’s Cultural Resources
                  were transportation corridors as well as centers for subsistence activities both in
                                                                                                        Specialist immediately so that compliance with state laws governing
                  prehistoric and historic times. The Dena’ina names for Iton Creek an dLIttle
                                                                                                        cultural resources may begin.”
                  Creek are found in Shem Pete’s Alaska: The Territory of the Upper Cook Inlet
                  Dena’ina and it is noted that there is a trail that was used by the Kroto band of
                  Dena’ina in the Talkeetna Mountains. The MSB Cultural Resources Dvision
                  requests that the State Office of History and Archaeology be immediately
                  notified about this proposed sale and that the SHPO’s recommendations be
                  followed. In addition, we would appreciate the change to document any cultural
                  remains found as a result of this action and to receive a copy of any survey
                  results. Please contact the MSB Cultural Resources office so that we might
                  record any cultural materials that may be observed. In the event that human
                  remains are encountered, all construction activiey must cease instantly and the
                  Alaska State Troopers immediately notified. (Fran Seager-Boss, Cultural
                  Resources Specialist, 745-9859).
                  SuForest Guidelines
ACE               The FLUP describes the process that leads to an agency decision allowing              The planning staff in the DNR’s Division of Mining, Land and Water has
                  timber harvest in a specified area/region. Specifically, area, management, and        begun to update the Willow Subbasin Plan, which will incorporate the
                  land use plans “determine where timber harvesting is allowed”, the Susitna            management plans within its boundaries, including the Kashwitna
                  Forestry Guidelines (SFG) determine timber harvest methods, and the FLUP is           Management Plan. The Division of Forestry will work with the planning
                  the detailed information document that describes the decisions about each             staff on updating the Willow Subbasin Plan, but in the meantime, we will
                  individual sale. FLUP at 5. The FLUP is therefore a compilation of
Copper Timber Sale: Comment & Response                                                                                                                      14
Commenter         Comment                                                                                Response
                  information that draws from the other plans and considers the best available           continue to abide by the existing guidelines.
                  data. AS. 38.05.112(b). Here however, this management decision was based on
                                                                                                         The Susitna Forestry Guidelines were adopted in 1991, and were intended
                  outdated area and management plans, an outdated set of guidelines in the SFG,
                                                                                                         to guide forest management for the next ten years (through 2001, see Page
                  and a FLUP that is based on a series of conclusory statements with very little
                                                                                                         1 in the SFG). The DOF is gathering data to begin to update the SFG, but in
                  analysis to back it up. As such, the best available data was not used which
                                                                                                         the meantime, we will continue to abide by the existing guidelines. The
                  ultimately frustrates the public review process. Until this is remedied the sale
                                                                                                         Susitna Forestry Guidelines were developed to clearly define how timber
                  should not take place.
                                                                                                         harvest would be done while protecting the other uses. The SFG
                  …
                                                                                                         recognizes the importance of non-timber values in the area, and protects
                  The SFG is overdue for revision. The SFG was to operate only through 2001,             them while providing access to timber resources. As you state, the SFG
                  and then be revised to reflect current conditions. SFG at 1. Thus, before the          contains “environmentally friendly limitations and restriction.”
                  sale contemplated in the FLUP goes forward, the SFG must be updated to
                                                                                                         There is no sunset clause on either of these plans, only recommended
                  reflect current science, data, and public comment, which can then be applied to
                                                                                                         revision dates.
                  the proposed sale. We do not mean to suggest, however, that in the meantime
                  DNR should abandon the environmentally friendly limitations and restriction in
                  the SFG; these should remain in place. DNR should not, however, take action
                  which would have the effect of prejudicing the possible outcome of planning
                  processes intended to update the SAP and SFG.

                  Public process
Strasenburgh      These are our, the public’s, forests, and DOF has a duty to manage them wisely         DOF does manage the state’s forest land in the public interest. The
                  and in the public interest. I believe that the FLUP process is deeply and fatally      planning documents that guide timber sales in the Mat-Su were designed to
                  flawed. I believe that DOF is pre-programmed to offer timber for sale, and that        allow a mix of uses, including timber harvest, while protecting other values
                  the FLUP process is mere FLUFF. In that regard, DOF is doing the public a              and uses.
                  disservice. The FLUP does not, by any stretch of the imagination, “provide
                                                                                                         The Copper Timber Sale was included in the DOF’s Mat-Su Southwest
                  sufficient information for reviewers to ensure that the best interest of the state
                                                                                                         Area and Kenai Kodiak Five Year Schedule of Timber Sales for 2005 to
                  will be served…”
                                                                                                         2009. The Schedule was published in January 2005 and noticed for public
                                                                                                         comment in local newspapers, post offices, and on the DNR website in
Steige            What is this sale? Where is it? I just an hour ago received this card telling me
                                                                                                         February. The notice was also sent to agencies, Mat-Su community
                  about it. Any public hearings? Is this private or state land? When is it?
                                                                                                         councils, tribal councils, Native corporations, planning commissions,
                                                                                                         Legislative offices, conservation groups, small mill operators, timber
Purkey            To be honest I don't think my email means sqat to anyone at the state or               industry representatives, and private citizens. Twenty-nine comments were
                  borough level for that matter. Bye that I mean this is just part of formalities that
                                                                                                         received.
                  has to be put up with before you all do what you want anyway. The state will
                  make very little money on this. It seems to me that the state and borough can up       The DOF held two open houses about the FYSTS, one at the Willow
                  date management plans that suit them and not the people.                               Community Center and one at the Trapper Creek Elementary School. Both




Copper Timber Sale: Comment & Response                                                                                                                     15
Commenter         Comment                                                                              Response
Cascadia          You are accustomed to receiving very little public comment on your decisions.        of these events were advertised as a public service announcement through
                  Perhaps part of the reason why is that people are wise to the fact that when they    the KTNA Public Radio Station, as well as in the Talkeetna Times and
                  comment, the decision-maker isn’t listening. Having never once seen the State        Frontiersman newspapers. The Trapper Creek event was attended by 13
                  of Alaska alter any decision of this sort due to public comment, even where that     people and received two comments and two requests for copies of the Five
                  comment is overwhelming, I am a little uncertain how or why to comment here.         Year Schedule of Timber Sales. The Willow presentation was attended by
                  The public notice indicated comments are particularly desired with regard to the     6 people and no comments were received.
                  proposal’s “consistency with the affected local coastal district management
                                                                                                       All of these comments were taken into account when writing the Forest
                  program.” That obscure and virtually worthless set of regulations is a very
                                                                                                       Land Use Plan (FLUP). The comments we receive on each of our FLUPs
                  strange area to seek public comment.
                                                                                                       influence the final finding. For example, for the West Petersville sale, in
                                                                                                       response to public comment, we changed the sale boundaries, included
                  If it is possible for a bureaucracy to make a Freudian slip, there is one here
                                                                                                       additional stipulations in the timber sale contract for the timber operator
                  where the public notice indicates the Director “will make a written final
                                                                                                       (for example, hours of operation), added guidelines to prevent the spread of
                  decision that the sale is in the best interest of the State.”
                                                                                                       invasive species, and added more information and guidelines about wildlife
                                                                                                       habitat, fish habitat, transportation, and other resources and uses.
                  I would like to please urge that you seriously consider public comment on this
                  proposal with regard to whether or not it is in the state’s best interests, per AS   The DOF carefully considers each comment we receive, and responds to it,
                  38.05.035(e) and Article VIII of the Alaska Constitution, and withhold making        showing how we have changed the final finding if a change was necessary,
                  your decision until after comments have been solicited and considered. “Best         or explaining why we did not change it if it was not necessary.
                  interest of the State,” is not an incantation you are required to utter, but a
                  conclusion you are required to come to considering public comment.



                  Trails
Mat-Su Borough    There are existing trails located in the proposed harvest areas. Maintain            The Willer-Kash Road, the Willow Creek Mountain, Link, and Central
                  integrity of trials during logging operations. See trail locations on enclosed map   Trails are very popular with mushers and snowmobilers in the winter and
                  (Bruce Paulsen, Land Management Specialist, 745-9867).                               hikers and ORV users in the summer. As required by the Kashwitna
WACO              Willow prides itself in claiming the ``Recreational Capital of Alaska.'' One         Management Plan and the Susitna Forestry Guidelines, a 300 foot buffer
                  large component of local recreation is the trails in the timber sale area.           (150 feet on each side of the trail’s centerline) is required to protect the
                  WACO's recently adopted Willow AreaTrail Plan states that the wisest and best        trails. Minimal management activities such as clearing blown down trees
                  use of the land in the sale area is for recreation and mushing habitat. The Plan     may occur within these buffers. Roads are allowed, but they must cross 90
                  also requests that the Kashwitna Management Plan and the Willow Sub Basin            degrees to the trail whenever possible.
                  Plan be updated with recreation and mushing habitat being the best use in many
                                                                                                       The Willer-Kash Road is protected by the Kashwitna Management Plan by
                  areas effected by the sale. Please see the enclosed the Willow Area Trail Plan.
                                                                                                       a 330 foot buffer zone from each edge of the road’s right-of-way and a 170
                                                                                                       foot management zone extending from the outer edge of the buffer zone.
                  The trails in the effected area considered vital for dog mushers training for the
                                                                                                       The purpose of the buffer is to provide wildlife cover, recreational
                  Iditarod, the Yukon Quest, the Fur Rondevous and many other classic races.
                                                                                                       opportunities, and to protect visual quality along the road. The purpose of
                  During the logging operations, the trails will be ``limited'' as described in the
                                                                                                       the management zone is to provide additional wildlife cover and public use.
                  sale's Land Use Plan, but for the many dog teams that train there this will mean
                                                                                                       Timber harvest within these zones requires consultation with the DPOR
                  ``closed.'' After operations are done, logging roads to the cutting areas will not
                                                                                                       and ADFG, which has occured. The DOF is not proposing timber harvest
                  have the loops and connections needed for good trail systems.



