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accurately identifying these characteristics. if the information 

 on economically important variables, such as volume class and log 

 size, is unreliable, the economic analyses will be equally 

 unreliable. This is particularly disturbing since the Forest 

 Service often includes large amounts of marginal timber in the 

 Tongass timber base, making it more difficult to differentiate 

 timber values between marginal and more productive forest lands. 



This practice will also exacerbate the existing problem of 

 highgrading on the Tongass, a practice that is a major issue in 

 current Tongass reform legislation. For the past 30 years, only 

 the higher volume stands of timber on the Tongass have been 

 harvested. The AMS not only fails to address the issue but 

 complicates it by claiming the forest is capable of sustaining an 

 exaggerated level of logging. The AMS indicates that harvest 

 rates of 580 to 780 million board feet (mmbf) are feasible for 

 the 1990s, while the logging rate from 1977 to present has 

 averaged 340 mmbf. 10 This proposed increase in logging reflects: 

 1) an excessive reliance on a special exemption from the National 

 Forest Management Act that allows the inclusion of marginal 

 timber lands in the timber base, 2) unreasonably high demand 

 forecasts for Tongass timber, and 3) overly optimistic yields 

 assumed for second-growth timber stands. 



The exemption from Section 6(k) of the National Forest 

 Management Act was intended to encourage the use of marginal 

 timber. In practice, Tongass managers have used the exemption to 

 inflate the timber base. While the timber base thus looks 

 healthy, the timber industry has never selected the marginal 

 timber, even though the Forest Service has spent millions of 

 dollars since 1980 to make this timber available. This has 

 forced the agency to meet the requirements of the two long-term 

 contracts by substituting better timber for unwanted marginal 

 timber. 



Th« timber Industry has concentrated logging on tha higher than averege voluea timber stands. The 

 average voluea per acre for the Tongass tlaber base it between 22,000 to 26,000 thousand board feet (mbf) 

 per acre. Yet, harvest yields for the last 30 yeers hsv* been about 40,000 to 42,000 mbf/acrt. Since 

 1950, the aoet economically Important species on the forest (Sitka spruce) accounts for about 27 percent 

 of the total voluea harvested. Its natural distribution over the timber base is only 11-14 percent. This 

 means that the aoet profitable trees have been cut at a rate two tlaber faater than what can be sustained 

 over the harvest rotation. The practice of concentrating on Sitka spruce end taking only the higher 

 voluea timber atands lowers the value of regaining timber supply. 



10 The period 1977 to 1989 includes two record high timber markets (1977 to 1961 and 1987 to 1989) and 

 one severe timber market recession (1982 to 1986). 



11 Since 1980, there hes setuslly been an Increase in the average voluea per ecre harvested, even though 

 the use of marginal lands was intended to more then double. Recent claims that significant marginal lands 

 are now being used sre the result of s 1985 change in the Forest Service definition of earginel timber. 

 About helf of the better timber lands originally designsted In the Tongaaa Land Management Plan (TLMP) 

 have been redefined es Marginal. 



