Eleven messages by Dave Person and others at ADF&G about the Big Thorne Project, Feb. 28 to April 18, 2011, in order first to last (Source: 3rd ADF&G APRA response at pp. 3-6, 28, 40-42, 491 and 492) From: Person, David K (DFG) Sent: Mon 2/28/2011 1:44 PM To: Porter, Boyd (DFG); Flynn, Rodney W (DFG); Moselle, Kyle W (DFG); Barten, Neil L (DFG); Larsen, Douglas N (DFG); Bethune, Stephen W (DFG) Subject: Big Thorne Hi All, The Big Thorne timber sale likely will have consequences for the future viability of the watersheds involved to sustain wolves and deer. It also will contribute to the long-term loss of deer hunting opportunities. I attached 3 maps showing deer winter range prior to industrial timber harvest, the situation by 2008, and what will remain after Big Thorne if all units are included. In particular, the Thorne River and Steelhead Creek watersheds that I highlight in the maps will be severely affected by the sale. There are simply no methods of mitigation that will compensate for that much loss of winter habitat. In the Thorne watershed, most of the productive forest below 245m was logged over the last 25 years. Much of it was pre-commercially thinned, which only provides about a 3-7 year boost in understory forage for deer compared with unthinned stands (see attached paper by Liz Cole). Even so, much of that forage is unavailable because of slash, which also may increase risk of death of neonate fawns (see Farmer et al. 2006). Indeed, during my current study of fawn mortality, most of our neonates collared within the proximity of precommercially thinned stands died from bear predation within or adjacent to that habitat. The Big Thorne sale goes further to remove the most important winter habitat for migratory deer in the watershed. Migratory deer generally over winter higher than resident deer unless pushed downward by deep snow. Many of the productive stands to be removed are situated above older clearcuts and are locally known for supporting deer during normal winters. Alpine and sub-alpine habitat is easily accessible to hunters in the watershed and many choose to hunt those areas because of abundant migratory deer. Loss of normal winter range likely will reduce that abundance. Steelhead Creek, is another area hard hit by the sale. Todd Brinkman reported that deer were currently abundant within the watershed and that they fared well during 3 consecutive severe winters compared to deer within the Maybeso and Staney drainages he studied. Their survival was enhanced by the availability of low elevation winter range, much of which will be removed by the sale. Steelhead Creek is also a major subsistence hunting area and still appears to have a healthy population of bears. The Big Thorne sale will result in entries for the third time within the North Thorne, Big Lake, Luck Lake, and Gravelly Creek drainages. The windowed image in my maps encompassed 30,124 ha of winter range in 1954, which was reduced to 14,964 ha by 2008. Much came from the private and state lands within the mapped area but as the maps show, much also came from the federal lands involved in the BT sale. Cumulative loss of productive forest habitat in those areas causes me to question the viability of those watersheds to maintain ecological functions and support a healthy predator-prey community. Wolf viability depends not only on reducing road density and risk of unsustainable harvest but also on abundant populations of deer. I doubt that a resilient and persistent wolf-beardeer-human predator-prey system will be possible within the watersheds affected after the project is completed, if indeed it is still possible as current conditions progress inexorably toward stem exclusion. Current risks of unsustainable wolf harvest will be exacerbated by 01824 Meters 14000 North and East Thorne River 14 To.'" .tb 4 g; 6- o o Steelhead Creek Figure 1. Deer winter range (volume classes 5-7 on all but north facing aspects below 245m) in 1954. Lakes are blue, roads are red, and winter range is green 01825 Meters 10000 North and East Thorne River Figure 2. Deer winter range (volume classes 5-7 on all but north facing aspects below 245m) in 2008. Lakes are blue, roads are red. and winter range is green 01826 Meters 10000 North and East Thorne River Steelhead Creek Figure 3. Deer winter range (volume classes 5-7 on all but north facing aspects below 245m) after Big Thorne project if all harvest units are included. Lakes are blue, roads are red, and winter range is green the project as deer become fewer in stem excluded forest and hunters blame wolves and bears for the lack of available deer. The legacy standard as written is of little value for protecting that ecological function. Basically, if there were only 3 old-growth trees left, the standard allows you to cut 2 of them. There is no lower limit below which no timber harvest is allowed. Finally, for now, the sale will impact 5 wolf denning areas (Trumpeter Lake, Big Lake, 3018 Long Lake, Angel Lake, and Upper Steelhead). With the exception of Upper Steelhead, each of those areas was used multiple times by wolves between 1993-2007. It is difficult to recommend any scoping changes other than simply to reconsider the whole sale because it will remove most of the best remaining old-growth in every watershed touched by the project. We are simply going to engage is a game of triage in which we recommend watersheds for which we hope to save some minimum level of wildlife viability and sacrifice the others. Dave ________________________________________________________ From: Sent: To: Cc: Moselle, Kyle W (DFG) Tuesday, March 01, 2011 10:21 AM Person, David K (DFG) Porter, Boyd (DFG); Flynn, Rodney W (DFG); Barten, Neil L (DFG); Larsen, Douglas N (DFG); Bethune, Stephen W (DFG); Timothy, Jackie L (DFG) Subject: RE: Big Thorne Thanks Dave. It looks like the roads in the 3 attached maps all use the current roads layer. So the roads shown in the 1954 winter habitat map are not the existing roads in 1954. Is that correct? No changes are necessary, I just need to know. Much of your input will be valuable for our comments regarding the cumulative effects analysis in the DEIS. Loss of low elevation deer winter habitat is an interesting issue, but a tough one to effectively comment on in a manner that drives development of an alternative in the DEIS. The management assumption of TLMP is that adequate low elevation deer winter habitat exists in non-development LUDs within and adjacent to the project area to maintain wildlife populations associated with those habitats. We will not get the forest service to avoid all deer winter habitat that exists in Timber LUDs. However, one of the goals of NEPA is to fully describe the effects to the human environment from the proposed action, so the FS needs to detail the impacts to deer winter habitat, and your comments will help with that. Do you have wolf den location data? That would be great data to share with the FS. Stephen attended the public meeting last night in Thorne Bay and we talked about the possibility of providing bear denning locations as well. Those locations would not be included in the DEIS (because we wouldn't want them publicly