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Vn. INACCURATE CIS TIMBER MAPS RESULT IN INACCURATE ECONOMIC 

 ANALYSIS. 



Because the current timber inventory cannot reliably distinguish between the three most 

 important timber volume classes on the Tongass, and because volume class differences 

 determine the net value of timber stands, the validity of FORPLAN analysis in drastically 

 eroded. 



Vm. INACCURATE TIMBER MAPS UNDERMINE ANALYSIS OF THE EFFECTS OF 

 TIMBER HARVESTING ON WILDLIFE AND ON LOCAL COMMUNITIES. 



Inaccurate timber maps mean the Forest Service cannot locate specific harvest areas or specific 

 wildlife habitat areas on a map or on the ground. Since they do not know exactly where 

 timber will be cut, they do not know exactly where wildlife habitat will continue to exist, and 

 they therefore do not know how timber harvest will effect community use of local wildlife 

 areas. 



EX. THE FOREST SERVICE HAS SCUTTLED ITS COMMITMENT TO A 



COMPREHENSIVE ASSESSMENT OF SUBSISTENCE RESOURCE NEEDS AS 

 PART OF THE TLMP REVISION. 



The following quote from the Alaska Department of Fish and Game illustrates the Forest 

 Service's backpedalling on subsistence. 



Subsistence policy decisions now being made in the course of the TLMP revision 

 contradict many of the agreements that we had taken as signs of progress. We 

 have been informed [by the Forest Service] that the TLMP revision is now 

 described as "programmatic" and therefore not subject to the requirements of 

 Sec. 810 of ANILCA. . . . future subsistence evaluations will apparently be 

 conducted at the project [EG: individual timber sale] planning level only, at 

 which point the cumulative effect of land management activities throughout a 

 rural community's subsistence harvest area will not be considered. The TLMP 

 revision, therefore, offeis the only opportunity to meaningfully assess long range 

 and cumulative forest management impacts. . . . These recently revised 

 approaches to National Forest planning and management appear to conflict with 

 the USFS subsistence handbook, which calls for Sec. 810 evaluations and 

 "significant impact" findings as part of draft forest plan development. 

 (Attachment K) 



The Sealaska Corporation "Position Paper on the TLMP Revisions" states: 



Subsistence is not an active consideration in the USFS forest planning process 

 until after forest management alternatives are developed or after a project is 

 proposed. This places subsistence in a secondary role to all other uses proposed 

 in the alternatives and projects. Sealaska believes that this is inconsistent with 

 the intent of ANILCA and opens the Forest Service to challenge unless 

 corrected. 



Unless agreement can be reached between the Forest Service and Sealaska 

 Corporation on the point that subsistence must be given the priority it deserves 

 in the USFS land use and management decisions for the Tongass, the 



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