Chinese market adds wrinkle to ailing Northwest logging industry


From the Douglas County News-Review

China’s effect on the U.S. timber industry is a classic story of supply and demand, with winners and losers.

U.S. home building continues to lag far below pre-recession levels. Meanwhile, millions of new homes are being built in rapidly growing China, the largest foreign customer for Oregon timber.

Demand by China has driven up timber harvests and log prices, even though the domestic market for wood products is weak.

Since most of the timber bound for overseas leaves Oregon in the form of raw logs, rather than finished wood products, China has kept loggers working and benefited timberland owners. But it’s put the squeeze on mills.

“It’s a mixed blessing. It’s had a negative effect on our milling infrastructure, but it’s a positive for our loggers and landowners,” said Bob Ragon, executive director of Roseburg-based Douglas Timber Operators, a timber advocacy group.

Until a few weeks ago, ports almost couldn’t load ships fast enough to sate China’s appetite for logs. In the first half of this year, the West Coast exported nearly 1 billion board feet of logs, mostly to China. That was a 79 percent increase over the same period in 2010, U.S. Forest Service economists found.

Oregon supplied more than half the logs, a total of 518.5 million board feet. Industry veterans say the developing Chinese market brought on record log prices, sometimes almost double normal prices.

Today, exports to China are in a lull. But industry insiders expect the hiatus to be only temporary and for demand to rise again in the spring.

“I guess that’s what happens when you do business with China. In the past, China has been known to do this, jump in and jump out,” Ragon said.

The hot-and-cold Chinese market adds a new element of uncertainty to the ailing wood products industry, which can’t afford to compete with China for logs when plywood and two-by-fours aren’t selling at home.

The volatile Chinese market has left people questioning whether China will become a dependable customer as lawmakers court the Chinese to buy American.

State Rep. Tim Freeman, R-Roseburg, went to China with a delegation of Oregon lawmakers in September and said China’s “emerging economy and boom has created a situation where they’re consuming more than they can produce.”

He said Oregon’s annual exports to China total $4 billion, quadruple exports eight years ago, and are mostly made up of commodities from Intel and other high-tech companies.

Freeman said Oregon’s proximity to the Pacific Rim should make China a growing market. Freeman said the delegation didn’t discuss log exports with their hosts.

Ragon and others say the best-case scenario would be for the Chinese to buy finished wood products from Oregon mills.

Ragon said exporting manufactured wood products, instead of logs, would triple or quadruple employment throughout the industry.

For now though, far more of Oregon’s cut trees are exported as logs rather than finished products, by a ratio of 10 to 1.

Oregon Employment Department Regional Economist Brian Rooney reports that mill jobs outnumber logging jobs by three to one in Douglas County. The number mill jobs, however, is declining. Rooney said the booming export market drove a slight increase in logging jobs, but not enough to offset the loss of mill jobs.

Oregon State University Extension Service forestry agent Steve Bowers said high log prices particularly benefited landowners with stands of Sitka spruce, hemlock and white fir — trees not as coveted by mills as Douglas fir.

Bowers said China, which has different building needs, was indiscriminate in the wood it bought. China’s demand for all types of logs, however, naturally drove up the price for Douglas fir, too.

“Export was dictating the values for domestic buyers, and they did not like that,” he said.

The president and CEO of Lone Rock Timber Co., Toby Luther, said the Roseburg logging company sends less than 10 percent of its logs to exporters. But the statewide increase in logging was driven by China.

“The amount of harvest is up, and that’s not because of mills. It’s because of China,” Luther said. “My concern is that, China continues to buy up logs and makes mills less competitive in terms of accessing logs at a price they can afford.”

Luther said log prices are comparable to what they were during the building boom in 2004-05, but mills can’t justify paying those high prices because of low domestic sales.

When Glendale-based Swanson Group this month announced temporary shutdowns, beginning Monday, that will affect all four of its mills and 700 employees, company President Steve Swanson blamed the foreign competition for logs.

Jim Dudley, log procurement and marketing manager for Roseburg Forest Products, said RFP has experienced similar price pressure. Most West Coast manufacturers are suffering losses, he said.