known), but the FS could develop an alternative action based on those data and our recommendations. The goal of this, or any timber sale, is to provide fiber to the timber industry. However, like us, the FS is a multiple use management agency, so they have to account for other users of the resources for which they are responsible for managing. There are going to be watersheds that see a significant amount of timber harvest, but that focused harvest is a result of avoiding harvest in other areas such as OGRs and other non-development LUDs. This project even goes further and avoids 2001 roadless areas regardless of their LUD status, which increases the harvest even further on the roaded land base. So our concern over loss of POG or other important habitats in Timber LUDs must be tempered by the fact that many other areas containing those same habitat types are being protected from development actions. This is not to say that we cannot address a specific fish or wildlife concern that occurs in the project area or even Timber LUD. For example, buffering or avoiding a wolf or den site, or avoiding harvest in a known important wildlife migration route. 2 I appreciate your input Dave. Please let me know if you can provide wolf denning locations. Also, it is imperative that you get me your wolf mortality risk analysis as soon as possible so we have some time to advise the FS and the contractors working on the NEPA for Big Thorne. Take care, Kyle ___________________________________________________________ From: Sent: To: Cc: Person, David K (DFG) Wednesday, March 02, 2011 3:14 PM [ March 2, 2011 ] Moselle, Kyle W (DFG) Porter, Boyd (DFG); Flynn, Rodney W (DFG); Barten, Neil L (DFG); Larsen, Douglas N (DFG); Bethune, Stephen W (DFG); Timothy, Jackie L (DFG); Titus, Kimberly (DFG) Subject: RE: Big Thorne Hi Kyle, Thanks for the note. The current roads on my map for conditions in 1954 are there for reference so you can easily compare the historical condition to current conditions. Attached is a map showing den locations within the project area. The Big Lake, Trumpeter Lake, and 3018 Lake dens are used by the Thorne Bay-Ratz Harbor pack. The Angel Lake denning area is approximate because we did not find the actual den but documented denning activity (tracks, scats, and rendezvous areas) within close proximity of the location shown. That den area was used twice by the Rio Roberts-Goose Creek pack. The Steelhead den was used once because the newly formed breeding pair were killed during the summer. Turnover of wolves in that area is very high because of the roads and accessibility to hunters and trappers. The Rio Roberts pack and Thorne Bay group are also harvested very heavily. With respect to deer, TLMP does not assume that adequate habitat is maintained only in nondevelopment lands. There is the wolf guideline specifying a minimum deer habitat capability of 18 deer/mi2. The intent of the conservation strategy in TLMP was to create an integrated system of features that included reserves, areas deferred from logging, and standards and guidelines for management of the matrix. I attached a copy of a paper by Jerry Franklin and Dave Lindenmayer on conservation strategies. They discuss why reliance on habitat reserves is often a recipe for failure and that the matrix of managed lands between reserves is critical to successful conservation. I attached 2 papers by Winston Smith and me (plus Sanjay Pyare) on flying squirrels and small OGRs that test some assumptions of the conservation strategy in TLMP and reinforce the conclusions of Franklin and Lindenmayer. The second paper with Smith and Pyare is a chapter in a book about sources and sinks to be published this year. It is in press at Cambridge University Press. Continuing on with nondevelopment lands within the matrix, deer avoid habitats along streams and lakes during winters with deep snow (>50cm, brisket height). That includes productive old-growth stands that constitute stream buffers. Attached is table 8 from my deer monograph showing habitat selection results from >100 yearling and adult does on Heceta, POW, and Mitkof Islands. Two candidate models are shown, with model 1 fitting the data best (w=0.633 vs 0.367). The coefficients (Betas) indicate that deer select open- and coarse-canopy old growth (ocog. crsog) at low elevations and on southing slopes. They tend to select locations closer to roads (distrd), however, that may simply be coincidental with selecting low elevations, where roads tend to be. They select locations away from lakes and streams (distl&s). They avoid ravines (where streams flow), ridges (higher elevations), and large patches of habitats with open canopies and sparse understories (patch4) such as muskegs, unproductive forest, frozen lakes and streams, and road surfaces. When snow is deep, they also avoid locations with high forest canopy contrast (e.g.; areas with many forest openings). Deer likely avoid riparian buffers during winters because being in proximity of a 3 lake or stream edge strongly increases the risk of predation by wolves. Consequently, nondevelopment lands associated with stream and riparian buffers are not going to contribute to winter habitat capability. Therefore, within timber production lands, that means only small OGRs, legacy trees (stands, patches, whatever they really end up being?), and beach buffers (only useful to deer adjacent to them), will constitute all of the winter deer habitat left. As part of scoping, we should ask the USFS to provide some maps showing reserves and nondevelopment lands within the affected watersheds. We need to pay attention to what lands are left and where they are. Do they provide vertical connectivity for migratory deer during winters with snow and sufficient low elevation habitat to prevent losses of deer like we observed in the Maybeso during winters 2006-2008? Several of the watersheds in the Big Thorne project currently are extremely popular hunting areas (North Thorne, Steelhead, No-name Creek). What losses to hunting opportunities will occur over the long term as the carrying capacity of the watersheds for deer diminishes? Is there any coordination between the project and meeting subsistence needs? For example, will the USFS maintain sufficient habitat capability on lands available to hunters after road closures occur? I am not advocating keeping roads open that are slated for closing, but wonder if the USFS has given any thought to managing those lands that are easily accessible to subsistence hunters in such a way that deer habitat capability is maintained at a high level? Take care, dave ________________________________________________________ From: Moselle, Kyle W (DFG) Date: Thursday, March 10, 2011 To: Lenhart, Thomas E (LAW) Subject: CONFIDENTIAL - draft wolf language CONFIDENTIAL ATTORNEY CLIENT PRIVILEGE; ATTOENRY WORK PRODUCT Hey Tom, Hope your vacation was successful :) I would like for you to help me our Big Thorne timber sale scoping comments related to wolves. << Redacted >> << Redacted >> << Redacted >> Let me know your thoughts next week after you return to the office. Thanks! Take care, Kyle Moselle ________________________________________________________ From: Clark, Clarence R (DNR) Date: Wednesday, March 16, 2011 1:36:00 PM To: Fogels, Edmund J (DNR); Moselle, Kyle W (DFG); Hanley, Kevin J (DEC); Bohan, Carrie D (DNR); Lenhart, Thomas E (LAW); Katz, John W (GOV) Cc: Balash, Joseph R (DNR); Curran, Michael J (DNR); Dense, Chas A (DNR); Flynn, Rodney W (DFG); Gibert, Sally (DNR); Hughes, Andrew N (DOT); Kelley, David L (DNR); Robbins, Mark K (GOV); Ruaro, Randall P (GOV); Strandberg, Jim (AIDEA); Warner, Douglas R (DNR); brain.frenette@alaska.gov; Larsen, Douglas N (DFG); Levi, Andrew T (DFG); Magee, Susan E (DNR); Mendivil, Gary A (DEC) Subject: Draft - Big Thorne Scoping comments 4 Attachments: DRAFT internal scoping comments - deliberative process 3-16-11.docx INTERNAL DELIBERATIVE PROCESS Greetings, Attached are draft scoping comments for the USFS Big Thorne timber sale project. Please review and send comments to either Kyle Moselle (kyle.moselle@alaska.gov) or myself. Please have your comments to us no later than Friday 3-18-11. Thanks to everyone for your help on this project. Clarence Clark << 13 following pages were redacted. >> ________________________________________________________ From: Person, David K (DFG) Sent: Friday, April 15, 2011 1:43 PM To: Moselle, Kyle W (DFG) Cc: Flynn, Rodney W (DFG); Larsen, Douglas N (DFG); Barten, Neil L (DFG) Subject: wolf dens Hi Kyle, Attached are some powerpoint slides showing wolf dens in the Big Thorne project area. The circles are 1200ft buffers. Is how 1200ft circles around suspected den sites at Angel lake. We know they denned there several times but we never found the actual natal dens. You should be able to compare the buffers with your maps of the proposed unit pool to see which units might fall within the buffers. Frankly, the den buffer guideline is not one that I worry much about. It is not based on my or anyone's work with wolves and is just a timing restriction. Its value is pretty limited because the area gets cut eventually. Wolves generally avoid logged stands and high levels of disturbance when selecting den sites but after they are actively denning, they will tolerate quite a bit of noise and human disturbance. Road density and deer habitat are much more important for wolf viability than the wolf den guideline. I did not respond to your last e-mail about deer habitat in the BT project because I was too busy. However, I want to make one point very clear. The Tongass Land Management Plan may or may not be adequate for protecting ecosystem functions and species viability. We simply don't know. It was based on some, not all, but some of the best science available in 1996. "Based on the best science available" does not mean the science was adequate. It is also a plan that many in the USFS only tolerated after doing everything possible to see that it never saw the light of day. Anyway, as a professional biologist who knows this ecosystem as well as anybody working here, who has worked in that system doing research on that system for almost 20 years, I would hope that my comments and concerns about a proposed project will be transmitted up the ladder regardless of whether they specifically relate to a TLMP S&G. Those S&Gs only address a fraction of the ecological problems associated with industrial-scale timber harvesting of northern Pacific rainforests. dave ________________________________________________________ 5 From: Moselle, Kyle W (DFG) Date: Friday, April 15, 2011 2:37:00 PM To: Timothy, Jackie L (DFG) Subject: FW: wolf dens Attachments: Wolf Dens.ppt FYI Take care, Kyle Moselle Tongass Coordinator ADF&G, Division of Habitat ___________ [ Person's above April 15, 2011 at 1:43 PM message was appended here. ] ________________________________________________________ From: Timothy, Jackie L (DFG) Sent: Friday, April 15, 2011 3:15 PM To: Larsen, Douglas N (DFG) Cc: Timothy, Jackie L (DFG) Subject: RE: wolf dens [ The message is unresponsive to to Person's concerns, but is included here as part of the chain. ] Hi Doug - I see in your email dated March 8, 2011 that you informed your staff you supported getting appropriate maps from the USFS so we could evaluate wolf den locations and accommodate den buffers. Tetra Tech provided us with shape files of the proposed action about three weeks ago. This afternoon, Dave Persons provided Powerpoint slides with circles showing wolf den buffers. However, the slides do not include legends, scale, or identifying information. Will you please ask Dave to provide us the lat and long for each wolf den location immediately so that we can assist the USFS in implementing the wildlife conservation measures? We will use the information to provide the USFS with specific locations that need to be excluded from the units to meet the 1200 wolf buffer S&G without divulging the location of the dens. We need to finalize our maps on the 25th before Kyle heads to the meeting with Tetra Tech and the USFS on April 26. Thanks. . .Jackie ________________________________________________________ From: Larsen, Douglas N (DFG) Sent: Mon 4/18/2011 8:17 AM To: Person, David K (DFG) Subject: FW: wolf dens Dave - I'd appreciate your help with getting Jackie and Kyle the lat/longs for the wolf den locations. 6 This appears to be information that could prove useful in protecting these important sites. Please note the April 25 date noted in Jackie's email. Your assistance with this will be much appreciated. Thanks! Doug Larsen, Regional Supervisor Region I - Southeast Alaska Alaska Department of Fish and Game Division of Wildlife Conservation ________________________________________________________ From: Person, David K (DFG) Sent: Monday, April 18, 2011 10:45 AM To: Larsen, Douglas N (DFG) Subject: RE: wolf dens Hi Doug, The images I sent had enough information including the lake names and roads to identify where the dens were and 1200 foot buffers. Anyway, here are the den lat longs using decimal minutes and WGS84 as the datum: << Information redacted by ADF&G >> << Information redacted by ADF&G >>. As I said to Kyle in my e-mail, the wolf den timing restriction is not particularly important for wolf conservation because it is only a timing restriction. They end up cutting the area anyway, just not during May and June. Road density and deer habitat are the major issues with Big Thorne. Dave _______________________________________________________ From: Larsen. Douglas IV (DFG) Date: Monday, April 18, 2011 10:51:28 AM To: Person. David K (DFG) Cc: Flynn. Rodney W [DFG) Subject: RE: wolf dens Thanks Dave, this is appreciated. I also understand and appreciate your observations about timing, roads, and cutting. We'll want to continually put those points forward. I hope your field work goes down. Please let me know how I can assist with the truck and float house. I'm prepared to do what I can, once I understand what's needed from me. Thanks! Doug Larsen, Regional Supervisor Region I - Southeast Alaska Alaska Department of Fish and Game Division of Wildlife Conservation 7 Woeck, Brita From: Sent: To: Subject: Moselle, Kyle W (DFG) Thursday, April 28, 2011 11:32 AM Woeck, Brita FW: Thinning for wildlife benefits (ADF&G thoughts) oops!, I had a typo in your emails address. :-) -----Original Message----From: Moselle, Kyle W (DFG) Sent: Thu 4/28/2011 10:31 AM To: mdillman@fs.fed.us; brita.woeck@tretratech.com Cc: jjkelley@fs.fed.us; randy.fairbanks@tetratech.com Subject: FW: Thinning for wildlife benefits (ADF&G thoughts) Marla and Brita, Below are some recommended prescriptions from Dave Person related to thinning activities on the Tongass, which he provided to me back in 2009. Although they apply to PCT and commercial thinning, I think the concepts in points 6, 7, and 8 translate well to original harvest as well. Let me know if you have any questions. Take care, Kyle **Provided by Dave Person** The key problems with many (not all) USFS thinning projects are as follows: 1. Most (not all) are ad hoc and do not include real or consistent measures to monitor the effects on vegetation and animal use or abundance. 