Comments on the TLMP Amendment Due February 22nd

Download this TLMP Action Alert  (PDF)

Public comments on the Forest Service’s Amendment to the Tongass Land Management Plan (TLMP) are due by Monday Feb. 22. We hope you will pitch-in by taking a bit of time to send your opinions to the agency, since this is a really big deal. TLMP rarely gets changed, this change will set the pace and nature of logging for perhaps several decades, and all the alternatives being considered are very poor.

GSACC urges you put the views below into your own words, and make a submission. Form letters, etc., are counted and considered only as one comment all together, so originality is important.

What you are commenting on is a draft environmental impact statement (DEIS) which includes five alternatives (all quite similar) and a draft Forest Plan. The five alternatives would commit to 370 to 1,100 million board feet (mmbf) of old-growth logging over the next four decades, then to continue at a rate of 50 mmbf per decade thereafter. All together that is a huge additional loss of the already greatly diminished non-renewableold-growth forest resource.

To be effective, it is important to aim you comments at the stated “purpose and need” for the plan amendment, and for an alternative that should have been considered, but wasn’t. Main points to consider making are:

  1. End Old-Growth Logging, Now!

Last year, at meetings of the Forest Service’s appointed Tongass Advisory Committee (TAC), citizens asked over and over that Plan amendment end old-growth logging on the Tongass immediately. The committee refused to recommend such an alternative, nor did the Forest Service include one in the DEIS. But old-growth forest is a finite resource, it has been overexploited on the Tongass for many decades, and logging it needs to be regarded as strip-mining, and ended immediately.

Part of the Purpose and Need for the Plan amendment is to determine which lands will be classified as “suitable” for timber production. All old-growth forestland should be declared “unsuitable,” and this needs to be included in an alternative that is considered in detail and that is then selected for final plan. Also, say that the “projected timber sale quantity” for old-growth should be zero.

  1. End Even Age Timber Management, Now!

Clearcutting mature second growth condemns the most biologically valuable watersheds of the Alexander Archipelago to the status of colonial tree (fiber) plantations, for export purposes. What was cut first on the Tongass were the high-productivity, low elevation forest stands – and the existing alternatives in the EIS for this so-called “Tongass transition” would log them as soon as they are marginally mature. That includes even the second growth in designated habitat reserves, riparian management areas, beach buffers and scenic viewsheds. These older second-growth stands are well on their way toward evolving back to an old-growth state, a process that for the most part needs to continue to the end instead of being cut short.

All the second growth that would be mature enough over the next 20-30 years would be vacuumed up, in attempting to support the existing industry. Instead, it would be reasonable for just some of the smaller mills to be sustained from a small portion of the second growth that is within the current timber-base. Beyond those 20-30 years, which is a time when ample second growth will reach maturity, a reconstituted industry may be reasonable, if the generations living at that time desire it.

  1. The Transition Needs to be About the Communities, Not the Timber Industry.

The alternatives in the DEIS are narrow-minded, with none looking at how to transition the half-dozen communities that have some reliance on logging into prospering on other economic endeavors. These endeavors can include outdoor work (e.g., recreation & tourism, forest road maintenance & decommissioning) or Internet-enabled work, etc. Only about 100 full-time equivalent timber industry jobs are involved – a doable transition for the federal government to lead, for a future that is truly sustainable. The timber economy as promoted in the DEIS is unsustainable, even over the short-term.

  1. The TLMP Planning Process Has Been Illegitimate — Get It on Track!

In May 2010, the Forest Service’s Alaska Regional Forester announced that a rapid transition would be made to end old-growth logging on the Tongass. Six years later we instead have: (1) the recently decided Big Thorne timber sale, by far the largest on the Tongass in over 20 years; (2) more large timber sales in the queue; and (3) a Proposed Alternative in the TLMP Amendment DEIS that would log 600 million board feet of old-growth over the next 40 years, and 900 million board feet within the 100-year planning horizon.

This is not just! In 2013 USDA Secretary Vilsack directed the preparation of the EIS and the TLMP Amendment. At his direction the effort is narrowly focused on timber production, not the kind of open-minded transition our region really needs. To further his marching orders, the Forest Service hand-picked a formally designated, federally-ensconced Tongass Advisory Committee (TAC). Plainly, the TAC members were unrepresentative of Southeast’s society and economy, it was set up to give the Forest Service a patina of “social license” for the plan it wanted all along. The TAC’s recommendation is now the Proposed Alternative for the TLMP Amendment. Instead, many citizens testified to the TAC that an immediate end to old-growth logging is what is sorely needed.

The Final EIS needs to include a new alternative that will accomplish that, and it needs to be adopted. We need a wholly new approach to management of the Tongass for the 21st Century, not a throwback to the past century.

The deadline is: received by midnight, on Monday February 22


Forest Supervisor, Tongass National Forest,

Attn: Forest Plan Amendment

648 Mission Street

Ketchikan, AK 99901.