Copper Timber Sale: Comment & Response                                                                                                                    16
Commenter         Comment                                                                               Response
Shreves           Why harvest timber in the middle of a widely used recreation area, used by            in the road buffer.
                  mushers and snow machiners alike? Why harvest timber in a fairly populated
                                                                                                        The Willer-Kash Road was built by the DOF for forest management
                  area? None of these questions have been answered to my satisfaction. Please
                                                                                                        activities such as timber harvest and wildlife habitat enhancement. Since
                  reconsider this incredibly bad proposal.
                                                                                                        the road was built, local mushers, snowmobilers, ORV users, and hunters
                                                                                                        have used the road as a starting point for trails they have cut for their use.
Purkey            As you know by now Willow residents as well as WACO our communty
                                                                                                        Harvest operations will have an effect on some trails but these effects can
                  council is against this logging to support Point McKenzie. Especially the
                                                                                                        be mitigated. These trails could be re-routed to take advantage of the
                  Willow Dog Mushers Association is against this logging of pecker tree's for
                                                                                                        secondary and spur roads constructed during the harvest. Where rerouting
                  chipping. Again taking money out of the pockets of tax payers,mushers who
                                                                                                        is not feasible, or there is a discontinuity between a road and a trail, the
                  won't be able to use the area to train there dog teams. There can be up to 20 dog
                                                                                                        contractor can use road-construction equipment to keep the trail or a route
                  teams on those trails any given day FYI.
                                                                                                        free of brush so they can continue to be used as needed.
                  …
                  Shirley town/ Willer Kash is the only area to train with hills for races threw out    The DOF is also pursuing the feasibility of widening the Willer-Kash Road
                  the state that are mountainous. I'd be more then glad to have the state pay me for    right-of-way in some areas to accommodate other users while the harvest
                  my time I can't use the area to truck dogs to others places in the state not to       operations are ongoing. The Division of Parks and the Department of Fish
                  mention the cost for someone to watch my other dogs at home. Logging will not         and Game will need to approve the wider right-of-way.
                  stop me from training my dogs in that area. As and Alaskan Army Infantry
                                                                                                        Recreation: Please see responses to comments in Recreation and Tourism
                  Veteran(medically retired) I have the right to use that area. I payed the price for
                                                                                                        sections.
                  it when I served this country.

Oxley             I oppose the Copper Timber Sale because it jeopardizes historical mushing trails
                  in the Willow Area.
                  …
                  If this sale is to take place I strongly request that all trails in the area be
                  protected and maintained before, during and after the sale.
McLarnon          Good day! I am a concerned Willow resident, an avid dog musher and the
                  President of the Willow Dog Mushers Association and I just wanted to pass
                  along that I oppose the Copper Timber Sale because it jeopardizes a historic
                  mushing trail system known as the Emil Stancec / Mail Trail / Tank Trail.

                  This important system of trails helps local kennels train and prepare for a
                  variety of sprint, mid-distance and distance mushing events. Mushing is the
                  state sport and a long-time tradition in Alaska, but as more and more of our
                  trails start to disappear, so will the mushers.

                  I do not oppose all logging practices nor do I oppose other economic
                  development ventures as long as it is done in a responsible manner and
                  traditional uses are protected and maintained.

                  However, until I see a plan that protects and maintains our trails in the Copper
                  Timber Sale area and others I strongly oppose this sale.



Copper Timber Sale: Comment & Response                                                                                                                      17
Commenter         Comment                                                                                Response
Leutwyler         My husband and myself own a sled-dog kennel of 30 huskies and have been
                  training for mid-distance races in the Willow area for almost 10 years. The
                  Willer Kash road is an integral part of the Eric Stancec winter trail system. This
                  trail system is used by many mushers, including several Iditarod contenders, as
                  well as recreational mushers and cross-country skiers. We are all part of
                  conserving Alaska's heritage of dog mushing and wilderness travel. We would
                  feel extremely disappointed if we lost our training grounds to a temporary
                  benefit from the sale of wood - it seems ludicrous to even consider this. We
                  strongly oppose logging along the Willer Kash road, and ask you to reconsider
                  the Copper Timber sales.

Frahm             I oppose the Copper Timber Sale because of the impact to historical
                  mushing trails in the Willow Area. If this sale takes place I strongly request that
                  all trails in the area be protected and maintained before, during and after the
                  sale. A substantial easement around the trails to ensure that use of the trails is
                  not only possible but still asthetically pleasurable must be included in the plan.
Davidson          Also, I am a trail user, and the Willow Area Trail Plan recently approved, again
                  by a unanimous vote, states that the best use for the area in question is for
                  recreation and particularly dog mushing.
Carter            Many folks here want the Willow area to be known as the mushing &
                  recreational capitol of southcentral Alaska. DNR's proposed timber sale would
                  devastate forest habitat, degrade local trails and substantially reduce the area's
                  value for recreational use.
Bryner            In a political season you will hear time and time again all candidates repeating
                  how valuable our trails are, how important it is to keep our Alaskan heritage and
                  maintain our historical trails. Well, this project will be doing just the opposite.
                  There are historical trails in the area which will be reduced to ruts and clear cut.
                  Again, this is to the detriment of the local tourism business and again, it favors
                  large corporations over local business and interest.

Bounds            …and the trails for which Willow is well known will be destroyed and/or
                  comromised.




Copper Timber Sale: Comment & Response                                                                              18
Commenter         Comment                                                                             Response
Barcome           Second of all, I just purchased a home in Willow less than 6 months ago. I
                  moved out to Willow specifically for the training opportunities available to my
                  sled dog team due to the historical trail systems that exist in this area. My
                  property is located on the east side of the Parks Highway, north of Willow-
                  Fishhook Road. Now I learn, through the Trails Committee of WACO and the
                  Willow Dog Mushers Association, that the trails I was so looking forward to
                  exploring this winter is the same area that the state of Alaska is offering up to
                  bids for clear cutting. So you can understand my concerns.
                  I just invested my entire financial being on this new property, only to find that
                  the trails I based this decision on will most likely be lost. Are there any
                  safeguards included in this offer to keep trails open and safe for the community
                  of Willow? If not, then please stop this project before it can begin.

                  Export
Wittshirk         Willow will lose a vital wilderness area in order to facilitate convenient          Part of the DNR’s mission is to provide jobs, habitat, wood, recreation and
                  extraction for a private business and to provide a token payment toward the port    other benfits from state-owned forests. The Willow Subbasin Area Plan
                  project.                                                                            and the Kashwitna Management Plan, through lengthy public processes,
                                                                                                      designated the Kashwitna area for forestry and wildlife habitat to fulfill part




Copper Timber Sale: Comment & Response                                                                                                                    19
Commenter         Comment                                                                               Response
Carter            Finally, this whole proposal smells of corruption -- sadly the halmark of the         of DNR’s mission. The Alaska Forest Resources and Practices Act and
                  Murkowski administration. As the Alaska Daily News article pointed out, the           Regulations and the Susitna Forestry Guidelines, however, establish the
                  only party who spoke in favor of the proposed logging was NPI, LLC, the               parameters by which the DOF can offer timber sales while protecting other
                  wood-chipping company that is likely to be the sole bidder. If this doesn't           resources such as recreation and fisheries.
                  smack of a "sweetheart" deal done behind closed doors I don't know what does.
                                                                                                        The sale provides raw materials to a local processor to produce chips,
                  The area proposed for logging has far more value as wilderness than a load of
                                                                                                        which are a value-added wood product [AS 38.05.123(j)(2)]. In addition,
                  chips heading to Asia. Especially when one factors in the costs of road
                                                                                                        the purchaser of the sale can sell sawlogs to the local mills as has been done
                  deterioration, safety & noise. This proposed sale is little more than a give-away
                                                                                                        with recent state and private timber sales.
                  to special interests much like the Coal-Bed Methane leases. Enough!
                                                                                                        The establishment of a chipping operation in the Mat-Su Borough has
                                                                                                        created a demand for spruce and hardwood chips that was not present 10
                                                                                                        years ago. The DOF is using the timber sales to meet this demand to bring
                                                                                                        this area under active forest management and also create forest diversity
                                                                                                        and wildlife habitat. In the past, contractors were paid to cut trees and
                                                                                                        scarify the ground to make new wildlife habitat. The cost and lack of
                                                                                                        funding for such projects has prohibited more of these projects from
                                                                                                        occurring. Now, with a contractor who can utilize these trees, the state can
                                                                                                        be paid to create some early successional habitat by actively managing the
                                                                                                        forest and also supporting local jobs and businesses.
                                                                                                        This Preliminary Decision is not the final decision. The Preliminary
                                                                                                        Decision is part of the DNR’s public review process. It is meant to solicit
                                                                                                        comments from agencies and the public. These comments, along with the
                                                                                                        best available data, are then used to arrive at a final decision. Please review
                                                                                                        Section F. Planning Framework, on page 4 of the Preliminary Decision for
                                                                                                        a more detailed discussion of the DNR’s public review process. The
                                                                                                        decision is not made behind closed doors.
                  Economics
WACO              The sale is not in the best interest of the State for many reasons, one of which is   The Division of Forestry will not accept any bids that do not meet the
                  the sale will generate very little or no revenue, especially after considering the    division’s costs for the preparation and administration of the sale. Selling
                  costs associated with managing the sale. Indirect costs of removing timber such       timber sales for direct revenues are not the only goal of the state’s timber
                  as rebuilding the Shirley Towne Bridge and wear on the public road system, if         program. Providing jobs to Alaskans and providing timber to a variety of
                  borne by the public, will further decrease net revenue.                               different types of operators are also important. Sale revenues are therefore
Davidson          I cannot see that the chipping of wood from the proposed area can be in the best      not as high as they might be without these additional goals. Additional
                  interest of the state and it is certainly not in the best interest of the local       benefits to the state from this Timber Sale, beyond the timber sale revenue,
                  population. The operation will basically export our raw materials out of state        are scarification, improved wildlife habitat, and the potential for improving
                  for minimal profit. The impact on the area far outweighs the meager gains from        the trail system as discussed in the Kashwitna Management Plan.
                  the cutting.




