Tongass Timber Sale Update: How an endemic species can halt a timber sale

Earlier in September, a press release from the Greater Southeast Alaska Conservation Community (GSACC) was shared with this blog. It opened with:

On August 16, GSACC and four other organizations filed an administrative appeal of the Tongass Forest Supervisor’s decision to proceed with the Big Thorne timber project. The appeal went to to the next highest level in the agency, Regional Forester Beth Pendleton. The appeal is known as Cascadia Wildlands et al. (2013), and other co-appellants are Greenpeace, Center for Biological Diversity and Tongass Conservation Society.

The project would log 148 million board feet of timber [enough to fill 29,600 log trucks], including over 6,000 acres of old-growth forest from heavily hammered Prince of Wales Island. 46 miles of new logging roads would be built and another 36 miles would be reconstructed.

Today, we get an update on the Big Thorne timber sale on the Tongass National Forest in Alaska in the form of this article, written by Dr. Natalie Dawson, one of GSACC’s board members.

Wolf

“When you spend much time on islands with naturalists you will tend to hear two words in particular an awful lot: ‘endemic’ and ‘exotic’. Three if you count ‘disaster’. An ‘endemic’ species of plant or animal is one that is native to an island or region and is found nowhere else at all.”
-From Last Chance to See by Douglas Adams, author of A Hitchhiker’s Guide to the Galaxy

by Natalie Dawson

On the Tongass National Forest, we hear mostly about trees – whether it be discussions about board feet, acres of old growth, percentage of forest converted to “second-growth” or “the matrix”[*], our conversations tend to focus on the dominant plant species group that defines the rare “coastal temperate rainforest” biome. However, the Tongass is more than a forest, it is a conglomerate of islands, islands of different sizes, islands of different geologic and cultural histories, islands with or without black bears, grizzly bears, or wolves, the iconic species of Alaska. Because of these islands, there are unique, or, endemic, species of various size, shape and color across the islands. Though they have played a minimal role in management throughout the course of Tongass history, they are now rightfully finding their place in the spotlight thanks to a recent decision by regional forester Beth Pendleton.

On Monday (Sept. 30), the US Forest Service announced its decision to reconsider the Big Thorne timber project. This project would have been the largest timber project on the Tongass National Forest in twenty years, taking 6,200 acres of old growth forest (trees up to 800 years old, 100 feet tall, and 12 feet in diameter) from Prince of Wales Island, an island that has suffered the most intense logging in the region over the past six decades. It is also an island that is home to endemic animals found nowhere else in the world.

Citizens of southeast Alaska and environmental organizations including GSACC jointly filed an administrative appeal on the Big Thorne timber project on August 16th of this year. Monday’s response comes directly from regional forester Beth Pendleton. In the appeal, Pendleton cited an expert declaration written by Dave Person, a former Alaska Department of Fish and Game (ADFG) biologist with over 22 years of experience studying endemic Alexander Archipelago wolves on Prince of Wales Island, with most of his research occurring within the Big Thorne project area. Pendleton cited Person’s conclusion that “the Big Thorne timber sale, if implemented, represents the final straw that will break the back of a sustainable wolf-deer predator-prey ecological community on Prince of Wales Island…” Her letter states, “This is new information that I cannot ignore.” The response to the appeal requires significant review of the timber project before it can move forward, including cooperative engagement between the Tongass National Forest and the Interagency Wolf Task Force to evaluate whether Dr. Person’s statement represents “significant new circumstances or information relevant to” cumulative effects on wolves (including both direct mortality and habitat).

As one of my students today in class asked me pointedly, “So what does all this mean?” Well, it means that the largest potential timber sale in recent history on our nation’s largest national forest, on the third largest island under U.S. ownership, is temporarily halted under administrative processes due to an endemic species. It does not mean that this area is protected. It does not mean, that our work is done. Pending the outcome from conversations between the Forest Supervisor and the Interagency Wolf Task Force, especially under the current political climate within the state of Alaska, we may have plenty to keep us busy in the near future. It does mean that, even if only briefly, the endemic mammals of the Tongass National Forest received a most deserving moment in the spotlight. This could result in a sea-change in how the Tongass National Forest is managed.

