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SEC. 705 (A') AND THE CONTRACTS HAVE RESULTED IN SUBSISTENCE NEEDS BEING 

 IGNORED . Under ANILCA Title VIII, the U.S. Congress expressly mandated that 

 the Forest Seirvice provide an analysis and protection of subsistence uses on 

 the Tongass. However, what Title VIII gives. Sec. 705(a) and the two 50 -year 

 contracts take away. This is compounded by the fact that the Forest Service 

 usually chooses to ignore subsistence needs. In almost every study the agency 

 has concluded that there are no impacts on subsistence, and that there never 

 have been. Subsistence users take serious exception to this analysis and 

 conclusion. The 1986-90 EIS for APC s timber operating plan is an excellent 

 example of the total disregard and total lack of understanding demonstrated by 

 the Forest Service toward rural residents of the Tongass. Only after 

 subsistence users successfully sued the Forest Service over the affects of 

 logging and road building in the Hoonah area did the agency begin to hold 

 subsistence hearings in affected communities as required by Title VIII. 

 Further south on Prince of Wales Island, the KFC 1989-94 EIS is only slightly 

 better -- solely because subsistence users have forced the Forest Service to 

 try to address their concerns. 



THE 50 -YEAR CONTRACTS SHOULD BE TERMINATED AND REPLACED WITH 

 SHORT-TERM TIMBER SALES. In order to remove the root of Tongass management 

 problems, the two 50-year contracts must be terminated and replaced with a 

 system of short-term sales and competitive bidding. A full two-thirds of 

 Tongass timber is sold under these contracts, allowing the pulp mills to pick 

 and choose the best timber from the forest without even having to bid against 

 competitors . 



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