Nevertheless, there is an upside for manufacturers. Dudley said the export market has sustained logging companies that wood products manufacturers will need when home building bounces back in the U.S.

“While (foreign competition) has been difficult to compete with on the manufacturing side, it has helped us protect our logging infrastructure. If we get any increase in domestic demand, it’s important to have that infrastructure,” he said.

Dudley and others in the logging industry say more federal logs, which can’t be exported, would ease the large price swings the Chinese market has caused.

Dudley said if logging on federal lands were increased to even one-fourth of what it was 20 years ago, before the spotted owl was listed as a threatened species, mills would have a steady supply of timber.

The ailing industry is almost entirely dependent on logging from private lands, he said.

According to the Oregon Department of Forestry, 75 percent of the state’s timber harvest occurs on private land, which makes up 38 percent of the state’s forests. Federal forests make up 59 percent of the resource and contribute 12 percent of the state’s timber production.

In Douglas County, private lands account for 44 percent of forestland and supplied 86 percent of the harvest in 2010. A majority of the county’s timberland, 54 percent, are on federal lands and produced 12 percent of the harvest.

“Now the onus has been put on private property to provide all the jobs for the Oregon forest industry,” Dudley said.

Environmentalists counter that the onus for providing wildlife habitat falls on federal lands.

“It seems to me that if the industry wants public logs, they have some responsibility to provide some habitat on their lands,” said Ken Carloni, president of Umpqua Watersheds, a Roseburg-based conservation group.

Carloni said only a lack of “cheap federal logs” was cramping domestic supply and suggested an export tax on raw logs could encourage China to purchase processed lumber instead.

“If it weren’t so attractive to ship the logs, then the domestic supply of logs would increase. Just as much fiber should be hitting those freighters and going overseas, it just should be square instead of round,” he said.

Industry leaders say unless there was a global agreement such a tax would drive the Chinese to buy logs from other countries, like Canada and Argentina.

“You put protectionist taxes on timber and you could tax your way right out of the market,” said Dave Stroble, Southwest Washington and Oregon region manager for Merrill & Ring, a Seattle-based log exporter.

Stroble said U.S. log exporters are in a wait-and-see period as the competitive Chinese market develops.

“The longer it lasts, the more it will mature. It could take years or decades to reach a level of stabilization that we’re used to over here, and it’s hard to speculate how this market is going to mature,” he said.

Our Public Land/ Private Forest Resources: How Not to Be a Colony

Large loaders negotiate waves of logs as they load visiting log ship Global Wisdom at the Port of Olympia in late September

It’s interesting, but not surprising, how our current serious economic situation has changed some of the tenor of discussions of resource use in the U.S. When I was a young sprout, forest policy was clearly in the hands of economists. Then, perhaps in the owl battles of the Pacific Northwest, wildlife biologists and others seemed to be in the lead (remember the Gang of Four?). As our last couple of posts show, knowing something of economics is, perhaps, undergoing a resurgence of importance as we discuss resources and jobs. There seem to be four different conceptual possibilities. First, exporting our resources without manufacturing here (the “colony” idea as stated by Governor Kitzhaber below); second, making sure we get as many jobs as possible from our resources before we export; third, using our resources for our own energy (see Denver Post story below); and fourth not using them at all but leaving them alone (can we afford this?).

In the last couple of days I have seen two pieces from different perspectives. First,
this piece, ostensibly about the FS using a a PR affiliated with Rosemont to work on scheduling public meetings to discuss the proposed Rosemont Mine. The comments are very interesting and go into topics like the copper going to Korea as a raw material, the fact that the mine would be owned by Canadians, and impacts on the trade deficit.

Check out the comments from this..here’s one from CK H.

Without geology and mining you have nothing. Nothing. Not your home, computer, car, electricity of ANY kind (solar, coal, hydro, nuclear, petroleum, gas), clothes you are wearing, the food you are eating (has to be grown with fertilizers, pumped water, transported etc.), bicycles, medical equipment, tile flooring, cosmetics, firearms, backpacks, Kindle/Nook, iPod/Ipad, camera, smartphone, and every other thing you ever possessed or ever will possess.

