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volume stands as only good producers of wood-fiber reveals an apparent bias in Forest 

 Service management philosophy; to justify logging them on that basis is to ignore their 

 significant ecological values. 



Mr. Sheridan's assertion that silvicultural practices used on the Tongass are actually 

 increasing rather than decreasing high-volume stands warrants comment. While second 

 generation regrowth stands may produce more wood fiber/acre than the old growth before 

 them, that argument presupposes that the entire concern is over wood-volume per se. 

 Rather, the composition, structure, and function of high-volume old-growth stands make 

 them important as wildlife habitat. Second-growth stands, regardless of wood volume, 

 have extremely low wildlife habitat value. Once old growth is clearcut (put into 

 rotation), those important ecological values are, for all practical purposes, permanently 

 lost. 



High-volume old growth is exceedingly rare on the Tongass Forest. By conservative 

 estimates, over half of the highest volume stands on the Tongass (those with over 50,000 

 board feet per acre) were logged between 1950 and 1978 prior to development of the 

 Tongass Land Management Plan (TLMP). By 1979, according to TLMP, there were less 

 than 100.000 acres of this type remaining forestwide (about 0.5 % of the total landbase). 

 While a moratorium on further cutting of these rare stands might ecologically seem in 

 order, TLMP instead scheduled half of the remaining acres in this volume class for 

 clearcutting in the next 40 years. Whether this management direction constitutes high- 

 grading or not, the situation clearly warrants our mutual concern. 



A comparison of actual harvest levels against what TLMP scheduled does not allay our 

 concerns about high-grading. It is the harvest schedule itself, not a failure to abide by it, 

 that is responsible for the rapid depletion of the remaining highest-volume stands. 

 Furthermore, comparisons with the TLMP schedule, and the 1978 land/timbtr type 

 database leave unaddressed the significant loss of these high-value stands prior to TLMP. 

 Notwithstanding the high levels of past, present and future harvest in high-volume stands, 

 departures from TLMP scheduling in favor of even more high-volume harvest (to Improve 

 sale economics) have been routinely considered and approved. TLMP targets were not 

 exceeded during those years primarily because of low market demand. 



Mr. Sheridan acknowledges that high-volume old-growth stands are being 

 disproportionately harvested from the forest. Although the reasons given are all valid 

 (better regrowth rates, easier access, and improved economics), equally valid reasons argue 

 against cutting these stands. Mr Sheridan, if he does indeed recognize those reasons, does 

 not mention them. At best, his letter reveals a narrow view of the forest's values to the 

 public, and the Agency's management responsibilities. 



Thank you for reviewing my concerns on this important wildlife habitat issue. 

 Sincerely, 



BaGuL 



Dave Anderson 



Regional Supervisor, Game Division 



cc: Lew Pamplin 

 Rick Reed 

 Craig Lindh 



