Gravina Documentation, etc.
By Gregory Vickrey
March 13, 2007
Thank you to all of you who have spoken on behalf of Gravina
Island; the traditional and cultural users who depend upon it;
those who enjoy waking up to the wonderful viewshed it provides;
and those that want to see the Bostwick road proceed only through
the proper legal channels.
Thank you for your fortitude and spirit.
Now, to address Mr. Tyson:
Although I suspect from the tone of your email you are not interested
in understanding my perspective on the Bostwick road and the
illegalities of it in addition to the poor conditions along its
length and associated with the rock pits, I am willing to provide
some of the documentation you have asked for in reference to
the position of the Tongass Conservation Society as well as Army
Corps of Engineers staff who visited the site this fall. I also
address a couple of other points from your email. Thank you for
taking the time to write.
You state: "I talked with Greg Staunton, the project engineer
for the state division of forestry, about the logging road on
Thank you for correcting your mistake is saying you communicated
with the project engineer for the Forest Service.
You state: "Perhaps the reason the corps of engineers has
taken no action on your cease and desist order is because when
someone higher up reviewed it they realized that one person from
the corps and you, are not the be all end all on road standards."
I do not issue cease and desist orders. The Army Corps of Engineers
does. There was not one person from the Corps who visited the
site, there were two, along with a gentlemen from the Division
of Natural Resources, ACMP Review. The Corps staff who visited
the site did so in order to check the conditions. It is their
job to ascertain conditions and determine a need for permitting
and mitigation. Their photo-documentation of the road and associated
pits, along with our own, confirm the conditions as they relate
to erosion, debris, and overburden.
"I drove that road and it doesn't look any different than
any other logging road I have ever seen."
Perhaps the next time you choose to drive the road, you and I
could travel it together so I can point out what the Corps recognized
as problematic; those problems are listed in previous communications
on Sitnews, on the TCS website, and with the Army Corps of Engineers
that you may refer to, or you may call the Army Corps of Engineers
staff responsible for the site visit.
"When I found out about the road being built, I took the
time (about the same time you were looking into it apparently)
to call around and find out about public access. I was told that
it would not be open to the public unless the road was upgraded
and some issues with mental health were worked out. I am wondering
how we got two, so very different stories? Be that as it may,
all the information I ever received on the road is exactly what
it ended up being."
Please see the information and references cited below. I encourage
you to also speak with the Army Corps of Engineers staff who
visited the site. I was not privy to your conversations with
folks, but I assume it included information that was not much
different than those made to the Ketchikan Daily News.
"Perhaps you could clue me in on 'the original and publicly
stated plans for the logging road'. I know that a few people
at the borough have told me they would like to see a public access
road to Bostwick but I never heard one word about the logging
road being it. Maybe you could provide me some documentation.
I must have missed it. I try to keep up on this type of information
but I guess this just slipped by me. My point is, building a
logging road and dreaming about a public access road are two
different things. I would hate to see someone try to confuse
the two so they could try to push another agenda. Just a sneaking
suspicion on my part, but when you refer me to the proper documentation
I am sure I can put my fears to rest."
Please consider reviewing the following documents and citations.
Most of this information is available on the internet.
NOTE: This information was taken from the site by me and separately
by the Corps of Engineers prior to its recent deletion by the
A. "The Lewis Reef and Bostwick Lake roads on Gravina Island
near Ketchikan have been a part of two environmental analysis
processes. The Federal Highway Administration included a portion
of the Lewis Reef Road in the Gravina Access Final Environmental
Impact Statement (FEIS) and Record of Decision (ROD). The Forest
Service issued a FEIS for Gravina Island Timber Sale FEIS. Both
FEIS documents were issued in 2004. ADPT&PF is planning to
issue a contract for construction of the first segment or the
Lewis Reef road in spring 2005. The Bostwick Lake Road will connect
to an extension of the Lewis Reef Road. The Bostwick Lake road
is planned for extension to National Forest lands. The State
of Alaska Department of Natural Resources (ADNR) has issued plans
for a timber sale (Bostwick 1) that uses the road corridor identified
for the Bostwick Lake Road. The rules associated with the funding
calls for it to be used on public roads.
The Forest Service is a public road authority and is accepting
the public road role for this work."
B. "Based on the transportation planning between the Forest
Service, ADOT&PF, ADNR, and the Ketchikan Gateway Borough,
potentially there could be a single coordinated transportation
system that begins with the ADOT&PF road from Ketchikan Airport
to a terminus west of the airport through the Airport Reserve
managed by ADOT&PF. That road is proposed to be extended
a short distance to the intersection with the Bostwick Lake road.
A short portion of the Lewis Reef Road will need to be constructed
beyond the intersection to facilitate future connections. The
Bostwick Lake Road has been located across Airport Reserve lands,
across Mental Health Trust Lands, and across ADNR lands to the
National Forest boundary."
A. "Mainline road 8100000 (11.8 miles) will be left open
for recreational purposes and subject to seasonal restrictions
on its use."
B. "The Selected Alternative provides roaded recreation
access to the people of Ketchikan by keeping the mainline road
open following timber harvest."
C. "Road and trail access on Gravina Island can provide
additional recreation opportunities for Ketchikan. This issue
addresses concerns for outdoor recreation opportunities including
scenic values offered in and around the Gravina Island Timber
Sale project area and the effects timber harvest may have on
these opportunities. The Selected Alternative maintains all existing
recreation uses within the Gravina Island Timber Sale project
area, while increasing accessibility for those who cannot use
the area due to the rugged terrain These uses include hiking,
deer hunting, berry-picking, sightseeing, camping, and freshwater
fishing. The roads kept open after the sale will provide motorized
access (except during deer hunting and wolf trapping seasons)
to areas previously inaccessible. Closed roads can be used as
hiking or bicycling trails."
