Action Alert

Defenders File Objection to the Prince of Wales Landscape Level Analysis Project

Ancient cedar stump on Prince of Wales. Photo: Elsa Sebastian.

Ancient cedar stump on Prince of Wales. Photo: Elsa Sebastian.

Alaska Rainforest Defenders filed an objection to the POWLLA project in December 2018. You can download the Alaska Rainforest Defenders objection here, and you can also download an objection filed jointly with Earthjustice and other conservation groups.

The Defender’s are deeply concerned with the USFS’s proposed actions presented in POWLLA, which would:

  • Log 235 million board feet (MMBF) of old growth timber over the next decade: 25 MMBF annually during the first five years of implementation and 15 MMBF annually during the second five years of implementation.

  • After logging 235 MMBF Forest Service would then evaluate whether to cut the remaining old growth on the island.

  • Alternative 2 would also remove 3 MMBF of recovering, second-growth forest annually for the first seven years of the project and then escalate to 50 MMBF per year for the final eight years, for a staggering total of 421 MMBF.6

  • The agency would construct 129 miles of temporary road and 35 miles of permanent system road, adding to the economic and ecological cost of the project.

These levels of timber extraction are unreasonable, particularly in light of the damaged ecological condition of Prince of Wales. In ARD’s objection we provide more details on impacts on salmon habitat, address the impacts of clearcutting recovering second growth forests, introduced some new science on Prince of Wales wolves, and challenge the idea of the need for timber harvest on Prince of Wales.

To read more, download Alaska Rainforest Defender’s objection.


WHAT:  Trump's Forest Service and Walker's State of Alaska are pushing federal rulemaking to permanently exempt the Tongass and Chugach national forests from the Roadless Rule. This would be a "state-specific exemption" from the rule.

Alaska Rainforest Defenders urges you to send the Forest Service your comments (here) against the proposed exemption. 

Please also attend the upcoming public hearing (if there will be one) in your town (schedule here).

The website for the proposed exemption is  here.  

The Roadless Rule, enacted in the last days of the Clinton administration after a lengthy public process, prohibits road construction in "inventoried roadless areas" greater than 5,000 acres because roads "have the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics.”

The Roadless Rule, enacted in the last days of the Clinton administration after a lengthy public process, prohibits road construction in "inventoried roadless areas" greater than 5,000 acres because roads "have the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics.”

BACKGROUND AND WHY: The Roadless Rule was first adopted in January 2001. Since then, it has survived several court challenges, one all the way to the Supreme Court, which declined in 2016 to overrule the 9th Circuit’s decision to uphold it. One case still pending in DC District Court.

The Roadless Rule, enacted in the last days of the Clinton administration after a lengthy public process, prohibits road construction in "inventoried roadless areas" greater than 5,000 acres because roads "have the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics.”

In fact, the Roadless Rule was the subject of 600 public hearings, received an avalanche of strong support of over 1 million public comments, and had the backing of hundreds of natural resource scientists[1], all of whom wanted the Tongass included in the Rule.

Importantly, despite the Rule’s prohibitions it does not block all road construction in roadless areas. For example, it allows the Forest Service to approve roads necessary for hydropower and mine development and for linking communities. In fact, “some 55 projects within roadless areas in Alaska have been rapidly approved by the Forest Service”.[2]

COMMENTS DEADLINE: The comment deadline for the proposed Tongass Exemption from the Roadless Rule is midnight, October 15, 2018.

ADDRESSES:  You can submit online here:

.Or send by mail to:

Alaska Roadless Rule,

USDA Forest Service, Alaska Region, Ecosystem Planning and Budget Staff,

P.O. Box 21628,

Juneau, Alaska 99802-1628

Here are some points you could customize and work into your comments:

•   The Governor Walker administration is turning its back on overwhelming public sentiment, science, concerns of American taxpayers, and truly sustainable Alaska industries that rely on intact forest ecosystems.