Copper Timber Sale: Comment & Response                                                                                                                      20
Commenter         Comment                                                                                Response
Bryner            I am totally opposed to this sale. First, it is not an economical project, if one      The purchaser of the timber sale is contractually obligated to secure any use
                  considers the necessity of building a new Shirley Towne bridge and the cost the        or maintenance agreement required for the use of roads owned by private,
                  DOT will have in repairing the wear and tear on the road system due to the high        federal, state and local landowners or administrators.
                  volume of heavy traffic and trucks. The income the State will get from the sale
                                                                                                         The Alaska Forest Resources and Practices Act was developed to prevent
                  will certainly not offset the cost of road/bridge repair, let alone make any sort of
                                                                                                         adverse impacts to streams and fish habitat. Timber road construction and
                  profit on it. So the idea of this project being for the greater good of the State
                                                                                                         maintenance must follow the standards set by the FRPA and its
                  holds no water.
                                                                                                         accompanying regulations. (See AS 41.17 and 11 AAC 95.285 to 95.320.)
                  Inconsistency abounds.
                                                                                                         Maintenance costs will be borne by the purchaser.
                  …
                  I urge you to put a moratorium on this sale until more local input and                 The State, through DOT administered funds, assumes the cost of
                  independent economical studies can be made.                                            retrofitting the Shirley Towne Bridge and reconditioning the Willer-Kash
                                                                                                         Road. Currently, the Shirley Towne Bridge will not support commercial
                                                                                                         vehicles (fuel trucks, etc.) servicing residents on the north side of Willow
                                                                                                         Creek. The retrofit will solve this problem. The Willer-Kash Road
                                                                                                         improvements will access future timber sales as well as provide better
                                                                                                         access to mushers, snowmobilers, hunters, and other recreationists.
                                                                                                         Because these improvements will benefit a variety of users, they are not a
                                                                                                         direct expense of the timber purchaser.
                                                                                                         Please see also the Export section.
TCC               We feel that, when it participated in building wood-exporting infrastructure, the      The DOF cannot speak for the Borough.
                  borough did not properly consider the negative impacts of large-scale industrial
                                                                                                         It is the goal of all producers to deliver a quality product produced at the
                  logging on the Upper Susitna Valley. This type of logging ruins the visual
                                                                                                         lowest costs possible for the highest price the market will sustain.
                  attractiveness and the natural ecosystem of the land, increases flood potential by
                                                                                                         Problems can occur when corners are cut in a manner that results in a
                  damaging the watershed, burdens roads and infrastructure, and endangers
                                                                                                         negative impact to resources. However, the DOF, through the contract with
                  people in the area with log trucks. The low timber quality means the loggers pay
                                                                                                         the purchaser that represents the best interest of the state, the Susitna
                  very little for it and extract it as cheaply as possible, leaving very little money
                                                                                                         Forestry Guidelines, and the FRPA and its regulations, has the tools
                  but lots of problems in their wake. The people of Willow, Talkeetna, and
                                                                                                         necessary to reduce the likelihood of environmental degradation.
                  Trapper Creek should not now be burdened by those negative impacts that the
                  borough forgot to consider.                                                            Please see also the Anadromous Fish, Traffic, Kashwitna Plan, Tourism,
                                                                                                         Recreation, Susitna Forestry Guidelines, and Export sections above.
                  We hope you will consider the costs of this sale and of the type of logging it
                  creates, and ask you to determine that this sale is not in the overall best interest
                  of the State of Alaska and its people.

Purkey            I am against strip,chip,ship logging that don't even stay in my country for
                  Americans to make a living using them and will contribute a very small amount
                  to our local economy. It will lower the value to the area in recreational use not
                  to mention the money I will personally lose not having that area to train my
                  dogs.
Strasenburgh      Economics (section P.) of the FLUP is the only section that pertains to a “best        Please see the DOF’s response to WACO’s comments above.
                  interest” evaluation. All other sections have to do with the characteristics of the
                  sale. The Economics section is absurdly vague, does not quantify in dollar             Under AS 38.05.112 [Forest land use plans], guidelines are general for
                  terms any of the so-called benefits, and fails to even mention costs, much less        what is required in a forest land use plan: “In adopting a forest land use
Copper Timber Sale: Comment & Response                                                                                                                       21
Commenter         Comment                                                                                Response
                  quantify them. DOF has failed to make a good faith effort to analyze the costs         plan, the commissioner shall consider the best available data, including
                  and benefits of this proposed sale.                                                    information provided by other agencies.” The statute also states: “In
                                                                                                         adopting a forest land use plan on lands not covered by a forest
                  Furthermore, the DOF response to comments to the West Petersville #1 sale              management plan under AS 41.17.230 [State forest management plans], the
                  (page 29), indicates that due to lower than expected timber volumes, the West          commissioner shall consider non-timber uses and resources within the sale
                  Petersville #1 sale could result in a net monetary loss to the state. So, basically,   area.”
                  DOF was making a decision (with West Petersville) to proceed with the sale
                  without knowing the timber volumes. I do not see in the Copper FLUP how                AS 38.05.035(e)(6) [Powers and duties of director] states that “the director
                  DOF is any more aware of the timber volumes as it was with West Petersville            shall make available to the public a written finding that…sets out the
                  #1.                                                                                    material facts and applicable statutes and regulations and any other
                                                                                                         information required by statue or regulation to be considered upon which
                                                                                                         the determination that the sale… will best serve the interests of the state
                                                                                                         was based…” The final finding FLUP must also include [under AS
                                                                                                         38.05.035(e)(7)(B)] “a summary of agency and public comments received
                                                                                                         and the department’s responses to those comments.”

                                                                                                         The FLUP final finding did consider the best available data, including
                                                                                                         information from the Office of Habitat Management and Permitting,
                                                                                                         ADFG’s Division of Wildlife Conservation, the Mat-Su Borough, and the
                                                                                                         U.S. Fish and Wildlife Service. The following list shows the timber and
                                                                                                         non-timber uses and resources that the FLUP considered:

                                                                                                             A. Physical characteristics of the sale area
                                                                                                                1. Topography
                                                                                                                2. Water bodies
                                                                                                                3. Stand Conditions
                                                                                                                4. Silvics of birch trees
                                                                                                             B. Current Land Use
                                                                                                             C. Wildlife habitat
                                                                                                             D. Fisheries and water quality
                                                                                                             E. Subsistence
                                                                                                             F. Recreation
                                                                                                             G. Scenic resources
                                                                                                             H. Cultural resources
                                                                                                             I. Sustained yield and allowable cut
                                                                                                             J. Regeneration
                                                                                                             K. Harvest methods
                                                                                                             L. Transportation
                                                                                                             M. Erosion
                                                                                                             N. Mining
                                                                                                             O. Materials
                                                                                                             P. Economics
                                                                                                             Q. Public Notice

Copper Timber Sale: Comment & Response                                                                                                                      22
Commenter         Comment                                                                            Response
                                                                                                     Each of these issues was examined, and the potential impacts of a timber
                                                                                                     harvest were explained. The FLUP also explains the statutes and
                                                                                                     regulations that were used to make this determination; for example,
                                                                                                     disposal procedure [AS 38.05.120], five-year sale schedule requirements
                                                                                                     [AS 38.05.113], best interest findings [AS 38.05.035(e)], timber sale
                                                                                                     statutes and regulations [AS 38.05.110-120; 11 AAC 71], and forest
                                                                                                     resources and practices statutes and regulations [AS 41.17.010-.950 and 11
                                                                                                     AAC 95].

                                                                                                      The DOF’s response to comments to the West Petersville #1 Timber Sale
                                                                                                     stated, “however, during recent fieldwork and timber sale layout work,
                                                                                                     DOF has examined the sale area and believes that the volume of
                                                                                                     commercial timber in the sale area is lower than the SFG estimates. These
                                                                                                     lower volumes are likely to mean less revenue, which may mean a net loss
                                                                                                     to the state.” The document goes on to say, “However, we do not know the
                                                                                                     bid price for the sale, and these figures are only estimates. The revenue
                                                                                                     will depend on the bid price, which in turn will depend on competition for
                                                                                                     the sale, the DOF’s requirements for site preparation after harvest, and the
                                                                                                     actual volume of the timber on the units.”

                                                                                                     As stated earlier: the Division of Forestry will not accept any bids that do
                                                                                                     not meet the division’s costs for the preparation and administration of the
                                                                                                     sale. The State set the minimum bid for the West Petersville #1 Timber
                                                                                                     Sale at $65,256 based on the DOF’s pre- and post-sale costs. NPI, LLC did
                                                                                                     not choose to bid, giving transportation costs and the high cost of fuel as
                                                                                                     reasons for their decision.

                                                                                                     The West Petersville volumes published in the preliminary FLUP were
                                                                                                     developed prior to the field work needed for the Final FLUP and contract
                                                                                                     documents. The DOF took a different approach for the Copper Sale, due to
                                                                                                     the better accessibility of the Copper Timber Sale Area. The majority of the
                                                                                                     field work was completed on the Copper Timber Sale prior to publishing
                                                                                                     the preliminary FLUP and is therefore a reasonable estimate of timber
                                                                                                     volume. The DOF stands by its volume estimates described in the FLUP
                                                                                                     on page 9 under Stand Conditions.

                                                                                                     Since then, the DOF offered and sold a much smaller sale in the Kashwitna
                                                                                                     area, approximately 40 miles closer to NPI’s port facility. The volumes per
                                                                                                     acre and quality of timber in the sold sale are comparable to the Copper
                                                                                                     Timber Sale.