D. "Harvesting trees and building and maintaining a road
system for recreational use will change the roadless character
of the island. The purpose of the Tongass Forest Plan was to
create a Forest-wide, long-term plan to achieve the desired balance
of uses over the entire Tongass National Forest. The Tongass
Forest Plan identified Gravina Island as one of the currently
predominantly inventoried roadless areas that would likely be
significantly developed in implementing the Forest Plan."
E. "The remaining 11.8 miles of mainline road will be left
open for recreational purposes and subject to seasonal restrictions
on its use."
F. "Alternative 1 would not provide for an economic timber
supply (Issue A) nor would it provide new recreational access
to the island (Issue C, Final EIS, Chapter 1)."
G. "Alternative 4 was the original proposed action when
scoping began and in the Draft EIS. It was designed to address
timber supply and economics and provide roaded access to NFS
lands on Gravina Island (Issues A and C). It would provide the
largest volume of timber and the greatest number of jobs of the
action alternatives, but is less cost-effective than Alternative
2 because of increased road construction and helicopter yarding.
It would also maintain a portion of the logging road systemas
open post-harvest, to provide roaded access for recreational
H. "After completion of harvest, the 8100000 and 8105000
mainline roads (15.6 miles) would remain open to provide roaded
I. "A modified version
of Alternative 3 was selected. The modifications were made to
reduce the impacts to deer winter range and to the marine environment
of Bostwick Inlet, and to improve sale economics. The road system
will be maintained as seasonally open to provide recreational
J. "A discharge of dredge or fill material from normal
silviculture activities such as harvesting for the production
of forest products is exempt from Section 404 permitting requirements
in waters of the United States, including wetlands (404(f)(1)(A).
Forest roads qualify for this exemption only if they are constructed
and maintained in accordance with best management practices to
assure that flow and circulation patterns and
chemical and biological characteristics of the waters are not
impaired (404)(f)(1)(E). The BMPs that must be followed are specified
in 33 CFR 323.4(a). These specific BMPs have been incorporated
into the Forest Services Soil and Water Conservation Handbook
under BMP 12.5. Forest roads kept open for public recreational
use after completion of timber harvest activities do not generally
qualify for this exemption."
K. "The Selected Alternative will require a Section 404
permit for roads kept open for public recreational use, for which
an application will be submitted."
L. "Executive Order 11990 (Wetlands) Executive Order 11990
requires Federal agencies to avoid, to the extent possible, the
long- and short-term adverse impacts associated with the destruction
or modification of wetlands. Because wetlands are so extensive
in the Gravina Island Timber Sale, it is not feasible to avoid
all wetland areas. Wetland soils not meeting Forest Plan criteria
for timber harvest suitability are excluded from the harvest
base. Soil moisture regimes and vegetation on some wetlands may
be altered in some harvest units; however, the affected wetlands
will meet wetland classification and will still function as wetlands
in the ecosystem. Road construction across wetlands is permitted
within Alaska. Such construction requires the filling-in of wetlands
and creates permanent loss of wetland habitat. Effects to wetlands
are minimized through the application of specific Best Management
Practices. Road construction through wetlands is avoided where
possible. See Chapter 3, Wetlands, for more extensive discussion
of the wetlands."
M. "U.S. Army Corps of Engineers Section 404 of the Clean
Water Act (1977, as amended) requires a permit from the Corps
of Engineers before filling or dredging in wetlands and tidelands.
A 404 permit will be needed for maintaining project roads as
open for public recreational use. Under an exemption, no 404
permits are needed for timber harvest that is conducted for silvicultural
3. One may also access a spreadsheet provided to the Army Corps
of Engineers that details roads to be built and their status
for recreational use. Of the 20.53 miles of roads slated for
construction - including the current Bostwick road - 15 out of
16 sections are slated to remain open for recreational use. The
portion meant to be closed is 1.03 miles. I encourage you to
contact the Forest Service and/or the Corps of Engineers for
a copy of this document.
4. In an email communication, the Army Corps of Engineers states,
"An examination of our files indicates that a permit has
never been issued for the discharge of fill for this road. Further,
no permit has been issued for fill resulting from the development
of the borrow pits. In evaluating this project, we examined our
available information, including the following: Gravina Island
Timber Sale Record of Decision [US Department of Agriculture,
Forest Service (USFS), Tongass National Forest, R10-M8-485a,
June 2004]; Final Environmental Impact Statement [R10-M8--485b
and c, June 2004 (FEIS)]; and a July 25, 2006, letter from Mr.
Gregory Staunton, Coastal Regional Resource Forester, Department
of Natural Resources, Division of Forestry (DOF) to Mr. Mike
Carney, Airport Manager, Ketchikan International Airport."
5. I also suggest reviewing the audio of Borough Assembly meetings
where the road is discussed in whole or in part. Meetings from
this fall and winter are most pertinent.
Please contact me with any further questions or thoughts.
Received March 12, 2007 - Published March 13, 2007
About: "Gregory is the
director of the Tongass Conservation Society and is a good friend
of Gravina Island."
Note: Comments published
on Viewpoints are the opinions of the writer
and do not necessarily reflect the opinions of Sitnews.
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