Tongass Land Management Plan Revision
Its effect on the forest products industry in Alaska

Prepared by

Alaska Forest Association, Inc.
Jack E. Phelps, Executive Director August 3, 1997

I. Summary

The Tongass Land Management Plan ( TLMP ) outlines land and resource management planning over the next decade for the nation’s largest national forest. The latest revision of the plan was issued in May, 1997, replacing the original 1979 TLMP , as amended in the mid- eighties. The revision took 10 years to complete, and cost the taxpayers nearly $13 million.

The Tongass Timber Reform Act of 1990 ( TTRA ) left 63 percent of the Tongass permanently closed to logging, including 58 percent of the forest’s old-growth acreage. Since 1954, only 9 percent of the Tongass old-growth has been harvested. In exchange for the extensive set- asides, the 1990 compromise guaranteed industry a 1.7 million acre timber base, as well as an allowable annual harvest ceiling of 520 million board feet ( mmbf ) including utility logs, on a 100-year sustainable rotation cycle.

The new plan, however, shrinks the available land base to 676,000 acres, and slashes the annual allowable harvest to about half the previous level. Many Southeast Alaskans believe this will have disastrous consequences for the region’s economy. Industry officials warn the lower harvest level will be insufficient to sustain an integrated timber industry, and will result in further mill closures and job losses. The plan will make it difficult to open new facilities in Wrangell , Sitka and Ketchikan.

There is also serious concern about the ability of the Forest Service to offer sufficient timber under the plan to make available the projected 220 mmbf in annual offerings. The placement of Habitat Conservation Areas and the application of the Anadromous Fish Habitat Assessment ( AFHA ) standards will inhibit the design of economic timber harvest units. The AFHA standards were deemed not necessary by the Forest Service field staff, and were not included in the 1993 draft plan revision. Their appearance in the 1997 plan revision appears to be politically, not scientifically motivated.

II. The numbers

  1. Commercial land base available for timber harvest 676,000 acres

  2. Proposed Allowable Sales Quantity (ASQ) 267 mmbf , 220 mmbf economic

    >>>   Under the Supervisor’s Preferred Alternative (Summer, 1996):

    Timber harvest land base = 1.2 million acres
    ASQ = 357 mmbf, 297 mmbf economic

  3. The new ASQ calculations are "sawlog plus utility;" whereas in the past, ASQ calculations were in "net sawlog." This accounts for a falldown of about 18%. In other words, the ASQ under the new revision is really 220 mmbf total, and 180 mmbf economic. Also it should be noted that, under the law, this is maximum allowable harvest per year over a ten year average, not annual deliverable volume.

  4. Projected annual offerings 180 mmbf , sawlog plus utility; or 148 mmbf , net sawlog . Compare this to the 10 year average from 1984 1993: 346 mmbf . Furthermore, an internal Forest Service document obtained by AFA shows that the Forest Service does not expect to actually be able to offer all of the volume in their 5-year schedule, due to appeals and litigation. In fact, the volumes they actually expect to make available for each of the next 5 years are, 81 mmbf in FY98 ; 140 mmbf in FY99 ; 121 mmbf in FY00 ; 136 mmbf in FY01 ; and 139 mmbf in FY02 .

  5. With only 676,000 acres in the land base and the various other harvest restrictions built into the plan (especially the standard and guides), it is going to be very difficult for the Forest Service to produce the volume the plan calls for. In other words, we believe even the reduced ASQ is unrealistic, given other aspects of the plan.

III. Needs of the industry

  1. Existing sawmills need more than 200 million board feet of sawlogs to operate at capacity, as shown in the attached chart. This means a harvest in the 350-400 mmbf range. The gap could be tightened a little depending on the ability of some of the mills to cut #3 sawlogs and to make some lumber, and possibly veneer, from pulpwood, but these would be marginal cuts and could have a negative effect on the operations’ bottom lines.

  2. Due to market and other economic concerns, the industry considers chip exports an unsatisfactory long-term component of a sustained timber industry in Southeast Alaska. The region needs a facility to utilize low grade wood and residual chips. The minimum pulpwood harvest needed to sustain such an operation (e.g., a medium density fiberboard plant) is estimated to be 87 mmbf. To operate at capacity, the plant would also have to receive a portion of the residual wood chips from sawmills. The attached chart shows that more than enough would be available if the existing sawmills were operating at capacity.

  3. Aside from the known capacity of existing mills, the industry’s best effort to estimate potential employment from harvest and milling activity in Southeast Alaska was set forth in the recent paper, "Four Visions of the Timber Industry on the Tongass National Forest." This paper showed that if harvest from the national forest were consistently at 300 mmbf, economies of scale would come into play that would truly sustain a viable, integrated timber industry. At 200 mmbf, those economies evaporate, and it is likely that only one or two mills and a handful of "mom and pop operations would remain viable over the long term. The conclusions of this paper were adopted by the Governor’s Southeast Regional Timber Task Force late last year, but there is no evidence it had any influence on the TLMP decision document.

IV. Other issues

  1. Implementation of the Anadromous Fish Habitat Assessment (AFHA) standards, using expanded stream buffers, small Habitat Conservation Areas (HCAs) to connect all large and medium HCAs, implementation of the various components of "Natural Setting" Land Use Designations (LUDs), and other harvest restrictions in the proposed plan will cause a significant reduction in the availability of second growth for future harvest. This is particularly disturbing because the justification for implementing these new "protections" is scientifically weak. For example, the AFHA standards have been found to be unnecessary by the Forest Service in the past, and the top federal expert on these matters, Dr. Michael Murphy of NMFS ’s Auke Bay lab, has shown that the existing buffer system is more than adequate to protect anadromous fish habitat.

  2. Requiring the retention of half the productive old growth in the timber harvest LUDs has not been shown to be necessary to protect animal species, and is simply another impairment to the Forest Service’s ability to meet the market demand for timber as mandated in the Tongass Timber Reform Act. There are sufficient set asides in the forested areas of the Tongass already to meet the needs of wildlife; no genuine viability studies have demonstrated the need for this additional restriction.

  3. The science represented in the recently released wildlife assessments is dated and inadequate to justify the proposed radical changes in the plan. It also appears that the data used were selected to achieve a predetermined result. For example, the goshawk assessment does not adequately consider the paucity of information on these birds, nor does it seem to consider the implications of telemetered data from goshawks living in the urban interface zone of east Douglas Island (near Juneau). Those data would tend to undermine the conclusion that goshawks need old growth habitat for survival. Mature conifers (80 year old second growth) are probably adequate. Interestingly, this was the tentative conclusion reached by an ADF&G study in the early 1990s .

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Last Updated: 29 Aug 97
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