175 



G) 



Page 25 



Although the Forest Service acknowledges that the Alaska Lands Act recognized subsistence as 

 a priority use of the Tongass National Forest, the Forest Service refuses to comply with Title 

 VIII of ANILCA in the TLMP Revision. The agency's original plan for a detailed analysis of 

 subsistence use of the Tongass has been scrapped in order to meet the short timelines imposed 

 by Forest Service policy makers. 



Page 28 



The description of issues here is woefully superficial. The Forest Service's inability to 

 acknowledge and grapple with the real issues on the Tongass is a major reason why 

 Congressional reform is so essential to the future of southeast Alaska. The key issues on the 

 Tongass include lands protection, subsistence rights, protection of streamside habitat, high- 

 grading the best wildlife habitat, destruction of key recreation areas, and domination of the 

 Tongass management by fifty-year timber contracts. 



Page 31 



The "benchmark" analyses being prepared by the Forest Service do no! show "what effect it's [a 

 given resource's] production has on other resources." Resource simulation models can show 

 such effects, but FORPLAN benchmarks are not intended for that purpose. For reasons 

 outlined below, the benchmarks summarized in the "user-friendly" AMS are worthless as models 

 of Tongass resource interactions and environmental effects. If these benchmarks "form the 

 foundation for reconsidering how to manage the Tongass National Forest for the next 10 to 15 

 years" we are in deep trouble! 



Page 32 



The statement that Tongass wilderness includes 1.5 million acres of old growth forest is 

 misleading. Of this land, less than 8000 acres is land with more than 50 thousand board feet 

 of timber per acre (50 mbf). Outside of wilderness, over half of this most important old 

 growth wildlife habitat, about 100,000 acres, has already been logged; the vast majority of the 

 remaining high volume old growth is presently available for logging. 



Page 34 



The Forest Service asserts that a small proportion of the forest has been clearcut to date. The 

 agency fails to point out that the roughly 360,000 acres of lands logged since 1950 were, for 

 the most part, prime wildlife habitat. The average volume per acre cut over this period was 50 

 mbf /acre, which is far greater than the Tongass- wide average of about 21 mbf /acre. In other 

 words, since 1950 the industry has been cutting the very best timber stands, which are also the 

 very best wildlife habitat -- a classic case of mining the high-grade timber at the expense of 

 the future. 



The graph presented on this page gives the impression that there's little to worry about -- lots 

 of roadless land left. But if the reader considers the problem of past high-grading and the 

 table on page 32 of the "user-friendly" AMS, it's clear that wildlife habitat is being logged, 

 whereas most of the remaining roadless land is ice and snow, alpine tundra, and rock, along 

 with muskeg and cutover second growth timber stands (referred to as "other forested lands" on 

 page 32). Yes there's a lot of roadless land left, but yes, the valuable fish and wildlife areas, 

 the heart of the Tongass, are being liquidated. 



