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The National Forest Management Act (NFMA) requires that the Forest Service provide 

 for the diversity of plant and animal communities. Maintenance of "viable populations 

 of native vertebrate species" is required in implementing regulations. The Tongass Land 

 Management Plan (TLMP), which is now undergoing revision, is the blueprint for 

 ensuring that logging activities in the Tongass are consistent with those legal 

 requirements as well as other legitimate purposes of the National Forest. 



Activities taking place under the existing KPC contract, including the guaranteed supply 

 of 192.5 million board feet per year, are certainly those which must be governed by the 

 forest plan blueprint. So why isn't this proposed contract renewal taking place within 

 the context of the TLMP revision process? We believe that if the effects of the KPC 

 contract are legitimately assessed through the revision process, it will be found to harm 

 the Forest Service's ability to maintain viable populations of native species. In fact, we 

 are convinced that the TLMP revision team should not just reject the KPC contract 

 extension, but should cancel the existing contract immediately, based on KPC's black 

 track record and the effects of mandated logging on the wildlife habitat. This bill would 

 ride roughshod over the TLMP process, and force the Forest Service to provide a high 

 volume of trees regardless of the environmental, economic, recreational, social, and 

 ecological costs. 



For over 40 years, KPC, owned by Louisiana-Pacific, has been operating under a 

 contract unique to the national forest system. Based on its record, there is no 

 justification for contract renewal, let alone the sweetheart deal that H.R. 3659 entails. 

 As representatives from local Alaskan groups have pointed out, the Environmental 

 Protection Agency's most recent reports show that KPC is one of the biggest toxic water 

 polluters in the Pacific Northwest, and has failed to comply with a host of federal clean 

 air and water laws. The record of KPC over the past 20 years includes a felony and 

 thirteen misdemeanor pollution convictions, millions of dollars in criminal and civil 

 penalty fines, hundreds of other pollution violations and citations, and numerous 

 breaches of its contract. Most importantly, the existing KPC contract guarantees a 

 timber volume of 192.5 million board feet per year. Based on our analysis, we believe 

 the Forest Service simply cannot guarantee KPC this volume, provide timber for 

 independent operators, and still meet the requirements of NFMA to maintain well- 

 distributed, viable populations of wildlife on the Tongass. And significantly, viable 

 population levels only meet the criteria that there are enough individuals for the 

 populations to continue to exist. There is no assurance that enough individuals will be 

 left for subsistence, hunting, viewing, or other uses of wildlife upon which Alaskans and 

 other Americans depend. As long as the KPC contract is in existence, timber will be 

 first priority, and wildlife, along with all other forest resources, will take a back seat. 



Defenders of Wildlife has sympathy for anyone whose livelihood would be affected by 

 the non-extension of the KPC contract. But there are thousands of employers 

 throughout the country which also depend on timber supplies, but are not given this 

 unprecedented control over a national forest, nor the subsidies which amount to millions 



