399 



The manner in which the AMS handles the issue of second- 

 growth productivity is deceptive. Problems of forecasting 

 second-growth productivity may stem in part from the fact that 

 the timber yield tables for second growth are largely based on a 

 report published in 19 3 0s, a report that did not emphasize regen- 

 eration of marginal timber lands. 15 The original report only 

 evaluates two such areas. Yet, the Forest Service uses the 

 projected increase in yields from second growth to be cut 100 

 years from now to justify logging more old growth today. 



The Forest Service also fails to address the fact that the 

 average quality of logs declines substantially in second-growth 

 timber. Unlike old-growth timber characterized by wood that is 

 fine grained, clear, and of superior strength, second-growth wood 

 on the Tongass is coarse grained, knotty, and of inferior 

 strength. Higher quality second-growth timber grown in the 

 Pacific Northwest already competes with Alaska's old-growth. 

 This means that Alaska's second-growth timber will probably be 

 suitable only for pulp and represents a serious problem in that 

 current pulp production in southeast Alaska is only possible 

 because it is underwritten by the higher selling values of high 

 quality lumber made from old growth. 



AMS Is Unable to Present the Real Tradeoffs Between Resources 



Fishing Seventeen years of research by the National Marine 

 Fisheries Service (NMFS) has concluded that logging within 100 

 feet of salmon streams and their important tributaries irrepara- 

 bly harms the production of salmon. Yet, the Forest Service has 

 failed to incorporate the minimum stream protections recommended 

 by the Service into the AMS. This means that commercial 

 fisheries will continue to be threatened by a taxpayer subsidized 

 timber industry. Not only does the AMS fail to consider any 

 tradeoffs between logging and fish production, it claims — without 

 substantiation — that current logging could be increased by 13 

 percent without any adverse impacts to the Tongass fisheries. 

 This defies not only two decades of scientific research and years 

 of experience by commercial fishermen but common sense as well. 



Subsistence Another notable deficiency in the AMS is the 

 lack of serious consideration of subsistence uses. While the 

 Forest Service provides information on the amount of wildlife 

 habitat needed to maintain minimum viable wildlife populations, 

 the agency does not provide information regarding how much 

 habitat is needed to meet existing and future subsistence uses. 

 Apparently, the Forest Service is choosing to ignore its statu- 

 tory requirements to meet subsistence needs. 



15 R.F. Taylor, 1934, Yield of second growth *e*tern hemlock- si tka spruce in southeastern alaska, US0A- 

 Forest Service, Washington O.C., Tech. Bull. 412. 



8 



