215 



Wilderness areas on the Tong&ss arc not adequate to meet the needs of the expanding nature-based 

 tourism industry, and these areas aie totally ofT-limits for any tour operations (hat require even simple 

 facilities, such as cabins, shelterj, or even out houses or new trails. Wilderness is also limited to groups 

 smaller than 12 people, including guides. And although Wilderness desigoaljon is a great marketing tool 

 in attracting vlsiiofs to an area, the Forest Service has determined that the carrying capacity (or those 

 tour groups that use Wilderness is quite limited. Furthermore, approximately 70% of Tongass 

 Wildeniess consists of high nxMinuins, ice and snow fields, poody-<k2iaai cnuskegs, and low-volume 

 forests supporting tow wildlife numbers. Much of the coastal Wijdemess has rocky or steep diotelines 

 or contains no safe aocfaoragcs. lliereibfe, much of WUderoess is of limited utility to a m^ority of the 

 tour industry, and to those companies like Alaska Discovery wtab heavily market trips to the more 

 sccessibtc and piotcUeJ coest Wikleniess areas, these areas are designed and managed for low levds of 

 commercial use. Thus, we and other companies look to areas outside of Wilderness, such as many of 

 those in the KPC sale area, for future tourism opportunities. 



The Forest Service estimates in the current draft Tongass Plan that the demand for scnu-primitive 

 motorized recreation will exceed the supply wjthin a few areas. This means that those areas of coastal 

 southeast Alaska most accessible by visitors will no longer meet their desired goal of less than 10 group 

 encounters per day and camping or aochoriog at night without being in si^ht or sound of other cajipers 

 or boats. The KPC contract extension would greatly exacerbate this shortage of recreation and tourism 

 places. If this happetn, coastal southeast Ala^ will no k>ngcr provide adequate opportunities for 

 visitors and residents alike to have the experiences for which they travel to the Tongass. 



Rather than extend the contract, and thus the high level of conflict, we prefer to see Metal aod stale 

 officials use the remaining 8 years of the current ooniiact to plaa for a transition to a lower timber 

 vohjnae for the Tongass. Rather than coooling timber volunoe, we urge ofiictals to help die industry 

 provide the same number of timber jobs using a lower timber volume via an emphasis on high value- 

 added secondary woods fxoducts manaufacturing.. Without the pulp mill contract, this should be 

 possible, thus representmg a win-win situation for everyone in the Tongass. 



TLMP UNDERESTIMATES TOURISM SECTOR AND DOES NOT ADEQUATELY PLAN FOR 



FUTURE TOURISM DEVELOPMENT • 



We continue to be disappointed in the tourism analysis and planning contained in the latest version of 

 the Tongass Land Management Plan. However , wc do not wish to see the Plan delayed any longer, and 

 WC urge the Forest ftervice to stay on it.'i cur rgnt timeline to cnmpleie the Plan. 



TLMP is clearly a timber plan only, and it does an iitadequate job of plaivniog for tourism development 

 over the next ten years. For example, there is no alternative that emphasizes tourism development and 

 exaiTunes the employment that could be generated if tourism development were a goal in the Plan. 

 Instead, tourism is assumed to remain virtually the same in all alternatives. Also, tt)e methodology 

 used to detemiine present net value of recreation/tourism on page 3-323 is highly questionable, 

 considering no good date exists to estimate total recreation visitor days on the Tongass, and the daily 

 value of an average recreation visit on the Tongass of S25.73 is unsupported by any study other than an 