The ore deposits of various sorts are sitting in host-rock geology in every geologic terrane imaginable. The contained metals or industrial materials are only liberated for your use owing to the dedicated efforts of geologists, mining engineers, metallurgists, technicians galore, haul truck drivers, shovel and LHD operators, surveyors, vendor service supporters, financial whizzes, reclamation and environmental specialists, general managers/foreman…right down to the guys at the end of the chute. Your comfortable life style is thanks to the labor of hundreds of thousands of individuals in small village to large cities around the world.

It sounds almost like dialogue from the “timber wars” days- if we use it (timber, minerals), someone’s going to produce it- why not us? Hypothetically our environmental and worker protections are better than some other places in the world- why not do it if it produces jobs for us and reduces our trade deficit?

Similarly, with regard to private timber, this story.

Kitzhaber: Oregon can’t be China’s timber colony
Cuts on state land could help boost local mill jobs

By Tyler Graf

The Forest Grove News-Times, Nov 9, 2011
(news photo)

Chase Allgood / News-Times

Oregon Governor John Kitzhaber addressed the State Forestry Board last week, arguing that a balance between industry and environmentalists can be achieved.

In July, Stimson Lumber Co. announced a new round of layoffs at its Hagg Lake and Tillamook Mills.

The reason? Boundless demand for logs from China (where buyers want whole, unmilled logs) was draining the demand for local milling.

And as logs from private lands are heading east, jobs here in Oregon’s forested wilds are disappearing.

That doesn’t sit well with Oregon Gov. John Kitzhaber, who tackled the issue during a speech he gave in Forest Grove last week.

Private land owners account for the vast majority of timber harvests and, unlike state-owned forests, are not legally required to mill their logs in the United States. Private-land harvests are often sent whole to China for milling.

“This amounts to nothing more than exporting our natural capital and jobs,” Kitzhaber said.

It’s necessary to increase harvests in state forests, Kitzhaber said, in part to protect struggling mills, but it’s also important for the state to find other revenue streams, such as selling the forest’s carbon credits on the open market.

State forests can take the lead in drafting a more durable future for forest health, the governor said during the regular meeting of the State Forestry Board in Forest Grove Thursday, calling for a new approach to forest management.
Finding middle ground

The governor’s speech centered on finding middle ground between the competing interests of state, federal and private forests and creating “long-term, sustainable practices” that both create jobs and protect natural resources.

“We have the opportunity to break the mold of conflict,” Kitzhaber said.

The federal government owns about 60 percent of the state’s forestland, accounting for 17 million acres. But that land generates only 12 percent of the state’s timber harvests.

Since 1989, timber harvests in the state’s national forests have dropped by 90 percent, sped along by a 1991 federal ruling that closed much of the Northwest’s old-growth forests to logging to protect Northern spotted owl habitat.

On the other hand, the state owns about 3 percent of forestland, including the Clatsop State Forest, and generates about 10 percent of the harvests.

Kitzhaber pushed the board to set aside state forestland for conservation areas, which would be free of timber harvests, as a way of demonstrating that the state is serious about protecting its forest from over-harvesting./blockquote>

But also note that log exports have been good for the Port of Olympia here.

Finally, a piece in the Denver Post this morning on rural jobs and clean energy about Michael Bowman here.

Last week, he found himself the only person to represent rural interests in America at a White House Champions of Change award forum, the Obama administration’s weekly initiative that touts people across the country making change in their communities.

His group of 15 individuals focused on green energy and job creation.

“Everyone knows we make food, but often people don’t think of these rural communities as places where the fuel and energy is going to come from to meet these new demands,” Bowman said.

He praised the wind farms of Colorado’s Eastern Plains and solar development in the San Luis Valley. “The most exciting things are happening where there are renewable-energy projects being built, and putting a tax base into a region where there was none before.”

He also met with officials at the departments of Defense and Agriculture, and pitched a plan for energy independence that would create an alternative to the strategic petroleum reserves — a “working reserve of bio fuel that every farm, ranch, and forest in America can participate in helping create,” he said during a phone interview.

He talked about the fuel-agnostic engine developed by Sturman Industries of Woodland Park. He serves as a consultant to the company, co-founded by Eddie Sturman, who invented digital valve technology for the Apollo space program in the 1960s, and then advanced that technology to create smart engines that run on all types of fuel.

