March 13, 2007
Tuesday AM

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 Gravina."

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.

1. http://www.fs.fed.us/r10/tongass/forest_facts/faqs/gravinaroads.shtml NOTE: This information was taken from the site by me and separately by the Corps of Engineers prior to its recent deletion by the Forest Service.

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."

2. http://www.fs.fed.us/r10/tongass/projects/decisions/gravina/2004rod.shtml

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 purposes."

H. "After completion of harvest, the 8100000 and 8105000 mainline roads (15.6 miles) would remain open to provide roaded recreational
opportunities."

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 access."

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 purposes."

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.

Gregory Vickrey
gregory[at]tongassconservation.org
Ketchikan, AK


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."

 

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