2. Most projects are very badly documented such that it is very difficult to revisit the sites years later to determine long-term effects and evaluate the treatments. 3. None of the projects of which I am aware deal with the amount, density, and distribution of treatments. As I remarked to you and the Forest Service, with respect to wildlife effects, the amount and distribution of treatments is as important or more so than the actual treatment. Here are some potential solutions: 1. Each project should be tied to a monitoring program that examines changes in understory vegetation and animal use over time. Track surveys, camera surveys, DNA population estimation, radio telemetry, etc should all be considered as tools for evaluating effects of treatments. 2. Each project for wildlife should involve a wildlife biologist at the decision making level and clear distinction made that a project is for wildlife restoration versus fiber production. 3. Each project should involve a landscape ecologist who can evaluate the treatments with respect to landscape context, distribution, and density. That person should be able to model the landscape over time to predict patterns of change caused by forest succession that will affect wildlife. 4. With respect to deer, they like edge. Consequently, no watershed should be subjected to large-scale single treatments. Acres and acres of pre-commercially thinned stands will not benefit deer very much and actually removes useable habitat over the shortterm. Over the long-term, only a fraction of whatever understory vegetation is sustained or restored will actually be used by deer unless the patch size is small and it is adjacent to habitat that deer can move through. 5. As a start, there should be corridors for travel every 30-50m within pre-commercially thinned stands. Those corridors should be made perpendicular and parallel to the accessing roads to create a rough grid-like pattern of corridors. Pellet and browse surveys could be used to determine how much of the treated stand is actually being used over time. 6. Again with respect to deer - in areas where wolves occur, treatments on slopes <9 degrees involving commercial thinning should be done at small scales and only light selection harvest or small patch cuts (0.5-1 acre as a start) should be consider if the project is to benefit deer. As slope increases beyond 9 degrees, treatment patch size can increase to small clearcuts or cleared strips (10-25 acres) interspersed with untreated or selectively thinned stands. South facing slopes should be given priority for treatment that is meant to enhance deer habitat. In fact, ranked priority for treatment should be south aspect (1), east or west (2), and north (3). 7. In areas where wolves do not occur but winter weather may be severe (GMU 4), a similar strategy for commercial thinning may 1 also be appropriate because south facing slopes will melt off faster, allowing deer to use openings and edges more effectively. Thus, coarser scale patches or clearcuts would probably work on slopes >9 degrees. However, the flatter land must contain habitat that deer can use in winters with snow. That requires trees for snow interception and small openings for forage production distributed at a fine scale so all of those resources are available to deer without them having to move very far. The strategy is this, during the peek snow period, deer will be confined to the low elevation winter range, but as melt begins in March or April, they can move up quickly and exploit open patches, clearcuts, and strips on south facing slopes. 8. Where alpine habitat is connected to a watershed, there must be corridors of travel connecting the valley bottom to the alpine. Those corridors should be old-growth strips but if none exist then untreated stem exclusion seral forest will suffice because deer can move through it easily and it will intercept snow. 2 Appendix Because preceding pages being a compiled, uniformly reformatted, and chronologically sorted rendition done by us, the messages as we originally received them are attached. These records were received through a public records request. 01822 From: To: Subject: Date: Attachments: Person, David K (DFG) Porter, Boyd (DFG); Flynn, Rodney W (DFG); Moselle, Kyle W (DFG); Barten, Neil L (DFG); Larsen, Douglas N (DFG); Bethune, Stephen W (DFG) Big Thorne Monday, February 28, 2011 1:44:00 PM Big Thorne Maps.ppt Cole et al. 2010.CJFR.Influence of precommercial thinning.pdf Farmer et a.l 2006.pdf Hi All, The Big Thorne timber sale likely will Deliberative Process I 01823 Dave 01824 Meters 14000 North and East Thorne River 14 To.'" .tb 4 g; 6- o o Steelhead Creek Figure 1. Deer winter range (volume classes 5-7 on all but north facing aspects below 245m) in 1954. Lakes are blue, roads are red, and winter range is green 01825 Meters 10000 North and East Thorne River Figure 2. Deer winter range (volume classes 5-7 on all but north facing aspects below 245m) in 2008. Lakes are blue, roads are red. and winter range is green 01826 Meters 10000 North and East Thorne River Steelhead Creek Figure 3. Deer winter range (volume classes 5-7 on all but north facing aspects below 245m) after Big Thorne project if all harvest units are included. Lakes are blue, roads are red, and winter range is green 01827 ecurity settings or invalid file format do not permit using Cole et al. 2010.CJFR.Influence of precommerci_1.pdf (343100 Bytes 01828 Research Article Risk Factors and Mortality of Black-Tailed Deer in a Managed Forest Landscape CHRISTOPHER J. FARMER,1,2 Department of Environmental and Forest Biology, State University of New York, College of Environmental Science and Forestry, Syracuse, NY 13210, USA DAVID K. PERSON, Division of Wildlife Conservation, Alaska Department of Fish & Game, Ketchikan, AK 99901, USA R. TERRY BOWYER, Department of Biological Sciences, Idaho State University, Pocatello, ID 83209, USA Abstract We investigated the influence of habitat use on the risk of death of Sitka black tailed deer (Odocoileus hemionus sitkensis) on Heceta Island in Southeast Alaska, USA. A mosaic of even and uneven aged forests covered much of the island and provided a model setting in which to assess relationships between habitat use and mortality of deer. We radiocollared and monitored 51 adult females, 11 adult males, and 