172 



IF ALASKA 



DEPARTMENT OF FISH AND CAME 



DIVISIOM OF SUBSISTENCE 



sTtvtcowra. go 



box 32000 



juneau. alaska 99303 



PHONE: 19071465-4147 



vbuSBk 



January 5, 1990 



Steve Brink 



TLMP Revision Team Leader 

 U.S. Forest Service 

 Juneau, Alaska 99802 



Dear Mr. Brink; 



JAN , 1990 



i REGION* 



The Division of Subsistence takes seriously our role in assisting federal agencies in ANILCA Title VIII 

 implementation. This includes specific direction in Sections 802 and 812 related to cooperation in the 

 conduct of subsistence research, an activity in which this Division has played a lead role. Accordingly, 

 we have closely followed the development of the Tongass Land Management Plan (TLMP) revision. 

 Indeed, Subsistence Division staff and the USFS cooperated in 1988 in a comprehensive regional 

 subsistence survey that was specifically tailored to meet TLMP revision information needs. This study 

 represented a substantial commitment of state and federal resources, with total costs of close to 

 Sl.000,000. In the course of several meetings during which I or a member of my Southeast Region staff 

 was present, we discussed ways that this subsistence information could be used in the TLMP revision to 

 insure that subsistence protections were built into Tongass land management decisions. 



This history is particularly significant, it seems to me, in the context of the current litigious climate, 

 wherein USFS land planning decisions have repeatedly been challenged on subsistence grounds. I am 

 sure all who participated in our discussions over the past several years believed that the TLMP revision 

 represented a unique opportunity for the Forest Service to fully meet ANILCA subsistence 

 requirements, adequately addressing the subsistence land management concerns that have proven so 

 intractable in Southeast Alaska. 



In view of all of this, we find it extremely troublesome that subsistence policy decisions now being made 

 in the course of the TLMP revision contradict many of the agreements that we bad taken as signs of 

 progress. We have been informed that the TLMP revision document is now described as 

 'programmatic* and therefore not subject to the requirements of Sec 810 of ANILCA. Subsistence 

 information that appears in the document will, at best, simply be used to predict generalized effects of 

 allocation alternatives. 



Furthermore, future subsistence evaluations will apparently be conducted at the project 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, offers the 

 only opportunity to meaningfully assess long range and cumulative forest management unpads. 

 Department staff have spent a considerable amount of time designing a meaningful approach to this 

 complex analysis. Please refer to our letter of 22 May, 1989, (Bosworth, Reed and Anderson to Brink) 

 for our detailed recommendation on an appropriate Sec 810 evaluation procedure for the TLMP 

 revision. 



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. This procedural handbook was prepared in concert with other 



