256 



Pick Seed "2- June 30. 1989 



Being disturbed as '. c the process b <■ uhich recent habitat 

 degradation of this tvpe occurs. I deciied to attempt to trace 

 the history of this unit. Significantly, jpop examination of 

 the Ketchikan Pulp Company's 1984-39 E15. I found that the 

 review materials previously nade available to the Department 

 of Pish and Game and the Pubi ic showed that much of tne 

 cutting I objected to uas not uithin the unit boundary maps. 

 In fact, on the pre-logging maps made available for Public 

 review, the unit boundary remains about a full one-quarter 

 mile auay from Logjam Creek, tributary H4021 and a ccno 

 rearing uetlands on the south (Attachment A) . The 

 pcst-logging unit boundary, as depicted in the newly released 

 1989-94 EIS. also shows that the recent logginq did not 

 encroach into the same quarter-mile riparian zone shoun on the 

 previous 5-year operating period EIS maps (Attachment 3). 



At this Point. I thought I may have mis ! ocated my positicn on 

 '.he maps, as neither the pr e-nor-pos t - I ogg l ng EIS come close 

 to corresponding uith uhat exists in the field. Upon 

 requesting and obtaining the unit release map uhich the Forest 

 Service transmitted to the Ketchikan Pulp Company (Attach- 

 ment C). I uas shocked to see that the unit boundary had been 

 adjusted to include extensive streamside logging, uhicn 

 corresponded to what uas observed in the field. The unit 

 'elease layout plan uas signed by the The- ne Bay District 

 Sanger on Harch 18. 1987, uith logging occurring in either 

 1987 or 1988. 



Questions to uhich ue need answers include: 



(1) Jhy uas the layout changed to include streamside logging 

 at the expense of habitat values 9 



(2) Uhy uas ADr&G net contacted of a proposed change 7 



(3) Don't changes such as this violate the NEPA process 9 



(4) Uhy uas no evaluation or mitigation provided to prevent 

 the damages uhich uere inevitable by such a change 9 



(5) After the unit boundary uas changed and the area logged, 

 uhy uas this change not indicated in the neu EIS just 

 publ ished 9 



Of Paramount concern, houever , is that such changes invalidate 

 the EIS planning process and all of the revieu that ADF&G and 

 others put into planning efforts, such as the 1989-94 sale 

 currently under revieu. or the forthcoming TLflP. In 

 consultation uith a former Forest Service employee. I uas 

 informed that, in his opinion, over 501 of the units get 

 changed from uhat is delineated in the EIS. This is very 

 disturbing, considering the amount of effort ue give to such 