This also means that science is being given a chance to play an important role in an administrative decision on our nation’s public lands, and two endemic species, the Alexander Archipelago wolf, and its primary prey species, the Sitka Black-Tailed deer, are forcing federal and state agency personnel to reconsider their actions. Science must continue to play an important role in the future of all activities on Prince of Wales Island. It is home to many endemic animals found only on a small percentage of islands on the Tongass National Forest, and nowhere else in the world. This lineup includes the Prince of Wales Island flying squirrel, the spruce grouse, the Haida ermine, and potentially the Pacific marten, which was only recently discovered on nearby Dall Island. The future of the Tongass timber program and human development on these complex islands are inextricably tied to ensuring a future for all other species in one of the world’s only remaining coastal temperate rainforests.
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Dr. Natalie Dawson has done years of field work on endemic mammals throughout much of Southeast Alaska, studying their population sizes and distributions through field and laboratory investigations, and has published peer-reviewed scientific papers on these topics. She presently is director of the Wilderness Institute at the University of Montana and a professor in the College of Forestry and Conservation.

[*] What is the matrix? The conservation strategy in the Tongass Forest Plan establishes streamside buffers (no logging) and designates minimal old growth reserves, in an attempt to ensure that wildlife species on the Tongass remain viable. (Whether the strategy is sufficient for this is at best questionable.) The matrix is the expanse of habitat that is allocated to development (such as logging) or that is already developed, and which surrounds those patches of protected habitat.

UPDATE: Readers may notice that in the comments section a claim is made that the Sitka black-tailed deer are not endemic, but were were introduced. The Sitka black-tailed deer (Odocdileus hemionus sitkensis) were not introduced to Southeast Alaska; the Sitka black-tailed deer is indeed an indigenous, endemic species there.

Also, another commenter suggested referring to the article on the GSACC website, as at the bottom of the article one can find much more information about the Big Thorne timber sale and also the declaration of Dr. David Person regarding Big Thorne deer, wolf impacts. Thanks.

5 Groups Appeal Tongass Timber Sale: 6,000 acres of old-growth would be logged, 46 miles of new roads constructed

The following was sent to me by the Greater Southeast Alaska Conservation Community (GSACC). If you have any questions about the release and the info contained within it, please contact the GSACC directly. Thanks. – mk

On August 16, GSACC and four other organizations filed an administrative appeal of the Tongass Forest Supervisor’s decision to proceed with the Big Thorne timber project. The appeal went to to the next highest level in the agency, Regional Forester Beth Pendleton. The appeal is known as Cascadia Wildlands et al. (2013), and other co-appellants are Greenpeace, Center for Biological Diversity and Tongass Conservation Society.

The project would log 148 million board feet of timber [enough to fill 29,600 log trucks], including over 6,000 acres of old-growth forest from heavily hammered Prince of Wales Island. 46 miles of new logging roads would be built and another 36 miles would be reconstructed. Our points of appeal encompass fundamental problems with the concept of the project, its economic problems, aquatic impacts from roading and logging, and severe impacts to wildlife including wolves, deer, bear, goshawks and flying squirrels. Our Request for Relief is that “the decision to approve the ROD and FEIS be reversed and that the project be cancelled in its entirety because of multiple failures to comply with the Administrative Procedure Act (APA), National Environmental Policy Act (NEPA), National Forest Management Act (NFMA), Clean Water Act (CWA), Alaska National Interest Lands Conservation Act (ANILCA), Tongass Timber Reform Act (TTRA), Federal Advisory Committee Act (FACA) and various regulations and policies implementing these statutes.”

Included with the appeal were three expert declarations. One is by Dr. David Person, who did 22 years wolf and other ecological research on Prince of Wales Island and recently retired from the Alaska Department of Fish & Game. It says that the predator-prey system on the island (which includes wolves, bear, people and deer) is likely at the point of collapse, with the Big Thorne project being the tipping point. Another declaration is by Jon Rhodes, an expert on the sediment impacts of logging roads and their effect on fish. The third is by Joe Mehrkens, GSACC board member and former Alaska Regional Economist for the Forest Service, on the failings of the economic analysis in the Big Thorne EIS and economic nonsense this project embodies.

The appeal and the declarations are available for viewing and download at this link. Because the appeal is 127 pages, you will likely find the clickable table of contents useful. This series of e-mails illustrates the kind of biological knowledge that the State of Alaska has withheld from the NEPA process for the Big Thorne timber sale project on the Tongass National Forest.

