176 



© 



Page 35 



Again, the Forest Service fails to realize that in southeast Alaska lands protection and 

 wilderness equate to food, jobs, income, and cultural tradition — fish and game for 

 commercial, recreational, and subsistence users. We are not dealing with a simple issue of 

 recreation versus development. This basic misunderstanding is crippling the Forest Service's 

 effort to come to terms with Tongass issues. 



Pages 36 and 37 



Once aga.'^ the Forest Service misrepresents the old growth concerns on the Tongass National 

 Forest. The agency refuses to admit that all old growth is not the same: an acre of stunted 

 muskeg pine is not the same as an acre of high volume hemlock when it comes to its value as 

 wildlife and fish habitat. 



The real issue is the fate of the biological heart of the Tongass, the 8-13% of the commercial 

 forest land that is the best wildlife and fish habitat, nearly all of which is open to logging and 

 is included in annual timber sale calculations. 



Pages 40 and 41 



The Forest Service explains the value of the salmon fishery to southeast Alaska, but the agency 

 understates the employment and monetary benefit of the fishery. In addition, the text does not 

 reveal that the riparian prescriptions employed in the TLMP Revision and the "benchmark- 

 analyses presented in the AMS both allow logging (clearcutting and selection harvest) as close 

 as 25 feet away from some class 1 anadromous fish streams, allow roads to be built in riparian 

 areas, and grant managers the discretion to modify fish habitat protection standards on a case 

 by case basis. Although most of the benchmarks left the salmon streams uncut, there is still no 

 guaranteed protection. 



Page 42 



The presentations on wildlife habitat present some useful information but distort and omit 

 other important information. For example, the following information is not included 



1) Brown bear seasons on north Chichagof bland were closed by the state due to heavy 

 mortality related to logging roads, logging camps, and generally increased human 

 activity. 



2) The definition of deer winter range is inconsistent with current scientific research, and 

 is inconsistent with the deer habitat model developed cooperatively by the Forest 

 Service and the Alaska Dept. of Fish and Game. 



3) Recent Forest Service documents predict that in pulp company logging areas bald 

 eagles, brown bear, black bear, deer, and pine marten populations will plummet as the 

 old growth forest is liquidated and a second-growth tree farm established. Many of 

 these areas are important for subsistence and for rural community stability. 



Page 43 



Here, the Forest Service acknowledges: 



'Most timber harvest is occurring in high volume stands that are also important for 

 many wildlife species." 