•   The Roadless Rule protects the world-class, old-growth forest environments that fish and wildlife depend on, American people treasure and Alaskans rely on for their collective livelihoods, quality of life, and subsistence uses. A Tongass exemption from the rule is shortsighted and would undermine all those values.

•   The Walker administration is caving-in to an industry that is less than 1% of the regional economy and has already resulted in a massive, decades-long drain on the public’s financial resources. From 1982-2012 the Forest Service spent $1,193,521,560 more to log the Tongass than it received in timber revenues! Enough already for this loser industry that does great harm for minuscule benefit.

•   The Walker administration feigns concern for the impact of climate change on Alaskan communities, yet with this proposed exemption it ignores that the Tongass is North America’s largest carbon sink, and sequesters 8% of all greenhouse warming gases of national forests in the US.[3] Logging these forests will have severe long-term environmental and economic consequences.

•   The Walker administration, at great commitment and cost to the budget-strapped State of Alaska, participated in the Tongass Advisory Committee which developed a plan to transition out of old growth logging. With this proposed Roadless exemption he has unilaterally abandoned the State’s support of the TAC’s findings and has squandered those resources in order to enter into a highly controversial, Hail Mary attempt to reverse the Rule on the Tongass. After nearly two decades of upheaval, Governor Walker is forcing Alaskans to endure a seemingly perpetual controversy—all to prop up an antiquated, harmful, and tiny sector of Alaska’s economy.

•    On Sept. 6, Governor Walker  announced he will establish a 13 member Alaska Roadless Rule Citizen Advisory Committee. The committee is a farce. Only 12 days later, all but two seats have reportedly been filled.This while the Roadless Exemption Open Houses are in progress, the comment period has not even closed, and local residents are still engaged in their end-of season livelihoods. Clearly, from the get-go, the panel was largely predetermined and the Governor had no interest in selecting from a broad base of qualified candidates.

•   With this proposed exemption, the Walker Administration forces the American tax payer to further subsidize round log exports to China and elsewhere in support of their manufacturing base—not Alaska’s. In fact, the 2016 Tongass Forest Plan makes clear that the Forest Service intends to authorize the export of roughly two-thirds of the timber removed from federal forests as unprocessed logs.[4] Enactment of this proposed rule would continue the trend of managing Tongass public lands as a subsidized timber colony  for the exclusive benefit of Alcan/Transpac Group, an international raw log exporter headquartered in Vancouver B.C., and Viking Lumber of Klawock. Viking is also a large-scale raw log exporter.     

[1] See scientists letter to Congress regarding Alaska Forest Riders and the Roadless Rule. Jan. 28, 2018.

[2] Juneau Empire. Keep the Tongass wild and roadless. Dominick DellaSala, John Schoen, John Talbert. August 17, 2018.

[3] Id.

[4]  2016 LRMP FEIS at 3-492-3-493, Tables 3.22-8, 3.22-9

Comments on the TLMP Amendment Due February 22nd

Download this TLMP Action Alert  (PDF)

Public comments on the Forest Service’s Amendment to the Tongass Land Management Plan (TLMP) are due by Monday Feb. 22. We hope you will pitch-in by taking a bit of time to send your opinions to the agency, since this is a really big deal. TLMP rarely gets changed, this change will set the pace and nature of logging for perhaps several decades, and all the alternatives being considered are very poor.

GSACC urges you put the views below into your own words, and make a submission. Form letters, etc., are counted and considered only as one comment all together, so originality is important.

What you are commenting on is a draft environmental impact statement (DEIS) which includes five alternatives (all quite similar) and a draft Forest Plan. The five alternatives would commit to 370 to 1,100 million board feet (mmbf) of old-growth logging over the next four decades, then to continue at a rate of 50 mmbf per decade thereafter. All together that is a huge additional loss of the already greatly diminished non-renewableold-growth forest resource.