Alaska’s chief forester hoodwinks Congress about the Tongass

(The following note and op-ed is from Larry Edwards, a Greenpeace forest campaigner and 36-year Sitka, Alaska resident. – mk)

I published the op-ed below today in the Juneau Empire, concerning fundamentally false testimony given at  Senator Wyden’s Senate E&NR Committee hearing on public forests (USFS and BLM) on June 25.  The particular testimony was given by the director of Alaska DNR’s Division of Forestry, Chris Maisch.

Although the topic may seem regional, concerning particulars about the Tongass National Forest, the piece should be of interest more broadly because Maisch’s testimony and the hearing in general were used to justify Senator Wyden’s approach to getting logging levels “UP” (his emphasis, repeatedly) by “streamlining” NEPA and ESA.

— Larry Edwards

——————–

Chris Maisch hoodwinks Congress about the Tongass
By Larry Edwards, Greenpeace
July 10, 2013

Alaska’s chief forester, Chris Maisch, should be fired and be held in contempt of Congress. Falsehoods were plentiful in his June 25 testimony to the Senate Energy & Natural Resources Committee, representing the state on Tongass National Forest issues.

He called these falsehoods “grim realities.” They mislead Congress, and their negativity harms the morale and economic reputation of Southeast Alaska.

Maisch introduced the Tongass as “the largest national forest …17 million acres of land.” Correct. But in noting merely that “not all of this” can be logged, he avoided informing senators that this land area is two-thirds glaciers, ice caps, rocky peaks, muskegs and scrubby trees. That’s nothing anyone would try to log, and not the prized forest habitats embroiled in controversy.

Had he disclosed that, his main point would have been silly: “the suitable timber base available for management has declined to only 672 thousand acres — or 4 percent of the Tongass acreage.” The comparison is absurd because the overwhelming portion of other 96 percent of the Tongass is the non-forest and unloggable landforms just described. Alaska’ chief forester must know better than the vision this created for senators.

More deceptively, he said, “Despite more than 50 years of timber harvest in the Tongass, a mere 2.5 percent of the old growth forest has been harvested.” That cons the Senate into believing the Tongass timber industry has had minuscule impact on forest habitat. If the existing 440,000 acres of Tongass clearcuts are really just “2.5 percent of the old growth,” doing the math, all the 17 million acres had to be old growth. Effectively, Maisch’s vision for senators is that there are no glaciers or unloggable terrains at all on the Tongass — just uninterrupted old-growth everywhere, of comparable quality to what has been logged.

Also deceptive: “The Tongass … is bigger than West Virginia, yet [that state has] 181 sawmills and 30,000 people employed.” West Virginia has far more commercial quality forest than the Tongass, and its climate grows trees faster. West Virginia’s industry is close to markets; Alaska’s is remote. Maisch’s incomplete comparison hoodwinked senators.

Maisch did a jobs shell-game. His testimony focused entirely on the Tongass, not mentioning other forest ownerships. Yet he claimed, “logging and wood products employment remains a mere shadow of its past, falling from 4,600 jobs in 1990 to approximately 307 logging jobs and 150 wood products manufacturing jobs in 2011.” In 1990 only 4,000 such jobs existed statewide. It was the peak year of Southeast Alaska’s logging boom, employing 3450. (Alaska Department of Labor). Over half the timber came from Native corporations rapidly liquidating their forests, not the Tongass. Maisch’s inaccuracy and comparison to an unsustainable high-water mark misdirected senators.

The current 457 jobs, too, are statewide. Under 100 jobs depend on Tongass timber, making this a good time for quickly transitioning out of Tongass old-growth logging. Magnifying the Tongass industry as four-plus times its actual size, Maisch avoided being confronted with that option. He asks the opposite — the ceding of 2 million acres of old-growth from the Tongass for logging — with contrived facts.

Maisch pointed to supposed steady decline in Southeast Alaska’s population and school enrollment. Population did decline 5 percent between the 2000 and 2010 Censuses, but senators also need to know the State estimates the population has rebounded 3.8 percent since 2010.

Maisch said school enrollment has declined 15 percent, “sustained over nearly two decades” in 87 percent of communities. Broad decline lasted only from 2000 to 2006. Stability or growth have become commonplace since then. Analyzing State records, enrollment has been stable in nearly 60 percent of Southeast’s school districts for the last 3-10 years, and is increasing in nearly one-quarter.