Korpi             The State Of Alaska Constitution dictates that the state's resources be utilized   Article VIII, Section 1 of the constitution encourages the development of
                  for the best benefit of ALL ALASKANS. Shouldnt this sale be called the             natural resources to make them “available for maximum use consistent with

Copper Timber Sale: Comment & Response                                                                                                                 23
Commenter         Comment                                                                            Response
                  Copper CHIP sale??? How is harvesting our states forest timber (by clearcutting    the public interest.” The Division of Forestry (DOF), through an extensive
                  this close to a community, disrupting local recreational uses,etc) soley for the   planning process detailed in Section F- Planning Framework on page 4 of
                  benefit of ONE corporation and the justification for building a port that was      the FLUP, has determined that the Copper Timber Sale is in the public
                  paid for in part with public funds the BEST BENEFIT TO ALASKANS?? So in            interest.
                  effect we paid for the port, and in order to justify it's existence, we need to
                  GIVE our timber to the exclusive port operator so they can make a profit while     Montana Creek was not a State timber sale.
                  they hire what...10 alaskans for 3 months???
                                                                                                     After the Final FLUP is approved, a timber sale contract is developed by
                  How can you justify the costs??? Will the state actually make enough money to      DOF to represent the state’s best interest. The contract stipulates the scope
                  cover the costs of preparing, marketing and administering this sale??              and nature of all actions that are appropriate on state land in connection
                  Hey, maybe by looking the other way once they start chipping you can save          with the purchase and removal of the timber. The DOF will monitor the
                  contract administration money, it worked on Montana Creek!!!                       timber sale through regular inspections and through additional “as needed”
                                                                                                     visits to the site to ensure compliance by the purchaser with all aspects of
                  If the state is really interested in giving NPI its welfare check while giving     the contract. The Office of Habitat Management and Permitting (OHMP)
                  locals the shaft, why not survey a highway right of way from port mckenzie to      will be consulted for any stream crossing that occurs, and if they feel it
                  big lake and let NPI chip the hell out of the road right of way. Kill two birds    necessary, they will visit the site. DOF will also encourage the wildlife
                  with one stone!!! I'm sure NPI would decline because it wouldnt make               biologists with ADFG to participate in our scarification plans.
                  economic sense. See, private enterprise bases their decisions on economic
                  reality. Maybe DNR should try that approach for a change!!!                        The DOF conducts and administers timber sale contracts under the
                                                                                                     authority of 11 AAC71.005-.350 [Timber and Material Sales]. DOF
                  Why destroy an area that is utilized for a much more beneficial purpose            regularly inspects all state timber sales for compliance with the Alaska
                  (recreation, hunting, mushing) in order to dole out a few handouts for political   Forest Resources and Practices Act, the Final Finding, and the contract. We
                  buddies...                                                                         also conduct compliance monitoring as a routine part of our inspections.
                                                                                                     Failure to comply with the contract or with FRPA can result in contract
                                                                                                     cancellation, retention of bonds, or civil fines under FRPA.

                                                                                                     The Division of Forestry will not accept any bids that do not meet the
                                                                                                     division’s costs for the preparation and administration of the sale.

                                                                                                     Please see also responses to comments above under Recreation, Tourism,
                                                                                                     Trails, and Export above; and Small Sales below.

Gualtieri         As a resident of the Upper Valley, I am constantly reminded of the impact of the   The FLUP discusses other benefits the proposed sale would have on the
                  needless and senseless wasting of OUR forests. From what I gather these sales      area besides the timber sale revenue. These include scarification, improved
                  benefit little or know one in the area, and permanently degrade OUR resource       wildlife habitat, and the potential for improving the trail system as
                  for generations to come.                                                           discussed in the Kashwitna Management Plan.
                  ,..
                  It would be different if these forests were managed for a practical sustainable    By law, the state must manage timber for sustained yield. To ensure that
                  purpose that benefits All ALASKANS, not least of all the communities that are      we manage sustainably, DOF establishes an annual allowable cut for each
                  impacted by this grotesque practice of chipping valuable timber to feed the        management area. Allowable cuts are set over an area that is large to
                  monster at Point McKenzie. The disgusting price that these acres are leased at     manage sustainably, efficiently, and with enough flexibility to design sales
                  alone should bring shame and humiliation upon all in OUR government that           to meet demand while mitigating impacts on other uses.
                  support and "oversee" this mis-management of OUR forests.
                                                                                                     Within the Susitna Forestry Guidelines, the allowable cut is split into three
Copper Timber Sale: Comment & Response                                                                                                                  24
Commenter         Comment                                                                          Response
                                                                                                   phases, and the first phase is split into the Mt. Susitna and East Side area.
                                                                                                   The Copper sale is in the East Side area of Phase 1. The annual allowable
                                                                                                   cut that is sustainable in this area is set by the Susitna Forestry Guidelines
                                                                                                   at 880-930 thousand cubic feet (Mcf) per year (see p.11, chart and
                                                                                                   “Sustained Yield”). State harvests in any five-year period must be no
                                                                                                   greater than five times the annual allowable cut. Because sales in the last
                                                                                                   four years have been far below the annual allowable cut, the remaining
                                                                                                   allowable cut in FY 2007 is 3,574 to 3,824 thousand cubic feet. The
                                                                                                   Copper Timber Sale contains 884.8 thousand cubic feet, well within the
                                                                                                   allowable cut.
                                                                                                   The DOF will monitor the timber sale through regular inspections and
                                                                                                   through additional “as needed” visits to the site to ensure compliance by the
                                                                                                   purchaser with all aspects of the contract.
                                                                                                   Please see the responses to WACO’s , Mr. Strasenburgh’s , and Mr.
                                                                                                   Korpi’s comments earlier in this section and responses to comments above
                                                                                                   in the Export section.
Denison           Logging may provide a few temporary jobs, but Alaskans will be short-changed     The total gross acres of the Copper Timber Sale area is 4,575 acres. Of
                  in the long run. Studies show that an intact forest has not only much more       that, 519 acres are wetlands and another 21 acres have been harvested for
                  environmental value, but economic value as well--as in tourism revenue. The      wildlife habitat; leaving 4,035 acres or 88 percent as forested lands. 1,203
                  wildlife we travel to see are either being killed (as are wolves) and/or their   acres or 32% of the forested acreage is proposed for harvest and roads.
                  habitat is disappearing! And providing "visual buffers" doesn't fool anyone!     2,832 forested acres or 70% will remain for recreation, wildlife, and other
                  Millions of other concerned Americans agree with us!                             forest uses.
                                                                                                   Visual screens are not attempts by the DOF to deceive the public. The
                                                                                                   public, during the process of writing the Kashwitna Management Plan and
                                                                                                   the Susitna Forestry Guidelines, expessed their desire to include visual
                                                                                                   screens between roads and harvest operations. The screens mentioned in
                                                                                                   the FLUP are there to satisfy the public’s wishes.
                                                                                                   The timber sale will not be visible from the Parks Highway or the Willow-
                                                                                                   Fishhook Road because the closest harvest unit to the Willow-Fishhook
                                                                                                   Road is 3.5 miles away and 4.5 miles away from the Parks Highway.
                                                                                                   Please see responses to comments above under Wildlife, Kashwitna Plan,
                                                                                                   Tourism, Recreation, and Export.




Copper Timber Sale: Comment & Response                                                                                                                 25
Commenter         Comment                                                                                Response
Cascadia          Despite these resolutions, and even ongoing litigation over the Petersville sale,      The Preliminary Finding does not consider any economic impact the
                  the Preliminary finding considers economic impacts only to NPI inc. What               proposed sale may have to NPI, LLC.
                  about the impact to homeowner’s long-term property values? What about the
                                                                                                         The closest private land is 1.7 miles south of a harvest unit. Property
                  impact to the recreation and tourism industry, the fastest growing in the state?
                                                                                                         values are generally affected by activities in the immediate vicinity of a
                  How about the food on the table and money in the bank offered by one of
                                                                                                         piece of land, not 1.7 miles away.
                  nature’s greatest gifts, Wild Pacific Salmon? These interests are ignored
                  entirely, in terms of economic impact.                                                 The SFG directs the DOF “to avoid conflicts with adjacent landowners to
                                                                                                         the extent feasible and prudent” for the purpose of preventing damage to
                  Wood chipping and export is a very low-end, almost desperate, use for these            private lands from trespass, blowdown, or other hazards created by the
                  forests. They are worth more as firewood, scenery, a place to play, habitat for        harvest. To achieve this, the SFG requires a buffer with a minimum width
                  fish and wildlife.                                                                     equal to the average height of codominant trees on the adjoining state land.
                                                                                                         This was not necessary due to the long distance to the nearest neighbor.
                                                                                                         The FLUP addresses each of your topics. A FLUP is not an Environmental
Bounds            Our property values will be lowered,
                                                                                                         Impact Statement or an Environmental Assessment. A FLUP is meant as a
                  …
                                                                                                         review of the best available information of the area as a basis for the
                  There is little value to our economy from "strip, chip and ship" logging. The
                                                                                                         commissioner’s finding. Please see also the response to Mr. Strasenburgh’s
                  potential devastation to the area cannot be undone; take a look at the "lower 48"
                                                                                                         comments earlier in this section.
                  to see what our beautiful community will become if the CopperTimber sale is
                  allowed to occur.                                                                      The State will accept the highest bid for this sale regardless of the final
                                                                                                         product – sawlogs, firewood, pellets, or chips – as long as the purchaser
Barcome           I totally oppose this project to clearcut the Willer-Kash area. There are better       meets the utilization, silvicultural, and environmental standards stipulated
                  ways to utilize our natural resources. And the residents that have invested in         in the contract.
                  property and the rural lifestyle deserve a better quality of life than what this
                                                                                                         Please see also the responses to comments above under Anadromous Fish,
                  effort will leave behind. Whatever profit the government planned to make off
                                                                                                         Kashwitna Plan, Tourism, Recreation, Susitna Forest Guidelines, Trails,
                  this project is not worth the sacrifices that the local residents will suffer for
                                                                                                         and Export.
                  many years to come.

ACE               ACE is in favor of local jobs, local purchases and local economic benefits from        The DOF appreciates ACE’s support of local jobs, local purchases and
                  sustainable forestry in the Mat-Su Valley. However, we disagree that this sale         local economic benefits from sustainable forestry in the Mat-Su Valley.
                  will provide the economic benefits that are promised in the plan. FLUP at 7.
                                                                                                         Please see the responses to Waco’s and Mr. Strasenburgh’s comments
                                                                                                         earlier in this section addressing infrastructure.
                  We believe that the sale will provide little to no benefit to the State, if you
                  consider the cost associated with managing this sale. The additional costs             Logging road closure will be made part of the logging contract. The costs
                  associated with the removal of the wood product from the site: roads must be           associated with road closure will be borne by the purchaser and the
                  built, bridges constructed to cross rivers and steams, and heavy equipment and         purchaser’s bid price will reflect these costs.
                  chip trucks wearing down the local infrastructure of Willow and the cost related
                  to the proper closing of the logging roads after harvest, all are costs that are not   Harvest unit size does affect logging costs. The SFG requires units to be
                  addressed in the plan.                                                                 spaced at least 330 feet from each other. By reducing unit size, more roads
                                                                                                         would need to be built between units to access the same acreage and timber
                  …
                  Similarly, the analysis of Alternative 2 fails to be meaningful because it is          volume. For example: Two 50 acre units (the maximum size allowed by
                  largely conclusory and not based on any analysis evident in the FLUP. Here the         the SFG) would require at least 330 feet of road to connect the two. If the
                                                                                                         total harvested acreage was divided into ten 10 acre units, an additional
                  FLUP rejects the alternative because it claims that “[d]ecreasing the size of the
                  units would increase logging costs or leave timber that would be more difficult        2,640 feet of road would need to be constructed to harvest the same acres.
                  to harvest in the future.” FLUP at 29. However, there is no data in the FLUP           This would be an 8-fold increase in the cost of road construction. In
Copper Timber Sale: Comment & Response                                                                                                                       26
Commenter         Comment                                                                             Response
                  that supports this contention or any other claim that is based on the logging       addition, since each ten-acre unit would need to be buffered from the other
                  costs.                                                                              units, the total footprint of the timber sale would be much larger.