Managing Forests Because Carbon Matters: Journal of Forestry Supplement

Thanks to Terry Seyden for finding this; I’ve been carrying this special section around trying to find time to read it.

New Analysis of Carbon Accounting, Biomass Use, and Climate Benefits
http://www.sciencedaily.com/releases/2011/11/111109093852.htm

ScienceDaily (Nov. 9, 2011) — A recent report provides new ideas surrounding carbon and energy benefits forests and forest products provide. The report, Managing Forests Because Carbon Matters: Integrating Energy, Products, and Land Management Policy, summarizes and analyzes the most recent science regarding forests and carbon accounting, biomass use, and forest carbon offsets.
A team of researchers from the U.S. Forest Service, several universities, and natural resource and environmental organizations coauthored the report, which appears as a supplement to the October/November 2011 issue of the Society of American Forester’s Journal of Forestry.
” This work should help policymakers reconsider the critical impact forests have on our daily lives and the potential they have to solve problems that confront our Nation,” says Bob Malmsheimer, lead author of the report and a professor at State University of New York (Syracuse) College of Environmental Science and Forestry. “We believe our science-based findings should lead toward positive reforms that encourage investment in this vital renewable resource.”

The report suggests that U.S. environment and energy policies should be based on the following science findings:

Sustainably managed forests can provide carbon storage and substitution advantages while delivering a wide range of environmental and social benefits including timber and biomass resources, jobs, economic opportunities, clean water, wildlife habitat, and recreation.
Energy produced from forest biomass returns to the atmosphere carbon that plants absorbed in the relatively recent past; it essentially results in no net release of carbon as long as overall forest inventories are stable or increasing (as with U.S. forests).
Forest products used in place of energy-intensive materials such as metals, concrete, and plastics reduce carbon emissions (because forest products require less fossil fuel-based energy to produce and they also store carbon for a length of time based on their use and disposal), and they provide biomass residuals (i.e., waste wood) that can be substituted for fossil fuels to produce energy.
Fossil fuel-produced energy releases carbon into the atmosphere that has resided in the Earth for millions of years; forest biomass-based energy uses far less of the carbon stored in the Earth, thereby reducing the flow of fossil fuel-based carbon emissions to the atmosphere.

“Perhaps this report will inspire fresh efforts to find management strategies that folks can agree on,” says coauthor and Forest Service scientist Jeremy Fried. “The forest inventory and analysis data collected by the Forest Service on all forested lands in the U.S. provided the data necessary to explore how forests can be managed to provide climate benefits. Full life-cycle analyses of U.S. forests show that the best opportunity for these forests to provide even more climate benefits requires a combination of factors. Those factors are: sustainably managed forests, a healthy market for long-lived forest products, and renewable energy generated from forest and mill residues.”

The report emerged from the Society of American Foresters Task Force on Forest Climate Change Offsets and Use of Forest Biomass for Energy. Authors include Robert Malmsheimer, State University of New York (Syracuse) College of Environmental Science and Forestry; James Bowyer, Professor Emeritus of University of Minnesota; Jeremy Fried, U.S. Forest Service; Edmund Gee, U.S. Forest Service; Robert Izlar, University of Georgia; Reid Miner, National Council for Air and Stream Improvement; Ian Munn, Mississippi State University; Elaine Oneil, University of Washington; and William Stewart, University of California-Berkeley.

Read the paper online here.

Profile of Forest Industry in the Interior West- Guest Post by Todd Morgan

The sun rises at Pyramid Mountain Lumber the morning of August 30, 2011, in Seeley Lake, Montana. They are one of the largest saw mills in Montana.

Another photo by Josh Birnbaum. You can find more of his photos here, on the Celebrate Forests photoblog.

Guest post by Todd Morgan.

Thank you for contacting me regarding forest industry information. I used the link and went to the blog discussion about “corporate interests.” There seems to be a lot of misconceptions or misunderstanding of the logging and wood products industries in the West. Sure, most mills & logging operations are part of corporations, but most local businesses (bike shops, ice cream stands, coffee shops) are incorporated too. Incorporating is a legal means to separate one’s personal finances from those of one’s business. But there are many different kinds of corporations—limited liability, publicly traded, privately held, etc.