To be effective, it is important to aim you comments at the stated “purpose and need” for the plan amendment, and for an alternative that should have been considered, but wasn’t. Main points to consider making are:

  1. End Old-Growth Logging, Now!

Last year, at meetings of the Forest Service’s appointed Tongass Advisory Committee (TAC), citizens asked over and over that Plan amendment end old-growth logging on the Tongass immediately. The committee refused to recommend such an alternative, nor did the Forest Service include one in the DEIS. But old-growth forest is a finite resource, it has been overexploited on the Tongass for many decades, and logging it needs to be regarded as strip-mining, and ended immediately.

Part of the Purpose and Need for the Plan amendment is to determine which lands will be classified as “suitable” for timber production. All old-growth forestland should be declared “unsuitable,” and this needs to be included in an alternative that is considered in detail and that is then selected for final plan. Also, say that the “projected timber sale quantity” for old-growth should be zero.

  1. End Even Age Timber Management, Now!

Clearcutting mature second growth condemns the most biologically valuable watersheds of the Alexander Archipelago to the status of colonial tree (fiber) plantations, for export purposes. What was cut first on the Tongass were the high-productivity, low elevation forest stands – and the existing alternatives in the EIS for this so-called “Tongass transition” would log them as soon as they are marginally mature. That includes even the second growth in designated habitat reserves, riparian management areas, beach buffers and scenic viewsheds. These older second-growth stands are well on their way toward evolving back to an old-growth state, a process that for the most part needs to continue to the end instead of being cut short.

All the second growth that would be mature enough over the next 20-30 years would be vacuumed up, in attempting to support the existing industry. Instead, it would be reasonable for just some of the smaller mills to be sustained from a small portion of the second growth that is within the current timber-base. Beyond those 20-30 years, which is a time when ample second growth will reach maturity, a reconstituted industry may be reasonable, if the generations living at that time desire it.

  1. The Transition Needs to be About the Communities, Not the Timber Industry.

The alternatives in the DEIS are narrow-minded, with none looking at how to transition the half-dozen communities that have some reliance on logging into prospering on other economic endeavors. These endeavors can include outdoor work (e.g., recreation & tourism, forest road maintenance & decommissioning) or Internet-enabled work, etc. Only about 100 full-time equivalent timber industry jobs are involved – a doable transition for the federal government to lead, for a future that is truly sustainable. The timber economy as promoted in the DEIS is unsustainable, even over the short-term.

  1. The TLMP Planning Process Has Been Illegitimate — Get It on Track!

In May 2010, the Forest Service’s Alaska Regional Forester announced that a rapid transition would be made to end old-growth logging on the Tongass. Six years later we instead have: (1) the recently decided Big Thorne timber sale, by far the largest on the Tongass in over 20 years; (2) more large timber sales in the queue; and (3) a Proposed Alternative in the TLMP Amendment DEIS that would log 600 million board feet of old-growth over the next 40 years, and 900 million board feet within the 100-year planning horizon.

This is not just! In 2013 USDA Secretary Vilsack directed the preparation of the EIS and the TLMP Amendment. At his direction the effort is narrowly focused on timber production, not the kind of open-minded transition our region really needs. To further his marching orders, the Forest Service hand-picked a formally designated, federally-ensconced Tongass Advisory Committee (TAC). Plainly, the TAC members were unrepresentative of Southeast’s society and economy, it was set up to give the Forest Service a patina of “social license” for the plan it wanted all along. The TAC’s recommendation is now the Proposed Alternative for the TLMP Amendment. Instead, many citizens testified to the TAC that an immediate end to old-growth logging is what is sorely needed.

The Final EIS needs to include a new alternative that will accomplish that, and it needs to be adopted. We need a wholly new approach to management of the Tongass for the 21st Century, not a throwback to the past century.

The deadline is: received by midnight, on Monday February 22


Forest Supervisor, Tongass National Forest,

Attn: Forest Plan Amendment

648 Mission Street

Ketchikan, AK 99901.