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DDL THE FOREST SERVICE HAS NEVER PREPARED A TRUE NATIONAL FOREST 

 MANAGEMENT ACT FOREST PLAN FOR THE TONGASS, AND THE TLMP 

 REVISION PRESENTLY FAILS TO MEET THE REQUIREMENTS OF LAW. 



The first Tongass Land Management Plan of 1979 did not constitute a true NFMA Forest Plan. 



TLMP 1 was prepared after NFMA passed, but before any administrative implementation 

 regulations were adopted. As a result TLMP 1 was an ad hoc planning effort and was not 

 consistent with the NFMA Forest Plans that have been prepared for every other National 

 Forest in the United States. 



Throughout the debate on Tongass Reform the Forest Service deferred all administrative 

 concern with management reform to the TLMP Revision. Now, the Forest Service has scuttled 

 much of the promised planning, analysis, and consideration of reform. For example. 



Forest wide subsistence studies have been scuttled or foreshortened 



Wildlife habitat modeling will not be site specific in nature 



The range of alternatives for Tongass management has been cut to only three poorly 

 conceived options all designed by the Forest Service in-house with no formal public 

 involvement at all. 



The Washington Office of the Forest Service has directed the TLMP planners to scuttle plans 

 for a comprehensive, meaningful TLMP Revision. 



James Overbay of the Forest Service's Washington Office has directed the Tongass noi 

 to perform a comprehensive, "zero-based* plan that looks at a comprehensive range of 

 alternatives. (Attachment I) 



Overbay has also directed Tongass planners noi to perform site specific environmental 

 assessment of the many logging and road building and other projects that will be 

 authorized in the TLMP Revision. (Attachment J) As a result there will never be a 

 comprehensive assessment of the cumulative effects of the hundreds of interrelated 

 development actions that will be implemented under the banner of the TLMP Revision. 



IV. THE ALASKA REGIONAL FORESTER HAS ACCELERATED THE TLMP 



REVISION SCHEDULE, FORCING UNPRECEDENTED SHORT DEADLINES 

 THAT OBVIATE MEANINGFUL, PROFESSIONAL PLANNING. 



The TLMP Revision Work Plan, prepared by the Forest Service to guide the new planning 

 effort, allowed planners sixteen months from completion of the "Analysis of the Management 

 Situation" (AMS) to the publication of a draft Forest Plan. The full AMS was not published 

 until mid-February, 1990. Yet the Regional Forester has asked the planners to put a draft plan 

 on his desk for review by March 23rd, thereby condensing a sixteen month job into less than 

 two months! Regional Forester Barton and the Chief of the Forest Service promise to publish 

 that draft by May 31st. 