Most of the logging and timber-processing firms (the businesses that use timber from private and public lands) in Montana and the other Interior West states are privately held, not publicly traded, most employ fewer than 100 people, and most have owners, officers, and managers that live in or near the community where the business is located. I don’t think the same can be said of industrial forest landowners (TIMOs & REITs). As the wood products industries have changed over the past 30 years, many companies that owned mills and timber land (vertically integrated) sold off one aspect of their business or the other, becoming either a mill/wood products business or a timberland business. There are very few left that have both, and those that do have both are generally overwhelmingly into one aspect or the other. For example is Plum Creek; they are a REIT with a great deal of timberland all over the country, but their only mills are the few in Montana; Rayonier, Weyerhaeuser, Boise, International Paper—these are similar publicly traded companies. But those are quite different than the local mills Pyramid, Tricon, R-Y, Sun Mountain, etc. that have very little or no land holdings, are not publicly traded, and must compete against the big corporations for timber, labor, and market share.

Most logging in our region is also performed by small, private contractor firms; they are not crews that work for the mills; they are not publicly traded companies; and I suspect most are in debt up to their eyeballs, considering the price of logging equipment, fuel, insurance, and skilled labor. Hopefully they are incorporated, so that if the business fails, they don’t lose their homes to pay business debts.

In terms of forest industry info, my program here produces quite a bit of information about Montana’s industry, Idaho’s, as well as the other western states. You have obviously been to our web site and seen some of the quarterly, annual and periodic information we produce. Attached are some documents that may be of interest to you, and below are some specific links to regional publications.

For quarterly conditions in Montana: http://www.bber.umt.edu/forest/wage.asp

For annual forest industry conditions in Montana and Idaho: http://www.bber.umt.edu/forest/outlook.asp

For periodic reports about the industry in various western states: http://www.bber.umt.edu/forest/regionalreports.asp

For a report we did that highlights industry capacity changes across the West as well as in Montana: http://www.bber.umt.edu/forest/timber.asp

It doesn’t take much research to see that the forest industries in the Interior West are more dependent on Federal timber than elsewhere in the country. It likewise doesn’t take much to realize the firms that comprise the forest industries in the Interior West are not the giant, highly politically influential, publicly traded companies that “occupy Missoula” and “occupy Wall Street” are rallying against and which people feel have too much power. Recognizing these facts would, however, require people to give up some of their pre-conceived notions and perhaps re-evaluate their world view.

Please let me know if you find this useful and what other types of info you could use or would like to see made available. We are constantly striving to improve the timeliness, relevance, and usefulness of the information we report. We also have several more up-to-date reports that are going to press or currently in review. These will be posted to our site ASAP.

Thank you again for contacting me. I look forward to further discussion.

Todd Morgan is the Director of Forest Industry Research at the Bureau of Business and Economic Research at the University of Montana.

Here are five documents he provided.
Baucus_request_2009_BBER

Finaldraft_DRC_ report_DRAFT

montana mill closures 4_6_2010

R1_capacity_report

RB-8

Western Wood Processing Facilities Map

Created by Jean Daniels, United States Forest Service, Pacific Northwest Research Station.

While trying to follow up on this discussion of the size and shape of the wood products industry.. I ran across the above map. You can click on it to get a better scale to check out your own local industry. After a couple of clicks, you get a much smaller scale where you can see the different colored circles for different industries.

The site where I found the map is the University of Montana’s Bureau of Business and Economics Research Forest Industry section here. There is much useful information, including the Timber Outlooks and the Regional Reports (although I couldn’t find these for recent years).

Logjam Project Decision

Here’s a link to the decision. I excerpted the parts that referred to the claims made about the NEPA analysis. Here’s a news story.