19 young of the year. We compared risk of death with habitat composition, habitat distribution, topography, distances to features such as roads, and functional habitat characteristics such as seasonal forage biomass within 50 , 500 , and 1,000 m circular buffers around relocations of deer. Those buffers encompassed habitats used at scales of radio locations, home ranges, and landscapes. We addressed hypotheses that related habitat composition and distribution to risk of death from malnutrition, predation, and hunting. Predation by wolves (Canis lupus) and malnutrition were the principal causes of death of adult females and young, whereas hunters killed most adult males. Habitat factors at scales of 500 and 1,000 m had the greatest effect on mortality of adult females and young, whereas habitat characteristics in the immediate vicinity of radio relocations had the greatest effect on mortality of adult males. Malnutrition was positively associated with use of forage poor habitats such as pole stage, second growth forest. Use of precommercially thinned second growth increased risk of death for young deer. Use of level terrain was the most influential factor with respect to predation and increased risk of death at all scales. Use of open habitats, such as muskegs and young clearcuts, also increased risk of death. Use of shrub sapling stage clearcuts in landscapes accessible by roads increased risk of death from hunting. We showed that use of specific habitats and the landscape context of those habitats were important factors influencing mortality of deer. We also demonstrated the importance of comparing habitat use with measures of fitness rather than simply with availability when evaluating habitat suitability for deer. Our results should be useful to wildlife researchers investigating contributions of habitat to fitness and population dynamics of ungulates, and to wildlife managers attempting to manipulate habitats to benefit deer populations. (JOURNAL OF WILDLIFE MANAGEMENT 70(5):1403 1415; 2006) Key words black-tailed deer, Cox proportional hazards, forest management, habitat use, mortality, Odocoileus hemionus, risk ratios. Sitka black-tailed deer (Odocoileus hemionus sitkensis) are the most abundant and widely distributed ungulates in temperate rainforests of Southeast Alaska, USA (MacDonald and Cook 1996). Although much is known about habitat use (Wallmo and Schoen 1980, Schoen and Kirchhoff 1990, Yeo and Peek 1992, Doerr et al. 2005) and foraging ecology (Hanley and Rogers 1989, Parker et al. 1999) of those deer, researchers have not conducted studies to examine relationships between habitat use and risk factors such as malnutrition, predation, and hunting that affect survivorship, nor have they examined those relationships at multiple scales and among sex and age classes. McNay and Voller (1995) estimated survivorship and cause-specific sources of mortality of female Columbia black-tailed deer (O. h. columbianus) on Vancouver Island, Canada, and Klein and Olson (1960) described sources of mortality of Sitka blacktailed deer in Southeast Alaska. Nonetheless, neither of those studies related habitat use to mortality. In addition, there have been few studies published concerning effects of large-scale industrial activity, such as timber harvest, on risk factors for deer. 1 E-mail: farmer@hawkmtn.org Present address: Hawk Mountain Sanctuary, Acopian Center for Conservation Learning, Orwigsburg, PA 17961, USA 2 Farmer et al.  Risk Factors and Mortality of Deer Researchers believe causes of death related to severe winter weather to be the primary sources of mortality of deer in Southeast Alaska (Klein and Olson 1960, Klein 1965, Wallmo and Schoen 1980), particularly where snow depth exceeds 50 cm (Hanley and Rogers 1989). In those areas, deer strongly select productive old-growth forest on southern exposures below 250 m elevation in winter (Wallmo and Schoen 1980, Schoen et al. 1988, Schoen and Kirchhoff 1990). Timber harvest has increased fragmentation of forest habitat, creating many small, remnant stands of old-growth forest within a matrix of younger second-growth forest. Fragmentation may reduce the value of forests as winter habitat by forcing deer to remain in small patches of timber isolated by snow (McNay 1995). Over-browsing of forage may occur in those stands because deer may have difficulty moving between patches, effectively reducing carrying capacity (K) in winter. Thus, landscape context likely influences availability of forage, and possibly mortality of deer (Kie et al. 2005). In areas of lower snow accumulation, the importance of productive old-growth habitat for survivorship of deer may be more ambiguous. In the absence of snow, fat accumulated from foraging on high-quality summer and autumn ranges may enable cervids to survive, regardless of the quality of winter habitat (Kie et al. 2003, Stewart et al. 2005). 1403 federal agency to conduct research on a fish or wildlife population, or if the requestor has been the department to perform specific activities and agrees to use the records and information only for purposes as provided under a contract or agreement with the department. After 25 years, the records and information that are kept confidential under this subsection become public records subject to inspection and copying under AS 40.25.1 10 - 40.25. 140 unless the department determines that the release of the records or information may be detrimental to the fish or wildlife population. In this subsection, "personal information" has the meaning given in AS 40.25.350 . From: Person, David (DFG) Sent: Wednesday, March 02, 2011 3:14 PM To: Moselle, Kyle (DFG) Cc: Porter, Boyd Rodney Barten, Neil Larsen, Douglas Bethune, Stephen Timothy, Jackie Titus, Kimberly (DFG) Subject: RE: Big Thome Hi Kyle, Thanks for the note. The current roads on my map for conditions in 1954 are there for reference so you can easily compare the historical condition to current conditions. Attached is a map showing den locations within the project area. The Big Lake, Trumpeter Lake, and 3018 Lake dens are used by the Thome Bay-Ratz Harbor pack. The Angel Lake denning area is approximate because we did not find the actual den but documented denning activity (tracks, seats, and rendezvous areas) within close proximity of the location shown. That den area was used twice by the Rio Roberts- Goose Creek pack. The Steelhead den was used once because the newly formed breeding pair were killed during the summer. Turnover of wolves in that area is very high because of the roads and accessibility to hunters and trappers. The Rio Roberts pack and Thorne Bay group are also harvested very heavily. With respect to deer, TLMP does not assume that adequate habitat is maintained only in nondevelopment lands. There is the wolf guideline specifying a minimum deer habitat capability of 18 deer/mi2. The intent of the conservation strategy in TLMP was to create an integrated system of features that included reserves, areas deferred from logging, and standards and guidelines for management of the matrix. I attached a copy of a paper by Jerry Franklin and Dave Lindenmayer on conservation strategies. They discuss