                  Small sales
WACO              Our community strongly supports local sawmills, log home builders and               In addition to this timber sale, the Division of Forestry will continue to
                  firewood cutting areas, but this sale would take away available logs for local      offer smaller timber sales to supply small operators with timber. Offering
                  uses. For example, the best value added use of mature spruce is not wood chips      this timber sale to support the chipping industry does not decrease the
                  but house logs that can be utilized by local log builders or sawmills.              opportunity for small sales to support smaller operators. Providing wood to
                                                                                                      support jobs for wood chipping does not eliminate other forestry jobs. In
Strasenburgh      Real value added means use of the wood locally, for log homes, small mills, and     fact, selling large sales can increase the accessibility to more forested land,
                  manufactured wood products. These would benefit the local economies and             and can create more opportunities for small timber sales.
                  create jobs without the down side that accompanies large scale logging.
                                                                                                      Value-added products. The production of wood chips is a value-added
                                                                                                      timber product, and is being processed locally. AS 38.05.123(j)(2) defines
Bryner            If logging is to be done, then it must be done in a manner which is beneficial to
                                                                                                      “value-added wood product” as “round house logs, chips, green lumber,
                  the local residents foremost. Local saw mill businesses are being stabbed in the    flitches, cants, rough planks, and other similar wood products…”
                  back by the State by selling this timber to a large corporation for exporting our
                  resources. Resource development should benefit local businesses first and           Our emphasis in the state timber sale program is to offer sales in a range of
                  should not be exported as primary goal.                                             sizes to support the different types of timber businesses in the local area.
                  Exporting our resources at the expense of local businesses and residents is a
                                                                                                      Offering this timber sale will enable the DOF to manage the forest as
                  very bad policy.
                                                                                                      allowed in the planning documents that guide activities in the area. This




Copper Timber Sale: Comment & Response                                                                                                                    27
Commenter         Comment                                                                                Response
ACE               The Division of Forestry’s Five Year Timber Schedule 2005-2009 for the Mat-            proposed timber sale is well within the annual allowable cut for the area,
                  Su Area states that, wood should be provided for local, small and independent
                  mills and harvesters. But the FLUP at 27 clearly states that the market for the
                  bulk of the wood in this sale area would benefit one company, NPI. A large,
                  outside corporation, that plans to export our resource to foreign countries. We
                  fail to see the local component in the DOF’s market analysis.

                  ACE supports the local, value added, use of the Mat-Su’s forest. We see local
                  mills, log home builders, and fuel wood business providing more of an
                  economic boost to the local economy than the “strip, chip and ship” practices of
                  NPI.
                  …
                  It is also impossible to evaluate the merit of Alternative 3. The analysis
                  simply rejects the alternative since “[d]eferring harvest to a later date would fail
                  to meet many of the objectives of the sale program.” FLUP at 29. However,
                  the only objective mentioned is the desire to make “state-owned timber
                  consistently available to the timber industry.” Id. But the FLUP does not
                  identify the “timber industry” or information to suggest that adequate timber
                  would not otherwise be consistently available if the sale was not held.
                  Therefore, it is impossible to evaluate the FLUP’s claim. In addition, with this
                  limited review the FLUP fails to balance the stated benefit against any other
                  public policy objectives so it is not possible to determine whether the decision is
                  consistent with public policy.



                  Silvicultural prescription
Barcome           First of all, I am totally against clear cutting any area. I understand that trees     The Copper Timber Sale area will not be “decimated for decades to come.”
                  are a natural resource and have many uses. But the idea of leaving an area             According to the Alaska Forest Resources and Practices Act and its
                  decimated for decades to come goes against every instinct.                             regulations, when timber is commercially harvested, it must be reforested
                  There are better ways to harvest the usable mature trees, while leaving younger        [AS 41.17.060(b)(4)]. The specific reforestation requirements for public
                  trees to continue on in their life cycle. There are certainly many ways to restore     land are set in the Alaska Forest Resources and Practices Regulations [11
                  some semblance of natural balance when the project is near completion. Yet             AAC 95.375 - .390]. For Region II (Southcentral Alaska), a harvested
                  little consideration seems to be given to what areas like this will look like when     stand must be reforested within seven years using the following standards:
                  the harvesting companies walk away with their profit.
                                                                                                         1. Vigorous, well-distributed residual commercial trees free from
                                                                                                         significant damage meet or exceed the following standards, or a
                                                                                                         combination of trees and seedlings approved by the division, meet the
                                                                                                         following standards:
                                                                                                          Average DBH          Minimum
                                                                                                          of Remaining         Stocking
                                                                                                          Stand – Inches       Standard
                                                                                                                               (trees/acre)
                                                                                                          Greater than 9       120
Copper Timber Sale: Comment & Response                                                                                                                      28
Commenter         Comment                Response
                                          6 to 8                    170
                                          1 to 5                    200
                                         2. The number of vigorous, undamaged, and well-distributed seedlings of
                                         commercial tree species must average a minimum of 450 trees per acre and
                                         must have survived on site for a minimum of two years.
                                         3. Adequate reforestation means a combination of seedlings and residual
                                         trees that will meet the standards set out above.
                                         4. No more than 10 percent of the harvest area or contiguous areas may be
                                         below the stocking levels as set out above.
                                         ------------------------------------------------------
                                         In many cases, with adequate site preparation techniques such as
                                         scarification, natural regeneration exceeds the required regeneration
                                         standards, so planting is not necessary.
                                         In addition, the majority of state land in the area will remain unharvested,
                                         partly because of varying land use classifications on different areas of state
                                         land, and partly because harvest is limited by our annual allowable cut.
                                         The timber harvest has been designed as required by the Susitna Forestry
                                         Guidelines. Forest management in the Susitna Valley is designed to create
                                         and maintain a mosaic of age classes that will provide for a mixture of cut
                                         and uncut areas to provide and protect fish and wildlife habitat, and
                                         produce timber.
                                         The clearcutting is being done in small units, with irregular borders, as per
                                         the Susitna Forestry Guidelines. The sale area consists of 46 cutting units,
                                         with an average size of 25 acres. Unit sizes range from 4 to 50 acres. In
                                         the few units that are larger than 50 acres, islands of timber will be included
                                         in the final layout of the unit, so that the harvested area in the unit will be
                                         no larger than 50 acres. The proposed units have been properly buffered
                                         between themselves with 330 foot no-cut areas as required by the SFG.
                                         The SFG also limits cutting openings: “Cutting openings generally shall be
                                         no wider than approximately 660 feet to allow access to cover for bears and
                                         moose and to encourage full utilization of browse.”
                                         Both non-timber and timber uses are provided for by the plans that govern
                                         land use in the Susitna Valley. See “General response to comments,” page
                                         2 of this document, for an explanation of the broad-scale planning efforts
                                         that determined the mix of uses that are allowed in the Susitna Valley. See
                                         F. Planning Framework in FLUP.




Copper Timber Sale: Comment & Response                                                            29
Commenter         Comment                                                                                 Response
ACE               In addition, the SFG states that “[w]here birch is the primary species harvested,       Change made: The description of the stand density and stand conditions in
                  seed tree harvesting is the preferred harvesting system for wildlife habitat and        the FLUP was confusing, because only the merchantable timber was
                  timber production.” SGF at 20. Although this method is not mandatory it is              counted in the study plots. However, there were many smaller trees of 5”
                  preferred because it exposes “mineral soil and sunlit openings that are needed          dbh and less, of both spruce and birch in both stand types. Both stand type
                  for abundant germination and growth of birch seedlings.” Id. Here the FLUP              descriptions have been modified by adding the term “merchantable,” to
                  proposes a modified seed tree method where rather than leaving 5-10 large               clarify the descriptions:
                  mature trees it intends to instead leave all trees under 6 inches (dbh). FLUP at
                                                                                                          First stand type: “Stand density for this type is approximately 200 to 250
                  23. In its description of the stand conditions however, the FLUP identifies two
                                                                                                          merchantable trees/acre. Merchantable birch range from 6 to 14”
                  stand types, one with trees ranging from 6-14” (dbh) and the other ranging from
                                                                                                          diameter at breast height (dbh) with an estimated average of 8 inches.”
                  6-18” (dbh). FLUP at 9, 10. Therefore the selected harvest method really
                  purports to cut all the trees since the stand has few if any trees that are less than   Second stand type: Stand density for the type is approximately 110 to 160
                  6” (dbh). This method is not conducive to the regeneration of birch and fails to        merchantable trees/acre. Merchantable birch range from 6 to 18”
                  provide mature trees to re-seed the area. The lack of adequate cover and                diameter at breast height (dbh) with an estimated average of 11 inches.
                  regenerating trees will adversely affect wildlife species and runs counter to the
                  assertion in the FLUP that regenerating birch will provide excellent browse for
                  moose populations in the region.