2. TCS’s first challenge on appeal to the approval of the Logjam Project is that the Forest Service violated NEPA’s requirement that it take a “hard look” at the cumulative impacts of the project by failing to disclose the cumulative environmental impacts from six logging projects currently planned by the Forest Service, as well as from past logging and road building on non-federal lands.
We do not find TCS’s arguments persuasive. The future logging projects identified by TCS involve less than 300 acres, but past harvests in the Tongass National Forest involve over 10,000 acres, and the Logjam Project itself will involve 3,422 acres. The Draft Environmental Impact Statement (“DEIS”) listed the six future logging projects as well as the planned harvests on lands owned by Alaska. It devoted eleven pages to the impact on the aquatic environment, discussed the cumulative impact for each of the alternatives under consideration, and is supported by an appendix that lists projects “in the Logjam Timber Sale Cumulative Effects Area.” Although TCS alludes to other future projects, they appear to be too indefinite to allow a study of their cumulative impact on the Logjam Project. In sum, TCS has not shown that the Forest Service did not take a “hard look” at the cumulative impacts of future projects together with the Logjam Project.
Furthermore, it does not appear that TCS raised concerns about the cumulative impacts from these future projects before the Forest Service. Neither TCS’s administrative appeal of the Logjam Project nor any of the appellants’ objections to the DEIS mentioned the six timber sales on federal land or the two sales on state land. This failure to focus the Forest Service’s attention on the treatment of the cumulative impact of future projects may well bar TCS from raising the matter before this court. See Buckingham v. Sec’y of U.S. Dep’t of Agr., 603 F.3d 1073, 1080 (9th Cir. 2010) (plaintiff barred from raising argument in judicial proceeding because it failed to raise it with the Forest Service “with sufficient clarity to allow the [agency] to understand and rule on the issue”).
TCS also argues that the Forest Service failed to take a “hard look” at the cumulative impacts of future timber sales by “tiering” to a non-NEPA document and by aggregating cumulative impacts. It is true that we have prohibited an environmental impact statement from “tiering” to a non-NEPA document, see Muckleshoot Indian Tribe v. U.S. Forest Serv., 177 F.3d 800, 801-11 (9th Cir. 1999), and League of Wilderness Defenders v. U.S. Forest Serv., 549 F.3d 1211, 1219 (9th Cir. 2008). However, it is not clear whether the FEIS’s citations to certain supporting documents constitute “tiering” in the sense of deferring to the supporting documents to address the impacts of the project, or constitute references to specialist reports prepared specifically for an environmental impact statement as permitted by 40 C.F.R. § 1502.21. Similarly, TCS has not shown that the aggregation of cumulative impacts, which the Ninth Circuit allows for past timber harvests, see Ecology Ctr. v. Castaneda, 574 F.3d 652, 667 (9th Cir. 2009), may not be applied to harvests that have already been approved under a separate environmental impact statement. In any event, there is no suggestion that the Forest Service hid, or failed to consider, any relevant information regarding cumulative impacts.

Finally, even if we were to find some merit to some aspect of TCS’s arguments concerning the cumulative impact of future projects, we would still deny TCS relief on the ground that the error was harmless. In Shinseki v. Sanders, 129 S.Ct. 1696, 1705-06 (2009), the Supreme Court clarified that to set aside an agency decision as being based upon an error, the plaintiff must show that the error was not harmless. We recently reiterated that “the failure to provide notice and comment is harmless only where the agency’s mistake clearly had no bearing on the procedure used or the substance of decision reached.” Cal. Wilderness Coalition v. U.S. Dept. of Energy, 631 F.3d 1072, 1090 (9th Cir. 2011) (internal quotation marks and citations omitted). Under NEPA, we will not grant relief for a violation of procedure if “the decision-maker was otherwise fully informed as to the environmental consequences and NEPA’s goals were met.” Laguna Greenbelt, Inc. v. U.S. Dep’t of Transp., 42 F.3d 517, 527 (9th Cir. 1994). Here, in light of the minimum acreage involved, the Forest Service’s consideration of the impacts, and the parties’ focus on other issues, any error in the presentation of the cumulative impact of future projects would not warrant relief.

3. TCS’s second argument on appeal concerning the Forest Service’s approval of the Logjam Project is that the Forest Service violated NEPA by failing to disclose the concerns of the Alaska Department of Fish and Game (“ADF&G”) about wolf mortality. Specifically, TCS asserts that the DEIS failed to state that ADF&G had concerns about wolf mortality, that this resulted in challenges to the DEIS being focused on wolf mortality concerns rather than discussing alternatives, and that the FEIS, while acknowledging ADF&G’s concerns, did not do so adequately.

