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DEPARTMENT OF FISH A>D GAME 



SOUTHEAST REGIONAL OFFICE 



Mr. Phil Jaoik 



Director, Wildli fe and Fisheries 



USDA Forest Service - RIO 



P.O. Box 21628 



Juneau, AK. 99802 



STEVe COWPER, GOVERN* 



PO BOX 20 



DOUGLAS. ALASKA 99824-0020 



PHONE (907) 



4 April 1988 



Dear Phil: 



A letter of 3 March from Walt Sheridan of the U.S. Forest Service to Richard Agnew, 

 Minority Counsel in the U.S. House of Representatives, has recently been called to my 

 attention. In that letter, Mr. Sheridan dismisses allegations of 'high-grading" on the 

 Tongass as having no basis in fact. While it is neither my responsibility nor my intent to 

 take issue with Mr. Sheridan's conclusions about forest management economics and 

 silviculture, I am deeply concerned about what appears to be a lack of recognition of the 

 value of high-volume old-growth forest for purposes other than wood fiber production. 

 Because I believe you will share my concern, I have chosen to comment to you for the 

 record. 



Mr. Sheridan is certainly correct that allegations of "high-grading" have been made in the 

 sense of a disproportionate harvest of high-volume old growth. In fact, it is the Alaska 

 Department of Fish and Game's official position that such high-grading" has occurred, 

 and does carry serious ecological consequences for wildlife. Because Mr. Sheridan's 

 discussion appears to be an attempt to resolve this issue in the minds of decision-makers, 

 it seems important that we again state the basis for our concern. 



Forest Service records clearly show that high-volume (> 30,000 bf/acre) old-growth stands 

 have, and continue to be, cut at a greatly disproportionate rate relative to occurrence. 

 The Forest Service acknowledges this is happening, but apparently objects to labeling it 

 "high-grading". In his letter, Mr. Sheridan volunteers an alternate (and more correct in 

 timber management circles) definition of high-grading (selective harvest of the better 

 quality trees from a stand), and then proceeds to explain why, for silvicultural reasons, 

 the agency does not endorse this type of timber management. As the Forest Service must 

 certainly recognize, the selective harvest of individual trees from a stand is not at issue 

 here. While such an approach may be relatively compatible with wildlife and fisheries 

 values, we recognize it is not the most efficient way to grow new trees, nor would it be 

 able to provide the volume of wood needed by the two pulp mills. Regardless of what it's 

 called, the real issue is the disproportionate rate at which high-volume old growth stands 

 have been (and continue to be) clcarcut. 



Mr. Sheridan correctly points out that the highest-volume stands grow on the best sites 

 which are usually located at low elevations, along the base of hills, and in riparian 

 corridors. Because trees grow best in these areas, it may make sense from a silvicultural 

 perspective to cut them and get them into production early in the rotation. However, as 

 you know, the Forest Service has obligations beyond producing wood fiber, such as 

 maintaining ecological diversity, providing habitat for fish and wildlife, and providing 

 subsistence and recreation opportunities on the forest. Those same high-volume old- 

 growth stands, by virtue of their location and their characteristics, constitute some of the 

 most valuable fish and wildlife habitat on the Tongass. To view the remaining high- 



