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V. THE TLMP REVISION WILL ACTUALLY BE LESS SITE-SPECIFIC THAN 



THE FIRST TLMP! 



TLMP 1 subdivided the Tongass National Forest into individual watersheds, a logical 

 geographic unit of analysis. Each of the 867 watersheds was called a Value Comparison Unit, 

 or VCU. The resource values, capabilities, and trade-offs were considered on a VCU basis. 

 "Part II" of TLMP 1 contained a comprehensive schedule of all activities -- timber sales, roads, 

 log dumps --that were authorized in each VCU. The public could discern exactly what was 

 planned for each VCU, and when it was scheduled. 



The TLMP Revision uses a very much more general geographic unit of analysis. The Forest 

 Service has abandoned the 867 VCUs and replaced them with only 51 "Geozones", each of 

 which includes many VCUs. Geozones are the smallest unit of analysis, yet at an average size 

 of 370,000 acres the geozones are approximately sixteen times larger than the average VCU. 

 That is, the TLMP Revision analyses of environmental impacts will be conducted on a scale at 

 least 16 times less site specific than TLMP 1. 



The Forest Service asserts that because they have replaced the four TLMP 1 Land Use 

 Designations (LUDs) with 24 "management prescriptions", and will allocate smaller-than-VCU 

 sized tracts to these prescriptions, they will be more site specific. This is simply not true. 



The Forest Service is confusing allocation with evaluation. In spite of the 24 prescriptions, 

 which will result in a more complicated land use allocation map, the Forest Service will not 

 perform any environmental assessment on this level of detail. Evaluation of impacts of the 

 plan on wildlife, fish, timber, and recreation will only be specific to the geozone level. Even 

 worse, the Forest Service's own specialists concluded that the TLMP Revision timber database 

 is so poor that evaluation of the effects of the plan may not be reliable below the level of the 

 three administrative areas on the Tongass (Ketchikan, Stikine, and Chatham -- areas of many 

 millions of acres in size each). 



The leader of the TLMP Revision told members of the SEACC staff and board of directors 

 that the TLMP Revision will qoj contain a schedule of proposed activities by VCU or 

 watershed, as did TLMP 1. Without such a schedule the TLMP Revision will provide much 

 less detailed informat ion about what the agency plans to do on the ground than did TLMP 1. 



VL THE TLMP REVISION TIMBER INVENTORY IS SO INACCURATE THAT IT 

 HAS NO VALIDITY FOR COMMUNITY- BASED OR SITE-SPECIFIC 

 PLANNING. 



The Forest Service's new Geographic Information System (GIS) stores, sorts, and maps the 

 TLMP Revision timber database. Although the GIS machinery is complex and produces artful 

 maps, the quality of the timber maps in the GIS is so poor that the GIS maps and analysis are 

 unreliable. 



The Alaska Region of the Forest Service was so concerned about the inaccuracy of its TLMP 

 Revision Timber Type Map that it brought in an agency expert in timber inventory to review 

 the data. That specialist concluded that the data fell short of providing the information needed 

 for National Forest planing, saying: 



Particularly lacking is the means of relating timber estimates to specific smaller 

 areas of land with any reasonable precision. 



