View RDC's Comment Letter

Deadline for comment is April 30, 2007

Overview:

A 2005 Ninth Circuit Court ruling and the Five-Year Plan Review (completed in January 2005) indicated the need to amend the current Tongass Land and Resource Management Plan. The proposed forest plan addresses deficiencies identified by the Court and opportunities presented in the recent five-year review.

Seven alternatives have been provided in the Plan by the Forest Service, with no preferred alternative identified.  RDC supports Alternative 7, with modifications, to help rebuild the forestry industry in Southeast Alaska. Modification to Alternative 7 is necessary to ensure that the plan can be implemented as presented.

The Plan not only applies to timber harvesting, but other multiple uses, including mining. Within the Tongass, there are 52 areas totaling 589,000 acres that contain identified mineral resources. Currently, 25% of this acreage is closed to mineral development.  Under the current plan, 29% of the remaining areas are in land use designations that result in higher cost of entry to develop.  Alternative 7 would decrease this to 22%.

Action Requested: 

1. Provide oral comments in support of Alternative 7, with modifications, at a public hearing:

Friday, March 30, 7-9 pm
Loussac Library Assembly Chambers

2. Submit written comments supporting Alternative 7, with modification, by April 30, 2007 to:

Email: r10_tongass_juneau_rd_plan_adjustments@fs.fed.us

Internet: http://www.fs.fed.us/r10/tongass/

Points to consider for your comments:

• I support Alternative 7 in order to revitalize the Southeast Alaska economy and help rebuild a fully-integrated and sustainable industry in the region. This will provide new jobs and business opportunities that will strengthen the economy of local communities.
• I support full implementation of Alternative 7. A reliable supply of economic timber of at least 360 million board feet is imperative in order to achieve full integration and to competitively meet market demand.
• Given the Tongass has a biological potential of providing an annual timber harvest of 1.3 billion board feet, with over 600 million board feet set aside in congressionally-designated Wilderness and roadless areas, the annual 421 million board foot timber base identified in Alternative 7 for harvesting is a reasonable volume for the Forest Service to offer in its final plan.
• I support Alternative 7 to improve the economics of new mineral exploration and development in the forest. This will help diversify the economy and provide opportunities when lawsuits prevail over timber sales.
• Based on updated science and a decade of field experience, four conservation strategies imposed by the 1997 TLMP should be removed: 1) the marten and goshawk standards, 2) the 100-foot buffers on each side of all Class III, non-fish streams, 3) the large medium and small Habitat Conservation Areas (also called “old-growth reserves”)  4) the 1,000-foot beach and estuary buffers. The negative economics of these four conservation requirements are the primary reason the Forest Service has been unable to implement economic timber sales since 1997 and why it has fallen so utterly short of its annual volume target.
• The State of Alaska’s stream buffer requirements and best management practices for road building and timber harvesting are sufficient to protect fish habitat. The Forest Service requirements under Alternative 7 are unnecessarily more protective than Alaska’s Forest Practices Act.
• The proposed addition of a Legacy Forest Structure guideline in the amendment calling for the retention of old growth stand characteristics within all harvest units should be excluded. This requirement will further hamper the economics of timber sales, create severe safety hazards during harvest and would leave trees subject to future wind damage. The need for this additional guideline, which increases the costs of sale planning and layout, is not founded in science.
• Even with the removal of the four 1997 conservation strategies, Alternative 7 would still leave approximately 80 percent of the old-growth timber undisturbed in perpetuity. Moreover, Alternative 7 would leave 75 percent of the Tongass undeveloped, preserving a vast majority of the forest to protect wildlife species and scenic values. Alternative 7 is the only alternative that truly strikes a balance among multiple uses.

Deadline for comment is April 30, 2007