He also claimed that since 1990 six schools closed and the Southeast Island School District’s (SISD) enrollment declined from 381 to 160 students. (Enrollment of under 10 causes closure; correspondence school is a fallback option.) Of those six, permanent closures in two tiny fishing villages (1997 and 1999) and in Hyder (2009) are irrelevant to logging issues. A fourth school closed only during 1996. The remaining two, in timber country, have cycled on/off for two decades. Maisch ignored SISD’s steady enrollment recovery since 2010, reaching 190 (not 160) this year.

Chris Maisch’s testimony was fundamentally false. If he believes what he said, he is not a competent public resources steward. If otherwise, he committed perjury. Either way he must go, and the State needs to retract his testimony!

• Larry Edwards is a Greenpeace forest campaigner and 36-year Sitka
resident.

Tongass Timber Economics 101

Tongass
By Joseph R. Mehrkens (retired economist)

This paper is designed as a briefing paper.  Future revisions and additions will periodically occur.  It will be available on the Greater Southeast Alaska Conservation Community website.  It is the sole product of J.R. Mehrkens and is based primarily on Tongass information collected since 1977 and organized into a series of Excel Spreadsheets.

Introduction:  It is well known that the Tongass timber program is a real money loser.  The GAO (federal Government Accountability Office) found in the late 1990s that the Tongass timber program lost 80-94 cents on every dollar spent.  The loss is far worse today – especially with the new wrinkle where the Forest Service uses old-growth timber sale revenues to finance even greater money losing activities, e.g., stewardship/restoration contracts.  In essence, this means more old-growth is logged to ostensibly repair past old-growth logging and to create more potential restoration projects.

While forest restoration is a good goal, there are far superior ways to pay for it.  However, first it’s important to revisit some of the basic underlying issues of Tongass timber economics such as taxpayer losses, the steep decline in timber demand and the high costs for logging roads (the greatest contributor to taxpayer losses).

In economic analysis there are two primary tasks: (1) identifying the stream of costs and benefits over time to determine if benefits exceed costs, and (2) identifying who benefits from and who pays for the project.  To date all of the Tongass restoration projects (proposed or in-progress) have done neither.

Download the entire paper here.

NOTE: Joseph R. Mehrkens is a retired resource economist residing in Juneau, Alaska. He has B.S. in Forestry from the University of Minnesota and a M.S. in Forest Economics from Michigan State University. Since 1979 he has worked as an economist for the U.S. Forest Service, The Wilderness Society, the Alaska Department of Commerce and Economic Development and as a private consultant. Past work assignments include assessments of the timber trade between Alaska and the Pacific Rim countries, Congressional reports on the annual supply and demand for Southeast Alaska timber, lobbying for the passage of the Tongass Timber Reform Act of 1990, testifying before Congress on taxpayer subsidies for Tongass NF timber, and recommending changes to the President’s Budget for the Tongass NF for consideration by the House and Senate Appropriations Committees.

Retired Forest Service Economist on Folly of Sealaska Bill

The following piece was written by Joe Mehrkens, a retired Forest Service economist and a former alternate member of the Tongass Futures Roundtable.  We’ve discussed the Sealaska bill on this blog previously. – mk

Back in the heydays taxpayers paid a subsidy of $12,000-$36,000 per Tongass timber job. Based on more recent Forest Service accounting information, this subsidy has grown during the last decade to a staggering $224,000-$510,000/job, a nearly 1,400% increase. How can this be? Simply, the Forest Service kept spending like the industry was in its heyday while the industry was in a persistent long-term decline.

To the Forest Service’s credit the Tongass timber program expenditures have decreased in recent years, but the fact remains that the Forest Service is still chasing after fewer and fewer timber jobs. The result is that the subsidy/job remains extraordinarily high. However, the current subsidies will be pale in comparison to those to support a 2nd-growth industry. The 2nd-growth subsidies will be from cradle to grave: for mill construction, raw material procurement, manufacturing, transportation, and perhaps even marketing & sales.