We do not find TCS’s arguments convincing. The DEIS disclosed that (a) wolf hunting and trapping occurs in the area, (b) roads provide access for hunters and trappers, and (c) the road densities for the area exceeded the recommended density level. Furthermore, it appears that appellants were aware of ADF&G’s concerns and addressed them in their comments on the DEIS. Thus, the DEIS, despite its misstatement of ADF&G’s position, contained enough information to elicit extensive detailed public comments on the wolf mortality issue, and thus served “the NEPA goals of public participation and informed decision making.” Westlands Water Dist. v. U.S. Dep’t of the Interior, 376 F.3d 853, 874 (9th Cir. 2004).
Moreover, a review of the FEIS reveals that the Forest Service gave wolf mortality the requisite “hard look.” The FEIS (a) recognizes the concerns of the ADF&G biologists, (b) notes that the Forest Service and ADF&G are working on wolf mortality concerns on a broader basis than the project, (c) explains why the harvest data and wolf management reports do not support a wolf mortality concern in the Logjam area, (d) discusses a number of options that ADF&G has for regulating the hunting of wolves, and (e) explains why much of the wolf hunting in the Logjam Project is not explained by the density of roads. The district court properly found that TCS had not shown that the Forest Service failed to take a “hard look” at wolf mortality.

4. TCS’s third issue on appeal also concerns wolf mortality and alleges that the Forest Service violated the National Forest Management Act (“NFMA”) by arbitrarily concluding that wolf mortality was not a concern, failing to consider the unlawful hunting of wolves, failing to consider that closing the project area to hunting will not reduce wolf mortality, and failing to prepare a wolf habitat management program prior to approving the Logjam Project.

TCS’s arguments are not persuasive. The record reveals that the Forest Service does not deny that wolf mortality is a concern. Rather, the record shows that the Forest Service is working with ADF&G to address the concern on a broader level than this particular logging project. An appendix to the FEIS details why approval of the Logjam Project will not compromise the wolf population. Also, the regional supervisor for ADF&G confirms that the ADF&G and the Forest Service are working together to develop a wolf management plan and that the Logjam Project “does not trigger an immediate conservation concern.” Accordingly, our independent review of the record leads us to conclude that the Forest Service reasonably determined that it did not have to prepare a wolf habitat management program in advance of implementing the project. TCS has not shown that the Forest Service acted arbitrarily or in violation of the NFMA in approving the Logjam Project.

5. TCS’s final contention on appeal is that the Forest Service acted arbitrarily in analyzing the impact of the project on deer winter habitat. Specifically, TCS asserts that in its model for determining the effect of the project on deer habitat, the Forest Service (a) first correctly excluded non-federal lands for the estimation of habitat capability, (b) recognized that non-federal land have a presumed zero habitat capability, and (c) then “reported the habitat capability it calculated for just federal lands to be representative of the whole” area, resulting in an overcalculation of capability. The Forest Service responds that the deer model is only one tool for assessing management impacts on deer, and denies that it committed any material methodological error.

We need not determine whether the Forest Service committed an actual computation error of the habitat capability of the Logjam Project area because: (1) it is not clear that TCS raised this claim before the Forest Service, see Buckingham, 603 F.3d at 1073; (2) even if the Forest Service committed a methodological error, the record shows that it nonetheless gave the impact of the Logjam Project on deer habitat the requisite “hard look;” and (3) the distortion due to the computation error, if it occurred, was harmless. The ADF&G notes that it and the Forest Service reviewed the deer model, the model tends to overestimate the impact from timber harvests, and that the deer harvest in 2008 was the highest recorded in the last decade. Furthermore, as non-federal land constitutes only two percent of the Logjam Project area, the maximum distortion due to the alleged computation error would appear to be only two percent. TCS has the burden of showing that this alleged error was not harmless. Shinseki, 129 S. Ct. at 1705-06. Here, in light of all the other considerations that went into the FEIS, any error in the computation of the deer model for the Logjam Project had no bearing on the Forest Service’s decision.