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On Haida Gwaii/Queen Charlotte Islands: Is the Population Continuing to Decline? Wildlife Dynamics Consulting

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On Haida Gwaii/Queen Charlotte Islands: Is the Population Continuing to Decline? Wildlife Dynamics Consulting IJ.H. Fl.'IQ A WILDUFI! 8ERUCE United States Department of the Interior U.S. FISH AND WILDLIFE SERVICE Anchorage Fish and Wildlife Conservation Office 4700 BLM Road ~ Anchorage, Alaska 99507-2546 IN REPLY REFER TO: FWS/AFES/AFWCO September 7, 2018 Mr. Earl Stewart Forest Supervisor, Tongass National Forest U.S. Forest Service 648 Mission Street Ketchikan, Alaska 99901 Subject: NOI EIS South Revillagegido Integrated Resource Project Dear Mr. Stewart: The U.S. Fish and Wildlife Service (USFWS) appreciates the opportunity to provide comments for the U.S. Forest Service's (Forest Service) Notice of Intent (NOi) to prepare an Environmental Impact Statement (EIS), issued August 9, 2018, for the Tongass National Forest, Ketchikan Misty Fjords Ranger District, South Revillagigedo Integrated Resource Project (South Revilla IRP). The purpose of the South Revilla IRP is to harvest timber, restore watershed function, enhance or restore fish and wildlife habitat, and develop recreation opportunities. The proposed action would harvest approximately 60 million board feet of timber from up to 6,000 acres over 15 years. Our comments focus on areas of resource concern and are based on our authorities under the Endangered Species Act (16 U.S.C. 1531-1544: ESA), Migratory Bird Treaty Act (16 U.S.C. 703-712), and the National Environmental Policy Act [(42 U.S.C. 4321-4347 1969, NEPA) with Implementing Regulations (40 CFR parts 1500-1508)]. The USFWS recommends the Forest Service evaluate the following issues in the EIS, and include actions in each of the alternatives to address these issues: • The EIS should evaluate the extent of past logging on all ownerships in the affected Value Comparison Units (VCUs), and the impacts of this management (including conversion to single-age young growth) in the context of cumulative effects of Federal and non-Federal actions on resources in the project area. Much of the project area and the surrounding non-Federal land has been previously logged, which has directly impacted habitat for fish and wildlife. Because the proposed action combined with other proposed land conveyance can further reduce the existing old growth reserves, the USFWS recommends the Forest Service initiate an interagency review, as described in Appendix K of the Tongass Land and Resource Management Plan (TLMP) (USDA 2016), to review the adequacy of old growth reserves into the future. • The EIS should evaluate potential impacts to species harvested by subsistence users (e.g., deer, wolves) for all alternatives. Roads constructed primarily to facilitate timber harvest in the project area have had limited traffic in the past since these roads are not connected to the communities Mr. Earl Stewart 2 (Ketchikan and Saxman) on Revillagigedo Island. As a result. hunters and trappers have primarily accessed the area by boat. and most subsistence and general season harvest activity has been near the marine shoreline. This is anticipated to change as increased access to the project area is provided through the Ketchikan to Shelter Cove connector road (USDA 2018), and the Ketchikan road system is connected to roads in the project area. This may bring additional harvest pressure on deer. wolves; and other species in the project area important to subsistence users. • The USFWS recommends maintaining deer habitat capability at or above 18 deer per square mile (using habitat capability model outputs) within the project area. to provide for both human and wolf harvests where deer are the primary prey of wolves, as specified in the TLMP. The USFWS also encourages enhancement of Sitka black-tailed deer habitat with young-growth management for a range of successional forest stages. Remnant stands of productive old growth forest. isolated by past timber harvest. should be retained when the stands provide the only remaining shelter from deep snow during winter. In cases where these remnant stands are removed, habitat management should account for the loss of this important sheltering habitat. Concepts and examples of habitat treatments to benefit deer are described in the Wolf Technical Committee's (2017) report, which is focused on nearby Prince of Wales Island but is also applicable to the South Revilla IRP area. A range of habitat treatments should be included as alternatives in the EIS. The USFWS remains available to help the Forest Service identify habitat improvement opportunities. • The USFWS recommends managing road densities within the project area according to Wolf Technical Committee (2017) recommendations to help ensure that wolf mortality does not reach unsustainable levels. Summarized here, these