Ironically, the need for these vertically integrated subsidies is very well documented in a letter from Senator Murkowski to USDA Secretary Vilsack, dated March 13, 2013. In her letter Senator Murkowski asks the federal taxpayers to build two biomass plants, three lumber mills, and even help start a guitar factory. But Senator Murkowski also relays a very big ask made by the Viking mill owners: Most recently Kirk Dahlstrom has made a new proposal saying that he could remodel a current small log processing line for a grant of just $1.5 million to cover some equipment costs, if the Forest Service would enter into a true partnership with his mill to prove the economics of young growth. He is now proposing that the Forest Service cover the costs of logging and transporting young growth to his mill . He [Mr Dahlstorm] is asking the Forest Service to cover his actual costs of processing, sawing and kiln drying of the timber and provide him a 20 percent profit on just those operations the Forest Service then keeping any profits from shipping and marketing the timber. That is about as cradle to grave as you can get. But in all honesty, reading between the lines indicates little confidence in transition to 2nd-growth any time soon.

There are, and will be, small and sporadic opportunities for 2nd-growth, but not supporting a new region-wide integrated timber industry. Like old-growth the limiting factor will be the inability to sustainably compete against the many other global suppliers. This means the Alaska Transition simply has no clothes.

Nonetheless, the Forest Service is even going one step further by proposing policy changes to accelerate the Transition . Not surprisingly, there are no predicted dates except perhaps when the old-growth will be cut-out in about 30 years. If the Transition has no clothes than an accelerated Transition is wishing makes it so . Yet, the Transition is very much alive and well.

In fact, provisions for an accelerated Transition are now part of the political horse trading surrounding Sealaska Corporation’s expanded settlement under ANCSA (S.340). Sealaska’s S.340 is now conveniently bundled with a wider set of lower 48 lands/wilderness bills known as the Omnibus bill.

S.340 is viewed as the last legislative train leaving the station for environmentalists who want to salvage what little lands protection S.340 has offered them to date. To boost their meager take, especially in light of giving up gems they once described as most worthy of protection, some environmental groups are now supporting the legislative provisions for an accelerated transition — not for Alaska — but for the timber industry in the PNW. In the PNW, immature 2nd-growth is already economic.

Nonetheless, the provisions for an accelerated transition are far reaching in terms of changing long-standing National Forest management polices sets a major precedent.

So the grand deal may works like this. The lower 48 Senators who want their Omnibus bill will have to capitulate to Senator Murkowski s quid pro quo of including S.340. In Alaska, opposition to Sealaska’s lands legislation has been prolonged and widespread. So the bundling of S.340 in the Omnibus bill gives Senator Murkowski much needed cover.

Moving on, environmentalists are hoping to get more Tongass wilderness beyond the meager amount provided in S.340 — and its five previous versions. But, environmentalists have relatively little leverage, except perhaps for supporting the provisions for an accelerated transition. Not for Alaska industry, but really for PNW s timber industry. Note, that Oregon is the home state of the Chairman of the Senate Energy and Natural Resources.

In my opinion, it is age-old backroom politics — cover-for-cover, deal-for-deal. Unfortunately, the subsidies and other economic losses due to taking federal timber before it’s time (an accelerated transition) could certainly mean that the taxpayer will be the biggest loser.

Audubon: Implications of Pending Tongass National Forest Land Selections on Forest Diversity

Thank you to reader David Beebe for passing along this new report from Alaska Audubon titled, “High‐grading on the Tongass National Forest: Implications of Pending Land Selections on Forest Diversity.”  The entire Audubon report is available here.  I’ve pasted the report summary below, although that’s also available in PDF form here, with the citations included. – mk

UPDATED:  Paul Olson from Sitka, Alaska (who has been a commercial fisherman in southeast Alaska since the 1970s and is the board president of a new regional organization called the Greater Southeast Alaska Conservation Community) provided some excellent context in the comments section that deserves to be highlighted here:

“This legislation is also relevant to the issues you discuss in the ‘collaboration’ blog since the current version of the bill is largely the result of negotiations between a subdivision of a Forest Service initiated ‘collaborative’ group, the Tongass Futures Roundtable. That secretive subdivision is known as the “Devil’s Club” and has been primarily responsible for persistent but to date unsuccessful efforts to rezone public lands on the Tongass National Forest for the primary benefit of private timberland owners. That collaborative group has all the characteristics of a typical collaborative stewardship group – it meets during the day when the working public cannot attend its deliberations; most of the NGO stakeholders had funding funneled to them as a result of high level Forest Service efforts; the participating environmental group representatives are for the most part inexperienced imports from distant lands or otherwise “soft” on certain types of resource development….”