                  WACO Plan
Carter            The Willow Area Community Organization just voted at their October 2                    When the Willow Area community develops and adopts a community-wide
                  meeting to ask the Mat-Su Borough for assistance in developing a community-             plan, the DOF will include the plan in our considerations for offering
                  wide plan. No logging should take place in the Willow Area until the                    timber sales in the area.
                  community develops its land use plan.
                  Rotation age
ACE               The SFG indicates the timber sale area is a co-primary use area, where 60% of           Rotation ages only come into effect when an area has been harvested
                  the timber in the area would be cut on a standard rotation and “40% will be             already. The trees in this area have never been harvested. The regular
                  managed on long rotations” to protect other uses. SFG at 12. These restrictions         rotation age for birch is 80 years, and for spruce, is 100 years. The
                  are not adequately addressed in the FLUP. The FLUP does not indicate which              proposed sale is within the annual allowable cut, and will allow sustained
                  portions of the area will be managed under which rotation period. In fact,              use of the forest over the long term. The harvest units would not be
                  standard and long rotations periods are not expressly defined for the purposes of       harvested again until at least as long as the standard rotation age. The
                  this sale. Without this information, it is not possible to judge whether other uses     standard rotation approximates the age at which timber is mature enough to
                  will be protected.                                                                      provide natural regeneration and large enough to provide a mix of wood
                                                                                                          products such as fuelwood and sawtimber.
                                                                                                          Birch is considered a short-lived tree, and matures at 60 to 70 years old. It
                                                                                                          rarely lives longer than 140 to 200 years. The oldest birch in the sale area
                                                                                                          are estimated to be about 130 years old.
                                                                                                          The mix of long and short rotation ages required by the SFG is addressed in
                                                                                                          two ways. First, the allowable cut for the Phase 1 area is based on
                                                                                                          harvesting 60% of the areas where forestry is a co-primary use on a long
                                                                                                          rotation, and 40% on a short rotation. This means that across all co-
                                                                                                          primary units in Phase 1 there will be at least 40% of the area in long
                                                                                                          rotations. However, individual acres are not designated in advance as “long
Copper Timber Sale: Comment & Response                                                                                                                        30
Commenter         Comment                                                                            Response
                                                                                                     rotation” or “short rotation” sites. Second, at least 40% of each subunit
                                                                                                     must be kept in cover habitat at all times.
                                                                                                     The total area of state land in the entire Kashwitna planning area is 29,550
                                                                                                     acres. Of that total, 81 percent (23,930 acres) is forested and is shown as
                                                                                                     estimated timber base in the Kashwitna area. This timber sale plan
                                                                                                     proposes to harvest less than 5% (1,157 acres) of the timbered acres in the
                                                                                                     Kashwitna planning area.
                  Forest health
Cascadia          This focus is evident throughout the document, for example on page 10, where       The correct quote for the FLUP on page 10 is, “The timber value of this
                  you indicate the forest is full of “defect and decay.” According to this view,     stand type is in decline and a significant portion of the volume shows signs
                  trees are “succumbing to attacks from fungi and insects.” Another, equally valid   of defect and decay.” The Willow Subbasin Area Plan and the Kashwitna
                  way to characterize it would be as a mature and diversifying forest. The           Management Plan designated the Kashwitna area for forestry and wildlife
                  “defect” could just as accurately be understood as cavity nesting habitat for      habitat. One of the goals of the Management Plan is to “provide jobs and
                  birds and furbearers. Fungi and insects aren’t attacking the forest. They live     income through the management of state and borough lands and resources
                  there. Forests where “defect and decay” are absent could properly be understood    to support a vital, self-sustaining local and statewide economy.” The plan
                  as lacking in structural and biological diversity.                                 further states that it “contributes to this goal by providing opportunities for
                                                                                                     commercial and personal use timber harvest…” The description of the
                                                                                                     forest is valid in light of these goals. Although decaying trees do make
                                                                                                     excellent habitat for certain species of wildlife, they are not ideal for
                                                                                                     making sawlogs, firewood, pellets, or chips.
                                                                                                     The Susitna Forestry Guidelines were adopted to ensure that state forest
                                                                                                     lands continue to contribute to the quality of life and economy by providing
                                                                                                     wood for personal and commercial use, while protecting and enhancing fish
                                                                                                     and wildlife habitat. 40% of cover habitat in each management subunit
                                                                                                     must be left to meet wildlife needs. In addition, the FLUP requires
                                                                                                     clumped snags to be retained for cavity nesting birds, woodpeckers, small
                                                                                                     mammals, and other species.
                                                                                                     By mimicking the fire regime of the past, the harvest will create more
                                                                                                     forest diversity, leaving an older forest with approximately 25-acre cuts
                                                                                                     dispersed throughout the area. The early successional wildlife species such
                                                                                                     as moose will benefit from the disturbance and subsequent browse, while
                                                                                                     buffers and leave areas will continue to support species adapted to the late
                                                                                                     successional forest types.
                  Reforestation
Gualtieri         As a biologist myself, I am aware of the excruciatingly slow recovery time for     Birch is considered a short-lived tree, and matures at 60 to 70 years old. It
                  clearcut forests. Usually never returning to their healthy climax state. Forests   rarely lives longer than 140 to 200 years. In the Kashwitna area, the birch
                  that were either cleared or burned as far back as 30 years ago have been           occupying the Type 1 stands were established after a fire approximately 80
                  replaced by tightly packed 3-5 inch birch saplings with near incalculable stem     years ago. The stand has differentiated into approximately 200 to 250 trees
                  densities almost no under story, and essentially unusable habitat for most         per acre but, as you state, with very little understory available for wildlife.
                  animals (including people).                                                        The proposed harvest will create a mosaic of cut and uncut stands. The
Copper Timber Sale: Comment & Response                                                                                                                    31
Commenter         Comment                                                                               Response
Frahm             Here in Alaska the renewal process after cutting down trees is very slow and          uncut stands will continue to grow into an older age class while the cut
                  this action will have a long lasting affect. I fear for my childrens' and their       stands will provide the needed diversity and early successional habitat
                  childrens' rights to access and enjoy the great outdoors of Alaska. We have a         required by some species.
                  responsibility to learn from what has happened to so many other states' natural
                                                                                                        Birch commonly colonizes disturbed sites found after logging, fires, and
                  habitat. I live in Alaska because of the outdoors and all that goes with it. Please
                                                                                                        windstorms. Scarification techniques, as required for this proposed sale,
                  help to preserve our great Alaskan outdoor heritage.
                                                                                                        are used to mimic or augment these disturbances and ensure adequate
                                                                                                        stocking levels to meet management and regulatory goals. Scarification
                                                                                                        will be done on the harvest units to the standards set in the Susitna Forestry
                                                                                                        Guidelines to ensure regeneration that meets the reforestation standards in
                                                                                                        the Alaska Forest Resources and Practices Regulations [11 AAC 95.375 -
                                                                                                        .390].
                                                                                                        Birch growth and yields on good sites were similar in Alaska, Ontario, and
                                                                                                        New England. Yields in Ontario were greater than Alaska for the first few
                                                                                                        decades but the growth rate of Ontario birch declined more rapidly as it
                                                                                                        approached maturity and by age 80 Alaska birch growth rates surpassed
                                                                                                        those of Ontario.
                                                                                                        The DOF will monitor the post-harvest regeneration and will take measures
                                                                                                        to promote reforestation if performance of the regrowth indicates poor
                                                                                                        stocking. On the whole, the DOF believes natural regeneration will be
                                                                                                        sufficient in the sale area, given experiences with other sales in the area.
                                                                                                        Please see responses to comments under Wildlife, Silvicultural
                                                                                                        Prescription, and Forest Health, Kashwitna Management Plan, Recreation,
                                                                                                        and Trails.
Denison           If Alaska is so concerned about jobs, how about using some of those many              The State of Alaska is committed to the reforestation of all harvested lands,
                  millions of taxpayer dollars we're spending to have our forests destroyed--to         both public and private. In many cases, with adequate site preparation
                  hire these woodsmen to restore acreage that has already been clearcut?                techniques such as scarification, natural regeneration exceeds the required
                    The only environmentally acceptable and sensible alternative is "Do not offer       regeneration standards, so planting is not necessary. Scarification will be a
                  this timber for sale"----no more clearcutting!                                        requirement of the contract. The final bid price will reflect this added cost
                                                                                                        to the successful bidder. The following is a summary of the reforestation
                                                                                                        requirements for both private and state lands:
                                                                                                        According to the Alaska Forest Resources and Practices Act and its
                                                                                                        regulations, when timber is commercially harvested, it must be reforested
                                                                                                        [AS 41.17.060(b)(4)]. The specific reforestation requirements for public
                                                                                                        land are set in the Alaska Forest Resources and Practices Regulations [11
                                                                                                        AAC 95.375 - .390]. For Region II (Southcentral Alaska), a harvested
                                                                                                        stand must be reforested within seven years using the following standards:
                                                                                                         Average DBH           Minimum
                                                                                                         of Remaining          Stocking
                                                                                                         Stand – Inches        Standard
                                                                                                                               (trees/acre)
Copper Timber Sale: Comment & Response                                                                                                                     32
Commenter         Comment                                                                                   Response
                                                                                                             Greater than 9        120
                                                                                                             6 to 8                170
                                                                                                             1 to 5                200
                                                                                                            2. The number of vigorous, undamaged, and well-distributed seedlings of
                                                                                                            commercial tree species must average a minimum of 450 trees per acre and
                                                                                                            must have survived on site for a minimum of two years.
                                                                                                            3. Adequate reforestation means a combination of seedlings and residual
                                                                                                            trees that will meet the standards set out above.
                                                                                                            4. No more than 10 percent of the harvest area or contiguous areas may be
                                                                                                            below the stocking levels as set out above.
Cascadia          Regeneration is a concern. The preliminary decision uses flawed logic with                What is meant by this statement is not that harvest units will be larger but
                  regard to moose browse and regeneration. Past failures are viewed as solvable             there will be more small harvest units producing browse in the area and
                  by expanding them. It indicates:                                                          therefore decreasing the likelihood of an individual stem getting browsed.
                           In 1989, a 40 acre area east of the proposed Willer-Kash Road                    A few years without browse will allow that individual stem to grow above
                           extension was treated by the Department of Fish and Game to create               the browse line and develop to maturity. The FLUP on page 22 under J.
                           moose habitat by encouraging new hardwood growth for use by moose                Regeneration explains the literature used to arrive at this conclusion:
                           as browse. Birch regeneration appears adequate to meet FRPA
                                                                                                                     Collins (1996) noted the availability of browse may be much
                           reforestation guidelines, but it is generally over-browsed by moose and
                                                                                                                     shorter if the tree’s height growth is not retarded by browsing or
                           the trees have had difficulty growing past the browse line. The added
                                                                                                                     other damage. He used the abandoned Point Mackenzie
                           acreage of this sale will distribute browse potential over a wider area
                                                                                                                     Agricultural Project as an example where the old fields reforested
                           and will likely allow better stand development than what is presently
                                                                                                                     in hardwoods, produced excess browse relative to the moose
                           exhibited in the area treated by ADFG. (Preliminary FLUMP, p.11)
                                                                                                                     population, which was then lightly browsed and quickly outgrew
                                                                                                                     the browse line. (Collins, William B., 1996. Wildlife Habitat
                  This is wrong logic. It is like saying give an alcoholic lots of beer and they’ll
                                                                                                                     Enhancement in the Spruce-Hardwood Forest of the Matanuska
                  lay off the whiskey. More likely, if the treatment spreads, this same pattern of
                                                                                                                     and Susitna River Valleys. Alaska Department of Fish and Game,
                  moose browse inhibiting regeneration will spread.
                                                                                                                     Wildlife Conservation, Juneau, AK.) Collins and Schwartz, in
                                                                                                                     their management recommendations “to enhance early
                  I wonder if there is any evidence that wood chipping prescriptions will really be
                                                                                                                     successional moose habitat in hardwood and spruce-hardwood
                  “mimicking the fire regime of the past.” (p.13) There would seem to be
                                                                                                                     stands in Alaska,” state that the increased regeneration of
                  important differences between a burned forest and one that is hauled away and
                                                                                                                     hardwood will “lessen the probability that individual hardwoods
                  the ground scarified. Nutrients are lost. Cover and habitat are lost. Compaction
                                                                                                                     will be damaged or stunted by browsing” (Collins, William B, and
                  and roads are introduced. Hydrology is altered. Large woody debris is gone.
                                                                                                                     Charles C. Schwartz, 1998. Logging in Alaska’s Boreal Forest:
                                                                                                                     Creation of Grasslands or Enhancement of Moose Habitat. In
                                                                                                                     Alces. Vol. 34, Num. 2, p. 355-374. Lakehead University,
                                                                                                                     Thunder Bay, Ontario.)
Leo               The data used to establish this sale is useless. It is too old to use. It is based on a   The State of Alaska is committed to the reforestation of all harvested lands,
                  climate that no longer exists. You cannot use old data to project 50 or 100 years         both public and private. Please see the response to Denison, above, for an
                  into the future. I am repeating this because you just don’t seem to get it. Even a        explanation of reforestation requirements.
                  little. If you believe that you are forest professionals, then proceeding with this
                                                                                                            DOF conducts regeneration surveys on every timber sale. By the end of
                  sale would be unconscionable. You cannot dismiss the fact that THE DATA
                                                                                                            seven years, the harvest area must be regenerated to the standards explained
                  ON REGROWTH DOESN’T EXIST, because the only data extant is bad, old,
Copper Timber Sale: Comment & Response                                                                                                                         33
Commenter         Comment                                                                              Response
                  useless.                                                                             above (in the response to Denison’s comment). In areas of concern, DOF
                  Have you seen what’s happening at the NPI cut at mile 108 of the Parks? The          surveys the harvest areas soon after harvest, so that any additional measures
                  re-growth is grass. Nothing but grass. No birch seedlings, no spruce. Well-          are taken to ensure adequate reforestation by the seven year deadline.
                  rooted, pervasive, choking grass.                                                    Those measures may include additional scarification, planting, and seeding.
                  Do you just not care?
                                                                                                       You say that “the data on regrowth doesn’t exist.” While there is little
                  No one (not just "almost every individual" but NO ONE) came to or continues
                                                                                                       published literature about regeneration in the Mat-Su, we do have the
                  to reside in the Susitna Valley to see the forest whacked to moonscape without
                                                                                                       results from regeneration surveys on prior harvests. DOF has held timber
                  trust that those forests will grow back as rich as they have been for 7,000 years.
                                                                                                       sales in this area for several decades. Results show that the natural
                  There is now absolutely no doubt that we just don’t know what will grow back
                                                                                                       regeneration is quite good on most timber sales, and only a few sales have
                  from woodchip logging on the scale of Copper or West Petersville.
                                                                                                       not regenerated adequately, requiring extra work to achieve the FRPA
                  Stop.
                                                                                                       regeneration standards. In the Mat-Su, we can continue to learn about
                  Take a breath.
                                                                                                       natural regeneration by performing regeneration surveys on carefully
                  Do studies. No rush. 7,000 years is a heritage that allows a few additional years
                                                                                                       conducted timber harvests.
                  to make sure about what you’re planning now. Go slow. Do it right by stopping
                  this sale now.                                                                       If there is serious grass competition or other problems with our initial
                                                                                                       prescription for site preparation and natural regeneration, we must then take
                                                                                                       additional measures such as planting or seeding to ensure that we meet
                                                                                                       FRPA standards.
                  Invasives
Price             [the timber sale would] encourage the future use of herbicides (for site             The FLUP states precautions that must be taken to minimize the risk of
                  preparation and for plant "invasives" that would tend to colonize the disturbed      introducing invasive species to the timber harvest area:
                  ground).
                                                                                                       Before timber harvesting equipment enters the harvest area, it will be
                                                                                                       power-washed to remove possible invasive species seeds. Scarification
                                                                                                       equipment will also be power-washed before going on-site. In addition, the
                                                                                                       parking area at the intersection of Willer-Kash and Jim Carter Roads will
                                                                                                       be checked before scarification equipment is brought into the timber
                                                                                                       harvest area in the summer, to see if there is an infestation of invasive
                                                                                                       species along the highway at the entrance to the timber sale. If there is, the
                                                                                                       infestation will be treated prior to the scarification work being done.
                                                                                                       By treating the infestation, we do not necessarily mean treating with
                                                                                                       herbicides. If invasives are found, the treatment may be as simple as
                                                                                                       cutting the flowers off before they can set seeds, or pulling the plants.
                  Chips
Strasenburgh      DOF can best serve the public interest by performing substantive evaluations of      The proposed sale intends to provide raw materials to a local processor to
                  a possible timber sale and focus on real value added. I am aware that AS             produce chips, which, as you note, are a value-added wood product [AS
                  38.05.123(j)(2) includes ‘chips’ in its definition of value added, but I think you   38.05.123(j)(2)].
                  must agree that all “value added” wood products are not created equal. Wood
                                                                                                       Chipping operations require large volumes of wood. Small timber
                  chips is huge volume, low margin operation.
                                                                                                       operators harvesting sawlogs require higher-quality and lower volume. The
                  …
                                                                                                       DOF offers both types of sales. Our emphasis in the state timber sale

