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Page 45 



The chart and text explain that most of the important recreation places on the Tongass "occur 

 in areas associated with valleys, streams and beach fringes, [and] they also tend to have high 

 values for other resources including wildlife and timber", and that most of these important 

 areas are unprotected and open to logging. This is an important point: there are trade-offs 

 between recreation, wildlife, and fish, on the one hand, and timber on the other. As 

 discussed below, the "benchmark" analyses fail to present or clarify these trade-offs. 



Page 46 



These new "tentatively suitable timber land" acreage figures include a great deal of land where 

 timber is not economic to haivest, and where actually operating a timber saJe is not feasible. 

 Neither logging operability or economic efficiency are considered in delineating "tentatively 

 suitable timber." The tentatively suitable lands include a great deal of timber in the 8-20 

 mbf/acre volume class that is generally not economic to operate. Therefore, these figures 

 overstate the timber base. 



The use of the term "suitable for timber harvest" in the pie diagram is an error -- it should 

 say "tentatively suitable." The new category differs from the 1979 TLMP 1 definition of 

 "suitable" timber. The TLMP 1 classification considered roughly 1.7 million acres of land to 

 consist of suitable old growth. The TLMP Revision considers suitable timber growing land, 

 regardless of its current inventory status, and also includes lands allocated to Land Use 

 Designation (LUD) II in TLMP 1 -- the total is some 3.1 million acres. The book keeping 

 method has changed, but the resource supply estimates have not changed much. 



The pie diagram presented on page 46 constitutes an extreme misrepresentation of the facts 

 regarding the amount of commercially valuable timber in existing wilderness areas. First, the 

 Forest Service does not distinguish between tentatively suitable and not suitable timber within 

 wilderness. Second, the presentation does not consider timber land operability. Third, the 

 relative value of the timber in wilderness is not addressed. The fact is that, according to 

 existing Forest Service data, only 80,000 acres of wilderness lands have commercial timber 

 that is both commercially important (>30 mbf/acre) and harvestable under current federal 

 standards. 



Page 47 



The Forest Service projects that timber demand will remain at "all-time highfs]." This is 

 precisely the sort of reckless optimism that led us into disaster in the first Tongass Land 

 Management Plan, when rosy Forest Service timber demand forecasts were followed in the 

 1980s by the worst market collapse in history. The Forest Service was totally unprepared to 

 deal with the situation, and continued building "roads to nowhere" and dumping timber sales on 

 a shriveled market. In that case the losers were the American taxpayers, who between 1982 

 and 1986 lost an average of $50 million a year on the Tongass timber debacle. Why isn't the 

 Forest Service learning from the past and taking a more temperate, adaptable approach this 

 time around? 