Read Paul Olson’s entire comment here.
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Coastal temperate rainforests of the world occur in only ten areas, are extremely rare, and account for less than 3% of all forest cover on earth. Alaska’s Tongass National Forest contains a large portion of the world’s last remaining old‐growth rainforest. Regarded widely as the “crown jewel” of the national forest system, the Tongass is home to the bulk of America’s remaining old‐growth forest.

Over the last century, the Alaska timber industry has focused logging on the largest and most valuable old‐growth trees of the Tongass. This controversial practice is referred to as “high‐grading” and has already eliminated half or more of the very large‐tree stands on the Tongass. The very biggest trees, the ancient giants greater than 10 feet in diameter that can grow for many centuries, have largely been cut and eliminated from the forest.

Today, the remaining stands of very large‐tree old growth are extremely rare and account for only 0.5 percent (82,000 acres) of the 16.8 million‐acre Tongass. Known as volume class 7, these remnant stands are not only visually impressive but also provide important habitat for five species of Pacific salmon, Steelhead, brown bear, black bear, wolves, Sitka black‐tailed deer, river otter, marten, flying squirrel, Bald Eagle, Marbled Murrelet, Northern Goshawk and other wildlife.

Congress has long‐recognized the problem of high‐grading and took specific action to eliminate this practice of logging “a disproportionate amount of old growth timber” on the Tongass as part of the Tongass Timber Reform Act enacted in 1990.  Some twenty years later, however, the Sealaska Corporation is seeking legislation (S 730/HR 1408) that threatens a return to high‐grading of the largest and most profitable trees. If enacted, the legislation would eliminate a substantial portion of the last remaining very large‐tree old growth forest on the Tongass.

S 730/HR 1408 would re‐open the Alaska Native Claims Settlement Act (ANCSA) of 1971 to give the Sealaska Corporation the unprecedented ability to select and obtain highly valuable public lands in the Tongass containing extremely disproportionate quantities of very large‐tree old‐growth timber. The legislation would permit a 12‐fold increase in the Sealaska Corporation’s logging of very large‐tree old growth. The legislation would also authorize Sealaska Corporation to obtain some the most popular public lands in the Tongass in hundreds of smaller parcels scattered throughout the forest that are currently open to the public for fishing, hunting, and recreation.

Signed into law in 1971, ANCSA is the largest land claims settlement in U.S. history, andwas enacted with strong bi‐partisan support to resolve all aboriginal land claims in Alaska. Under existing ANCSA law, Sealaska Corporation has already made its final land selections within the Tongass. S 730/HR 1408 would give Sealaska Corporation approximately 65,000 acres in new public lands for logging and development outside of areas where the corporation’s existing selections have been made.

To evaluate the impact S 730/HR 1408, Audubon Alaska mapped each of the proposed new timber selections using a US Forest Service forest cover database.

Key report findings include:

• Following decades of controversial logging involving “high grading” (i.e., logging that targets the largest and most valuable old‐growth trees) the remaining stands of very large‐tree old‐growth (class 7) are extremely rare. These stands account for only 0.5 percent or ~ 82,000 acres of the 16.8 million‐acre Tongass National Forest.

• S. 730/HR 1408 would enable Sealaska Corporation to clearcut vastly greater amounts of highly valuable very large‐tree old growth than under current law. Public lands that would be transferred to Sealaska Corporation contain up to 12 times more acres of very large‐tree old growth than occurs on the lands the corporation has already selected under current ANCSA law.

• The public lands that would be obtained by Sealaska Corporation include a significant portion of the last remaining very large‐tree old growth in the Tongass. These highest‐volume large‐tree stands account for only 1.6 percent of productive old growth on the Tongass as a whole but make up 24‐27 percent of the lands Sealaska Corporation seeks under S 730/HR1408.

• Under S 730/HR 1408 Sealaska Corporation could clearcut up to 17 percent of the last remaining very large‐tree old growth (class 7) on the Tongass.

• Public lands that Sealaska Corporation would obtain under S 730/HR 1408 are far more valuable than the corporation’s existing land selections and include approximately $50 million worth of taxpayer‐funded infrastructure and other investments (e.g., roads, trails, bridges, transfer sites, fish habitat restoration projects).

S 730/HR 1408 would result in the permanent loss of a substantial portion of the remaining very large‐tree old growth on the Tongass National Forest. This loss would be additive to the logging of any other large‐tree old growth resulting from U.S. Forest Service timber sales, with long‐term impacts on forest diversity and associated wildlife habitat.