Copper Timber Sale: Comment & Response                                                                                                                     34
Commenter         Comment                                                                                 Response
Oxley             I t is also a terrible use of beautiful natural land for wood chips, please. If you     program is to offer sales in a range of sizes to support the different types of
                  are going to cut healthy forest down, get a better use out of the wood.                 timber businesses in the local area.
Cascadia          The preliminary decision does a generally good job of evaluating and
                                                                                                          In addition to this timber sale, the Division of Forestry will continue to
                  considering the stands and sale from the point of view of wood chip forestry. If
                                                                                                          offer smaller timber sales to supply small operators with timber. Offering a
                  this were a privately owned tree farm, the preliminary decision would be a very
                                                                                                          large timber sale to support the chipping industry does not decrease the
                  good piece of work. However, this is a public forest that serves a wide variety
                                                                                                          opportunity for small sales to support small operators. In fact, selling large
                  of public interests. The exclusive focus on chip-production is therefore
                                                                                                          sales can increase the accessibility to more forested land, and can create
                  inappropriate, and it is a major flaw of the Preliminary FLUMP.
                                                                                                          more opportunities for small timber sales.
Barcome           And to think these beautiful trees that have taken decades to reach mature
                  status, height, and foliage are being sacrificed for mere wood chips!
                  That just makes my blood boil! Wood chips should be a side product in order to
                  more fully utilize the natural resource, not the reason to roll in and totally raze a
                  beautiful wooded area. 1,000 acres to be sacrificed for wood chips! We should
                  all be ashamed.
                  ACMP




Copper Timber Sale: Comment & Response                                                                                                                        35
Commenter         Comment                                                                               Response
Mat-Su            According to the information provided by the applicant for the above referenced       Comment noted. DOF will follow the Borough’s Coastal Management
Borough           project, a written analysis is required for a determination of consistency with the   guidelines.
                  Matanuska-Susitna Borough Coastal Management Plan for this proposal. This
                  project is found to be consistent with the following stipulation:

                           1.   Within the 75 foot shoreline setback, all areas not occupied by
                                allowed development must minimize disturbance of natural
                                vegetation.

                   The intent of this stipulation is to protect water quality and fish and wildlife
                  habitat by providing for natural filtering of surface water runoff into the lake,
                  minimizing erosion and potential flood damage, and providing separation
                  between the waterbody and potential sources of pollution such as fertilizer, fuel
                  spills, and other items which would have a significant negative impact, as per
                  the Habitats (6AAC80.130) and Air, Land and Water Quality (6AAC80.140)
                  Standards of the ACMP and the enforceable policies of the Matanuska-Susitna
                  Borough (Coastal Habitats).

                  In accordance with MSBCMP (September 1987), Chapters 4 and 6, and
                  Amendment #2 dated March 31, 1988, this project is found to be consistent.
                  Please be aware of the following advisory information:

                                •   The project or action must comply with all rules applicable to
                                    special land use districts or geography areas affected,
                                    including but not limited to MSBtitles 15, 16 and 17.
                                •   The project or action must comply with all rules applicable to
                                    the affected uses, activities, habitats, and resources, including
                                    but not limited to requirements of the Alaska Department of
                                    Natural Resources, Department of Environmental
                                    Conservation, Department of Fish and Game, US Corps of
                                    Engineers, and the US Environmental Protection Agency. A
                                    Coastal Management Plan consistency determination by the
                                    state of Alaska may also be required.
                                •   This decision does not relieve the applicant from requirements
                                    of any other required local, state, or federal review or permits
                                    for the proposed projecdt.
                                •   Any changes in the execution of this project from the proposal
                                    reviewed for this decision will void this decision and will
                                    constitute cause for further review and/or initiation of
                                    enforcement actions against violations of borough, state, or
                                    federal ordinances.



