305 



Question 3 The Forest Service says they are not "high- 

 grading" the Tongass. Are high volume stands 

 on the Tongass being cut at a rate 

 disproportionate to occurrence? 



High-grading as used here refers to the 

 disproportionate (to occurrence) harvest of 

 the highest-volume stands on the Tongass. 

 Data I presented in my oral and written 

 testimony focused on this very problem. I am 

 attaching a letter I wrote over 1 year ago to 

 the Regional Director of Fish and Wildlife 

 for the Forest Service on the high-grading 

 issue. I believe it addresses the relevant 

 points. 



Since that letter was written the Forest 

 Service's Environmental Impact Statement for 

 the 1989-94 LPK 5-year timber plan was issued 

 with an analysis of how deer habitat 

 capability changed from 1954 to the present. 

 That analysis assumed that all the acres 

 logged during that time period came from the 

 2 highest volume classes (30 MBF/acre) and 

 above) — an assumption entirely consistent 

 with the high-grading charge. Furthermore, 

 analysis of harvest volume/acre for the time 

 period 1980-86 shows a mean harvest of 54 

 MBF/acre — higher than for any comparable 

 period in the past. This analysis has been 

 reviewed by the Forest Service. 



I should point out that high-grading concerns 

 are most acute with regard to volume class 7 

 stands (50+ MBF/acre) . These represent the 

 highest-volume stands, and the rarest stands 

 on the Tongass (89.3 thousand acres, 

 according to more recent Forest Service 

 estimates) . Sadly, the future disposition of 

 these stands will not be tracked after 1990. 

 The Forest Service intends to lump what's 

 left of these high-volume stands together 

 with the next lower volume class for the TLMP 

 revision. 