why reliance on habitat reserves is often a recipe for failure and that the matrix of managed lands between reserves is critical to successful conservation. I attached 2 papers by Winston Smith and me (plus Sanjay Pyare) on flying squirrels and small OGRs that test some assumptions of the conservation strategy in TLMP and reinforce the conclusions of Franklin and Lindenmayer. The second paper with Smith and Pyare is a chapter in a book about sources and sinks to be published this year. It is in press at Cambridge University Press. Continuing on with nondevelopment lands within the matrix, deer avoid habitats along streams and lakes during winters with deep snow (>50cm, brisket height). That includes productive old- growth stands that constitute stream buffers. Attached is table 8 from my deer monograph showing habitat selection results from >100 yearling and adult does on Heceta, POW, and Mitkof Islands. Two candidate models are shown, with model 1 fitting the data best (w=0.633 vs 0.367). The coefficients (Betas) indicate that deer select open- and coarse-canopy old growth (ocog. crsog) at low elevations and on southing slopes. They tend to select locations closer to roads (distrd), however, that may simply be coincidental with selecting low elevations, where roads tend to be. They select locations away from lakes and streams (distl&s). They avoid ravines (where streams flow), ridges (higher elevations), and large patches of habitats with open canopies and sparse understories (patch4) such as muskegs, unproductive forest, frozen lakes and streams, and road surfaces. When snow is deep, they also avoid locations with high forest canopy contrast g; areas with many forest openings). Deer likely avoid riparian buffers during winters because being in proximity of a lake or stream edge strongly increases the risk of predation by wolves. Consequently, nondevelopment lands 3:59:41 associated with stream and riparian buffers are not going to contribute to winter habitat capability. TiQ:l:le'i'olre, within timber production lands, that means only small OGRS, legacy trees (stands, patches, whatever they really end up being?), and beach buffers (only useful to deer adjacent to them), will constitute all of the winter deer habitat left. As part of scoping, we should ask the USFS to provide some maps showing reserves and nondevelopment lands within the affected watersheds. We need to pay attention to what lands are left and where they are. Do they provide vertical connectivity for migratory deer during winters with snow and sufficient low elevation habitat to prevent losses of deer like we observed in the Maybeso during winters 2006-2008? Several of the watersheds in the Big Thorne project currently are extremely popular hunting areas (North Thorne, Steelhead, No-name Creek). What losses to hunting opportunities will occur over the long term as the carrying capacity of the watersheds for deer diminishes? Is there any coordination between the project and meeting subsistence needs? For example, will the USFS maintain sufficient habitat capability on lands available to hunters after road closures occur? I am not advocating keeping roads open that are slated for closing, but wonder if the USFS has given any thought to managing those lands that are easily accessible to subsistence hunters in such a way that deer habitat capability is maintained at a high level? Take care, dave From: Moselle, Kyle (DFG) Sent: Tuesday, March 01, 2011 10:21 AM To: Person, David (DFG) Cc: Porter, Boyd Rodney Barten, Neil Larsen, Douglas Bethune, Stephen Timothy, Jackie (DF G) Subject: RE: Big Thome Thanks Dave. It looks like the roads in the 3 attached maps all use the current roads layer. So the roads shown in the 1954 winter habitat map are not the existing roads in 1954. Is that correct? No changes are necessary, I just need to know. Much of your input will be valuable for our comments regarding the cumulative effects analysis in the DEIS. Loss of low elevation deer winter habitat is an interesting issue, but a tough one to effectively comment on in a manner that drives development of an alternative in the DEIS. The management assumption of TLMP is that adequate low elevation deer winter habitat exists in non-development LUDS within and adjacent to the project area to maintain wildlife populations associated with those habitats. We will not get the forest service to avoid all deer winter habitat that exists in Timber LUDs. However, one of the goals of NEPA is to fully describe the effects to the human environment from the proposed action, so the FS needs to detail the impacts to deer winter habitat, and your comments will help with that. 3:59:41 00042 Do you have wolf den location data? That would be great data to share with the FS. Stephen attended the public meeting last night in Thome Bay and We talked about the possibility of providing bear denning locations as well. Those locations would not be included in the DEIS (because we wouldn't want them publicly known), but the could develop an alternative action based on those data and our recommendations. The goal of this, or any timber sale, is to provide fiber to the timber industry. However, like us, the FS is a multiple use management agency, so they have to account for other users of the resources for which they are responsible for managing. There are going to be watersheds that see a significant amount of timber harvest, but that focused harvest is a result of avoiding harvest in other areas such as OGRs and other non-development LUDs. This project even goes further and avoids 2001 roadless areas regardless of their LUD status, which increases the harvest even further on the roaded land base. So our concem over loss of POG or other important habitats in Timber LUDs must be tempered by the fact that many other areas containing those same habitat types are being protected from development actions. This is not to say that we cannot address a specific fish or wildlife concem that occurs in the project area or even Timber LUD. For example, buffering or avoiding a wolf or den site, or avoiding harvest in a known important wildlife migration route. I appreciate your input Dave. Please let me know if you can provide wolf denning locations. Also, it is imperative that you get me your wolf mortality risk analysis as soon as possible so we have some time to advise the and the contractors working on the NEPA for Big Thorne. Take care, Kyle From: Person, David (DFG) Sent: Mon 2/28/2011 1:44 PM To: Porter, Boyd Rodney Moselle, Kyle Barten, Neil Larsen, Douglas Bethune, Stephen (DFG) Subject: Big Thorne Hi All, The Big Thorne timber sale likely will have consequences for the future viability of the watersheds involved to sustain wolves and deer. It also will contribute to the long-term loss of deer hunting opportunities. I attached 3 maps showing deer winter range prior to industrial timber harvest, the situation by 2008, and what will remain after Big Thorne if all units are included. In particular, the Thome River and Steelhead Creek watersheds that I highlight in the maps will be severely affected by the sale. There are simply no methods of mitigation that will compensate for that much loss of winter habitat. In the Thome watershed, most of the productive forest below 245m was logged over the last 25 years. 