Copper Timber Sale: Comment & Response                                                                                                              36
Commenter         Comment                                                                              Response
OHMP (to          Pursuant to AS 14.4.870, the Office of Habitat Management and Permitting             Comment noted.
OPMP)             (OHMP) has reviewed the Forest Land Use Plan (FLUP) for the Copper Timber
                  Sale. Little Willow Creek, a specified, anadromous fish-bearing stream, is
                  within the Coastal Zone boundary and transects the northern portion of the sale
                  area. The FLUP proposes to cross Little Willow Creek with two bridges at a
                  location that is within the Coastal Zone. These bridges will require a Fish
                  habitat Permit from the OHMP.

                  It is our determination that this project qualifies for ACMP approval under the
                  terms and conditions set forth in Generally Consistent Determination 7 (GCD-7,
                  Culvert and Bridge Installation).

                  Little Willow Creek (Stream Number 247-41-10200-2130) has been specified
                  as being important for the spawning, rearing, or migration of anadromous fish
                  pursuant to AS 41.14.870(a). This stream supports three species of North
                  American Pacific Salmon as well as a variety of resident fish species.

ACE               It is also particularly troublesome that the FLUP raises only a limited and          State and Mat-Su Borough agencies were sent a copy of the Copper Timber
                  conclusory analysis of potential ACMP conflicts even though one stated               Sale FLUP for their consistency review under the Alaska and Mat-Su
                  purpose of the FLUP is to “provide sufficient information to ACMP reviewers          Borough Coastal Management Programs. The participating agencies had
                  and other reviewers to evaluate” consistency with the ACMP. FLUP at 3.               until October 11 to submit their comments or request additional
                  Although some ACMP concerns may not be relevant to this project, others most         information. Two agencies submitted comments. No requests for
                  certainly are. For example, as stated above, recreational use is important in both   additional information were received.
                  the sale area and the adjacent WCHMA. In addition, hunting activities may be
                                                                                                        The Office of Habitat Management and Permitting submitted a memo to
                  impacted from the disturbance of a road along the Little Willow Creek moose
                                                                                                       the Office of Project Management and Planning. They determined that this
                  migration corridor. Neither of these issues are adequately analyzed for purposes
                                                                                                       project qualifies for ACMP approval provided a Fish Habitat Permit is
                  of the ACMP consistency review. Furthermore, while the habitat standard for
                                                                                                       secured prior to crossing fish streams.
                  the ACMP is preempted by the FRPA it was not adequately analyzed for
                  purposes of either review. See above. As such, it is impossible to determine         The Mat-Su Borough Planning Division also found the project consistent
                  based on this cursory analysis whether the road corridor across Little Willow        with the Mat-Su Borough Coastal Management Plan with one stipulation:
                  Creek is consistent with the ACMP.
                                                                                                           •    Within the 75 foot shoreline setback, all areas not occupied by
                                                                                                                allowed development must minimize disturbance of natural
                                                                                                                vegetation.
                                                                                                       The reviewing agencies found the FLUP to contain sufficient information
                                                                                                       to find the project consistent with the Alaska and Mat-Su Coastal
                                                                                                       Management Programs.
                  Local opposition
Y Community       We strongly support the Willow Area Community Organization’s (WACO)                  The Department of Natural Resources must make decisions about its
Council           decision to oppose the proposed sale of timber within the approximately 1200         resources based on the best interests of the state of Alaska as a whole, not
                  acres near Willow. We believe this sale would not be in the best long term           just the local communities. This sale will provide jobs to Alaskans, as well
                  interest of the State or its residents.                                              as some timber harvest revenues, while abiding by the Susitna Forestry

Copper Timber Sale: Comment & Response                                                                                                                   37
Commenter         Comment                                                                                 Response
Wittshirk         The proposed sale of timber to NPR and the hacking out of 17 miles of roads             Guidelines, which provide opportunities to harvest timber while protecting
                  into the area north of Hatcher Pass Road will devastate a wilderness area and           other resources and uses.
                  provide little or no benefit to local residents. It's a great deal for NPR---a lousy
                                                                                                          While some comment letters we received supported the sale, the majority
                  deal for us.
                                                                                                          of the letters opposed the sale. However, the public comment period is not
WACO              At a general meeting of the Willow Area Community Organization (WACO), a
                                                                                                          intended to serve as a vote. While we take all the comments into
                  motion was passed to notify you of it's opposition to the proposed Copper
                                                                                                          consideration, we must determine whether the timber sale is in the best
                  Timber Sale in the Willow area. The community feels it is not in the best
                                                                                                          interest of the state of Alaska.
                  interests of Willow nor in the best interests of the State to precede with the sale.
                  …                                                                                       The proposed timber harvest is within the guidelines in the Susitna Forestry
                  Our community would support the Copper Timber Sale if it could be done                  Guidelines, which were designed to allow some timber management while
                  without adversely effecting other important land uses, when it generates                protecting the other high-value resources in the area, including recreation,
                  significant revenue or would provide an important ``value added'' product to            tourism, and wildlife habitat.
                  the local or state economy. The Willow Area Community Organization feels
                                                                                                          All comments are taken into account when writing the Forest Land Use
                  this sale does none of these things and is not in the best interest of our
                                                                                                          Plan (FLUP). The comments we receive on each of our FLUPs influence
                  community or the State.
                                                                                                          the final finding. For example, for the West Petersville sale, in response to
                                                                                                          public comment, we changed the sale boundaries, included additional
TCC               Whereas recent timber sales have caused considerable problems and very little
                                                                                                          stipulations in the timber sale contract for the timber operator (for example,
                  benefit to people throughout the Northern Susitna Valley, the Talkeetna
                                                                                                          hours of operation), added guidelines to prevent the spread of invasive
                  Community Council supports the Willow Area Community Organization in
                                                                                                          species, and added more information and guidelines about wildlife habitat,
                  their opposition to the Copper Timber Sale east of Willow.
                                                                                                          fish habitat, transportation, and other resources and uses.
Strasenburgh      The profit goes outside the local community, but the local community bears the          We carefully consider each comment we receive, and respond to it,
                  costs, in terms of beat up roads, safety, dust, noise, lights all night long, spoiled   showing how we have changed the final finding if a change was necessary,
                  landscape, diminished water quality, negative impacts to local recreation or            or explaining why we did not change it if we did not feel it was necessary.
                  tourism businesses, and so on. It is not a good deal for the locals, and it is not a
                  good deal for the State.

Korpi             I AM STRONGLY OPPOSED TO THIS SALE AS ARE THE VAST
                  MAJORITY OF THE LOCAL POPULATION!!!
Davidson          Furthermore, this sale has been unanimously opposed by the people of Willow.
                  We are not talking anti-development tree huggers here, these are the people of
                  Willow.
Corlyn-Belka      Willow is a pristine and heavily used recreation area that garners a great deal of
                  its income from recreational visitors in the area. Clear-cutting near salmon
                  streams, disconnecting sled-dog trails...why don't we just give up our Alaskan
                  feel of Northern Adventure and just go ahead and become California. Why not?
                  Because we won't let that happen. I feel comp[elled to let youknow that there is
                  a large contingency of people who are opposed to clea-cutting and we will
                  mobilize against this sale in hoards. The West Petersville project got no bids
                  mostly because of such a large public outcry. That was a whisper compared to
                  the action we'll take this time.



Copper Timber Sale: Comment & Response                                                                                                                        38
Commenter         Comment                                                                             Response
ACE               The DOF is also quick to dismiss the reasons for receiving the grand total of
                  zero bids on a similarly sized sale, West Petersville #1 near Trapper Creek. The
                  FLUP at 28 takes the corporation’s explanation of high transportation costs
                  deterring NPI from bidding, at face value. While at the same time the DOF
                  ignores the unanimous objection of local residents to the West Petersville sale.
                  With this dismissal of local concerns, it is clear whose interests the DOF is
                  advocating.
Leo               All four upper Su Valley Community Councils oppose this sale because
                  almost every individual resident is opposed to it. To proceed is a
                  violation of the public trust.
Cascadia          The unanimous community council resolutions decrying this sale as damaging
                  to not only ecology and recreation, but to the local economy, should be
                  considered. The public represented by an Oklahoma-owned corporation is
                  apparently being given more sway that the actual Alaskan public who lives in
                  this neck of the woods.

                  FLUP language
Strasenburgh      The FLUP, on page 3, states: “The purpose of this Forest Land Use Plan              The Copper Timber Sale and the West Petersville Road #1 Timber Sale
                  (FLUP) is to provide sufficient information for reviewers to ensure that the best   have very similar issues in terms of economics. They are both in Region II
                  interest of the state will be served….” by offering this timber for sale.           (Southcentral Alaska), and were both designed to provide birch timber for a
                                                                                                      chipping operation. We abide by the same regulations for all timber sales
                  Below is the language under P. Economics, on pages 26 and 27 of the FLUP:           in Region II, and in the Susitna Valley, the Susitna Forestry Guidelines, so
                                                                                                      the discussion of issues for sales in Region II is often similar.
                           In addition to generating royalties to the state’s general fund, the
                           proposed sale will create economic benefits to the Matanuska-Susitna
                           Borough and to other locations in Alaska. The borough business
                           community will receive direct economic benefits from providing
                           support services for the operators through sales of fuel, food, housing,
                           medical and miscellaneous supplies. The residents of the borough will
                           receive an indirect benefit through property taxes paid to the borough
                           by the operator and employees during the course of the timber harvest
                           operation.
                           The sale is expected to benefit the local economy by providing jobs.
                           This timber sale will have a positive impact on statewide employment
                           by generating at minimum an estimated 24,500 man-hours of work
                           directly associated with the harvest and wood processing operations in
                           this sale.
                           Additional impacts could be creating additional access for the public
                           and providing moose browse for increased subsistence and hunting
                           opportunities that would attract people to the local communities where
Copper Timber Sale: Comment & Response                                                                                                                  39
Commenter         Comment                                                                             Response
                           they would purchase goods and services.

                  This language is not unique; it is standard boilerplate that DOF uses repeatedly,
                  sale after sale, regardless of the individual differences among sales. With the
                  exception of the third paragraph, the Copper FLUP section P. is identical, word
                  for word, to the West Petersville #1 FLUP Final Finding II.




Copper Timber Sale: Comment & Response                                                                           40

								
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