178 



CD 



Page 48 



The net present value figure of $25.6 billion for the 13 "viable" mineral deposits should be 

 considered carefully. For example, this figure, depending on how it is handled in the Forest 

 Service's FORPLAN computer model, could dramatically skew the present net value 

 calculations for benchmarks and management alternatives. 



Pages SO and SI 



On these pages the Forest Service presents several phrases and concepts that govern the 

 FORPLAN benchmark analyses. Unfortunately, the explanations are so glib they could be 

 misleading. 



For reasons that are explained in my initial critique of the benchmark analyses, the "long-term 

 sustained yield capacity" of the Tongass is a relatively meaningless figure. Simply put, it 

 assumes unlimited expenditures on intensive timber management on every square foot of land 

 capable of growing a tree, with little consideration of practical operational limits, and with no 

 consideration of any other uses of the Tongass at all. 



"Non-declining yield" is often called "non-declining even flow" or NDEF. This constraint 

 merely forces the FORPLAN computer model to schedule logging activities so that the annual 

 cut never declines. However, NDEF does nothing to assure that the value of annual logging 

 programs does not decline, which is a big problem. 



Dispersion constraints only delay adjacent clearcuts for 10 years, therefore some huge (greater 

 than 1000 acres) de facto clearcuts could be possible over, say, a fifty year period. 



Both riparian (stream side, estuarine, and lake side vegetation) prescriptions being used in the 

 plan allow clearcutting and selective logging as close as 25 feet from some types of class 1 

 salmon streams, allow salvage of timber in and across class 1 streams, and allow road 

 construction and bridges along class 1 streams. In addition, managers may modify stream 

 protection standards on a site by site basis at their discretion. 



 

 The concept of "viable wildlife populations" has meaning with regard to biodiversity, habitat 

 fragmentation, and endangered species, but most Alaskans are concerned with the harvestable 

 surplus, not minimum viable populations. That is, most southeast Alaskans are concerned with 

 fish to catch, sell, and eat, and venison for the table --to protect these interests wildlife and 

 fish populations must be robust, not minimal. 