3:59:41 Much of it was pre-commercially thinned, which only provides about a 3-7year boost in understory 9(Q9g453for deer compared with unthinned stands (see attached paper by Liz Cole). Even so, much of that forage is unavailable because of slash, which also may increase risk of death of neonate fawns (see Farmer et al. 2006). Indeed, during my current study of fawn mortality, most of our neonates collared within the proximity of pre-commercially thinned stands died from bear predation within or adjacent to that habitat. The Big home sale goes further to remove the most important winter habitat for migratory deer in the watershed. Migratory deer generally over winter higher than resident deer unless pushed downward by deep snow. Many of the productive stands to be removed are situated above older clearcuts and are locally known for supporting deer during normal winters. Alpine and sub-alpine habitat is easily accessible to hunters in the watershed and many choose to hunt those areas because of abundant migratory deer. Loss of normal winter range likely will reduce that abundance. Steelhead Creek, is another area hard hit by the sale. Todd Brinkman reported that deer were currently abundant within the watershed and that they fared well during 3 consecutive severe winters compared to deer within the Maybeso and Staney drainages he studied. Their survival was enhanced by the availability of low elevation winter range, much of which will be removed by the sale. Steelhead Creek is also a major subsistence hunting area and still appears to have a healthy population of bears. The Big Thome sale will result in entries for the third time within the North Thome, Big Lake, Luck Lake, and Gravelly Creek drainages. The windowed image in my maps encompassed 30,124 ha of winter range in 1954, which was reduced to 14,964 ha by 2008. Much came from the private and state lands within the mapped area but as the maps show, much also came from the federal lands involved in the BT sale. Cumulative loss of productive forest habitat in those areas causes me to question the viability of those watersheds to maintain ecological functions and support a healthy predator-prey community. Wolf viability depends not only on reducing road density and risk of unsustainable harvest but also on abundant populations of deer. I doubt that a resilient and persistent wolf-bear-deer- human predator-prey system will be possible within the watersheds affected after the project is completed, if indeed it is still possible as current conditions progress inexorably toward stem exclusion. Current risks of unsustainable wolf harvest will be exacerbated by the project as deer become fewer in stem excluded forest and hunters blame wolves and bears for the lack of available deer. The legacy standard as written is of little value for protecting that ecological function. Basically, if there were only 3 old-growth trees left, the standard allows you to cut 2 of them. There is no lower limit below which no timber harvest is allowed. Finally, for now, the sale will impact 5 wolf denning areas (Trumpeter Lake, Big Lake, 3018 Long Lake, Angel Lake, and Upper Steelhead). With the exception of Upper Steelhead, each of those areas was used multiple times by wolves between 1993-2007. It is difficult to recommend any scoping changes other than simply to reconsider the whole sale because it will remove most of the best remaining old- growth in every watershed touched by the project. We are simply going to engage is a game of triage in which we recommend watersheds for which we hope to save some minimum level of wildlife viability and sacrifice the others. Dave 3:59:41 00491 From: Moselle, Kyle IDFG) To: Lenhart, Thomas (LAW) Subject: CONFIDENTIAL-- draft wolf Ianguaqe Date: Thursday, March 2011 PM CONFIDENTIAL ATTORNEY CLIENT PRIVILEGE ATTOENRY WORK PRODUCT Hey Tom. Hope y01u' Vacation was successful (C) I would like for V011 to l1el n1e om' Big Thome timbel' sale sco ins colmnents related to wolves. Let me know your thoughts next week after you rerlun to the office. Thanks! Take care, Kyle Moselle Tongass Coordinator Division of Habitat Office: 907-465-4287 Fax: 907-465-4759 00492 From: To: Cc: Subject: Date: Attachments: Clark, Clarence R (DNR) Fogels, Edmund J (DNR); Moselle, Kyle W (DFG); Hanley, Kevin J (DEC); Bohan, Carrie D (DNR); Lenhart, Thomas E (LAW); Katz, John W (GOV) Balash, Joseph R (DNR); Curran, Michael J (DNR); Dense, Chas A (DNR); Flynn, Rodney W (DFG); Gibert, Sally (DNR); Hughes, Andrew N (DOT); Kelley, David L (DNR); Robbins, Mark K (GOV); Ruaro, Randall P (GOV); Strandberg, Jim (AIDEA); Warner, Douglas R (DNR); brain.frenette@alaska.gov; Larsen, Douglas N (DFG); Levi, Andrew T (DFG); Magee, Susan E (DNR); Mendivil, Gary A (DEC) Draft - Big Thorne Scoping comments Wednesday, March 16, 2011 1:36:00 PM DRAFT internal scoping comments - deliberative process 3-16-11.docx INTERNAL DELIBERATIVE PROCESS Greetings, Attached are draft scoping comments for the USFS Big Thorne timber sale project. Please review and send comments to either Kyle Moselle (kyle.moselle@alaska.gov) or myself. Please have your comments to us no later than Friday 3-18-11. Thanks to everyone for your help on this project. Clarence Clark 00028 From: Larsen, Douglas To: Person, David Cc: Rodney (DFG1 Subject: RE: wolf dens Date: Monday, April 13, 2011 10:51:28 AM Thanks Dave, this is appreciated. I also understand and appreciate your observations about timing, roads, and cutting. want to continually put those points forward. I hope your field work goes down. Please let me know how I can assist with the truck and float house. I'm prepared to do what I can, once I understand what's needed from me. Thanks! Doug Larsen, Regional Super\'iso1* Region I - Southeast Alaska Alaska Department of Fish and Game Division of Wilcllife Conservation 802 West 3rc| St.. Douglas. AK 99824 P.O. Box 110024 Juneau. AK 99311 .- -- - .- doug.larsen@aIaska.gov From: Person, David (DFG) Sent: Monday, April 18, 2011 10:45 AM To: Larsen, Douglas (DFG) Subject: RE: wolf dens Hi Doug, The images I sent had enough information including the lake names and roads to identify where the dens were and 1200 foot buffers. Anyway, here are the den lat longs using decimal minutes and WGS34 as the datum: !s sai! to Eyle in my e-mail, the wolf !en timing restriction is not particularly important or wof conservation because it is only a timing restriction. They end up cutting the area anyway, just not during May and June. Road density and deer habitat are the major issues with Big Thorne. Dave 00003 From: Larsen, Douglas (DFG) To: Moselle, Kyle (DFG) Cc: Tim ki DF Subject: FW: wolf dens Date: Monday, April 18, 2011 10:53:27 AM Kyle -- Following are the den site locations you requested. Please let me know if there's any other information you need and I'll do what I can to secure it. Thanks. Doug Larsen, Regional Supervisor Region I - Southeast Alaska Alaska Department of Fish and Game Division of Wildlife Conservation 802 West 3rd St., Douglas, AK 99824 P.O. Box 110024 Juneau, AK 