recommendations are to: o Maintain a road density no greater than 0.7 mile per square mile to help maintain sustainable harvest rates. o Develop an updated vehicle map and effectively close all roads currently administratively closed by omission from Motor Vehicle Use Maps. o Effectively close all "temporary roads" when the purpose of the roads are met. o Use interagency and public input when prioritizing roads for closure based on wildlife vulnerabilities in future access trail management or NEPA planning processes. • The USFWS recommends design criteria for stream crossings focus on protecting stream health by maintaining riparian and floodplain processes. Newly constructed crossings should promote natural sediment transport patterns. provide unaltered flu vial (riverine) debris movement. and maintain or restore functional continuity and connectivity of the stream-floodplain-riparian corridor. In areas within the project area where known fish passage barriers exist. improvements to crossings should provide for long-term dynamic channel stability, retention of existing spawning habitats, maintenance of food (benthic invertebrate) production, and minimization of risk of failure of the crossing. Stream crossing designs should be based on site-specific information such as estimates of peak discharge, flow velocities and patterns, channel stability, suspended sediment and bed load transport, flooding regime (50- to JOO-year flood frequency and magnitude). cross-section profiles of channel morphology, and water surface elevations. Placement of in-stream culverts within tidally influenced waterways should not restrict tidal range. In the interest of accommodating subsistence and public recreational opportunities, consider adding parking areas adjacent to major road intersections or where bridges span streams that support adult salmon. The Forest Service's stream crossing design standards incorporate these concepts. The USFWS hopes to continue our collaboration and to explore additional opportunities for advancing stream crossing design concepts. • The USFWS is currently considering a petition to list yellow-cedar (Cupressus nootkatensis; a valuable timber species in the project area) as threatened or endangered under the ESA. Review of Mr. Earl Stewart 3 the listing petition is not yet complete, but recent work suggests that regeneration of yellow-cedar may be compromised by herbivory (particularly by deer), competition from faster-growing species, or freezing injury (Hennon et. aJ. 2016). The USFWS recommends the Forest Service consider maintaining mature yellow-cedar as seed trees in units where herbivory, competition, or freeze injury could impact regenerating seedlings or saplings; delaying harvest of seed trees until successful recruitment of yellow-cedar to pole stage has been demonstrated; and designing timber harvests and second-growth treatments to conserve yellow-cedar. • The Queen Charlotte goshawk (Accipiter gentilis laingi), found on the Tongass National Forest, is considered a sensitive species. In 2012, the USFWS listed the British Columbia Distinct Population Segment of the Queen Charlotte goshawk, found in adjacent coastal British Columbia, as "threatened" under the ESA due largely to concerns over timber harvest. This listing is consistent with the "threatened" status of the Queen Charlotte goshawk under Canada's Species at Risk Act. The USFWS recommends the Forest Service evaluate cumulative effects on goshawk nesting habitat in the project area from logging activity, and consider how implementation of proposed project alternatives would affect nesting habitat into the future. Doyle (2005) found that successful nesting territories on nearby Queen Charlotte Islands (also known as Haida Gwaii) had a minimum of 41 to 60 percent of the landscape in mature or old growth forest. Doyle and Holt (2005) used these thresholds to model habitat capability across Haida Gwaii. The USFWS recommends the Forest Service use similar analyses to evaluate potential impacts to goshawk nesting habitat in the project area. For convenience, please find enclosed a copy of Doyle (2005) and Doyle and Hoyt (2005) with this letter. The USFWS recommends actions to address our concerns be included in the EIS, the selected alternative, and fully described in the Record of Decision. Such actions will help sustain sensitive wildlife important for subsistence use, and ecological function on a landscape that continues to provide a range of forest products and services. The USFWS appreciates our continued collaboration with the Forest Service, and looks forward to working with you as the South Revilla IRP is developed. If you have any questions, please contact Mr. Kevin Foley at (907) 271-2788, or [email protected]. Sincerely, Stewart Cogswell Field Supervisor Enclosures Literature Cited Doyle, F.I. 2005. Breeding success of the goshawk (A. g. laingi) on Haida Gwaii/Queen
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