99811 mu'; 465-4." "3 //gm doug.Iarsen@aIaska.gov From: Person, David (DFG) Sent: Monday, April 18, 2011 10:45 AM To: Larsen, Douglas (DFG) Subject: RE: wolf dens Hi Doug, The images I sent had enough information including the lake names and roads to identify where the dens were and 1200 foot buffers. Anyway, here are the den lat longs using decimal minutes and WGS84 as the datum: As I said to Kyle in my e-mail, the wolf den timing restriction is not particularly important for wolf conservation because it is only a timing restriction. They end up cutting the area anyway, just not during May and June. Road density and deer habitat are the major issues with Big Thorne. Dave From: Larsen, Douglas (DFG) Sent: Mon 4/18/2011 8:17 AM To: Person, David (DFG) 00004 Subject: FW: wolf dens Dave -- I'd appreciate your help with gettinglackie and Kyle the lat/longs for the wolf den locations. This appears to be information that could prove useful in protecting these important sites. Please note the April 25 date noted in Jackie's email. Your assistance with this will be much appreciated. Thanks! Doug Larsen, Regional Supervisor Region I - Southeast Alaska Alaska Department of Fish and Game Division of Wildlife Conservation 802 West 3rd St., Douglas, AK 99824 P.O. Box 110024 Juneau, AK 99811 (907) 465-4369 (work) (907) 321-0770 (cell) (907) 465-4272 0'ax) doug.Iarsen@aIaska.gov From: Timothy, Jackie (DFG) Sent: Friday, April 15, 2011 3:15 PM To: Larsen, Douglas (DFG) Cc: Timothy, Jackie (DFG) Subject: RE: wolf dens Hi Doug -- I see in your email dated March 8, 2011 that you informed your staff you supported getting appropriate maps from the USFS so we could evaluate wolf den locations and accommodate den buffers. Tetra Tech provided us with shape files of the proposed action about three weeks ago. This afternoon, Dave Persons provided Powerpoint slides with circles showing wolf den buffers. However, the slides do not include legends, scale, or identifying information. Will you please ask Dave to provide us the lat and long for each wolf den location immediately so that we can assist the USFS in implementing the wildlife conservation measures? We will use the information to provide the USFS with specific locations that need to be excluded from the units to meet the 1200 wolf buffer without divulging the location of the dens. We need to finalize our maps on the 25th before Kyle heads to the meeting with Tetra Tech and the USFS on April 26. Thanks. . .Jackie From: Moselle, Kyle (DFG) Sent: Friday, April 15, 2011 2:37 PM To: Timothy, Jackie (DFG) Subject: FW: wolf dens FYI Take care, 00005 Kyle Moselle Tongass Coordinator Division of Habitat Office: 907-465-4287 Fax: 907-465-4759 From: Person, David (DFG) Sent: Friday, April 15, 2011 1:43 PM To: Moselle, Kyle (DFG) Cc: Rodney Larsen, Douglas Barten, Neil (DFG) Subject: wolf dens Hi Kyle, Attached are some powerpoint slides showing wolf dens in the Big Thorne project area. The circles are 1200ft buffers. I show 1200ft circles around suspected den sites at Angel lake. We know they denned there several times but we never found the actual natal dens. You should be able to compare the buffers with your maps of the proposed unit pool to see which units might fall within the buffers. Frankly, the den buffer guideline is not one that I worry much about. It is not based on my or anyone's work with wolves and is just a timing restriction. Its value is pretty limited because the area gets out eventually. Wolves generally avoid logged stands and high levels of disturbance when selecting den sites but after they are actively denning, they will tolerate quite a bit of noise and human disturbance. Road density and deer habitat are much more important for wolf viability than the wolf den guideline. I did not respond to your last e-mail about deer habitat in the BT project because I was too busy. However, I want to make one point very clear. The Tongass Land Management Plan may or may not be adequate for protecting ecosystem functions and species viability. We simply don't know. It was based on some, not all, but some of the best science available in 1996. "Based on the best science available" does not mean the science was adequate. It is also a plan that many in the USFS only tolerated after doing everything possible to see that it never saw the light of day. Anyway, as a professional biologist who knows this ecosystem as well as anybody working here, who has worked in that system doing research on that system for almost 20 years, I would hope that my comments and concerns about a proposed project will be transmitted up the ladder regardless of whether they specifically relate to a TLMP Those only address a fraction of the ecological problems associated with industrial-scale timber harvesting of northern Pacific rainforests. dave 00006 From: Moselle, Kyle (DFG) To: Timothy, Jackie (DFG) Subject: FW: wolf dens Date: Friday, April 15, 2011 2:37:00 PM Attachments: Wolf Dens.ppt FYI Take care, Kyle Moselle Tongass Coordinator Division of Habitat Office: 907-465-4287 Fax: 907-465-4759 From: Person, David (DFG) Sent: Friday, April 15, 2011 1:43 PM To: Moselle, Kyle (DFG) Cc: Rodney Larsen, Douglas Barten, Neil (DFG) Subject: wolf dens Hi Kyle, Attached are some powerpoint slides showing wolf dens in the Big Thorne project area. The circles are 1200ft buffers. I show 1200ft circles around suspected den sites at Angel lake. We know they denned there several times but we never found the actual natal dens. You should be able to compare the buffers with your maps of the proposed unit pool to see which units might fall within the buffers. Frankly, the den buffer guideline is not one that I worry much about. It is not based on my or anyone's work with wolves and is just a timing restriction. Its value is pretty limited because the area gets out eventually. Wolves generally avoid logged stands and high levels of disturbance when selecting den sites but after they are actively denning, they will tolerate quite a bit of noise and human disturbance. Road density and deer habitat are much more important for wolf viability than the wolf den guideline. I did not respond to your last e-mail about deer habitat in the BT project because I was too busy. However, I want to make one point very clear. The Tongass Land Management Plan may or may not be adequate for protecting ecosystem functions and species viability. We simply don't know. It was based on some, not all, but some of the best science available in 1996. "Based on the best science available" does not mean the science was adequate. It is also a plan that many in the USFS only tolerated after doing everything possible to see that it never saw the light of day. Anyway, as a professional biologist who knows this ecosystem as well as anybody working here, who has worked in that system doing research on that system for almost 20 years, I would hope that my comments and concerns about a proposed project will be transmitted up the ladder regardless of whether they specifically relate to a TLMP Those only address a fraction of the ecological problems associated with industrial-scale timber harvesting of northern Pacific rainforests. dave