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Rep. Furse re: Hatchery Reform and HabiUU ProUction, Mundy and Rhodes Page 6 



CRITFC's recommendations for the management of critical habitat in the Snake River 

 basin (CRITFC, 1991b) which include: 1) elimination of riparian zone impacts; 2) an aggressive 

 road obliteration program; 3) revision of all grazing allotments in the Snake basin; 4) limitations 

 the frequency, intensity, and amount of land disturbance in watersheds; and 5) the elimination of 

 grazing on degraded riparian areas until full ecological recovery has occurred. 



The South Fork of the Salmon River Step Plan placed a moratorium on all land disturbance 

 within the degraded watershed. The moratorium is to remain in effect until stream sediment 

 standards in fish habitat are met. The South Fork of the Salmon River Step Plan also developed 

 a program of sediment reduction through road obliteration. Notably, the South Foric of the 

 Salmon River Step Plan is the only one of the four approaches that has been implemented. It is 

 also the only degraded stream in the Columbia basin that has been documented to have improved 

 over the past 25 years. The EPA has now officially adopted the South Fork of the Salmon River 

 Step provision as the primary means of implementing the Clean Water Act Provisions for streams 

 that have been identified as "Water Quality Limited." 



The message that is common to all four of tiiese approaches is that protection of salmon 

 habitat and populations requires that we limit watershed disturbance Qogging, grazing, minin g and 

 road construction) and eliminate the degradation of riparian vegetation. We agree with the 

 testimony of the panel that these principles must be the cornerstones of comprehensive watershed 

 management aimed at restoring salmon populations. 



2. State and Private Lands. The states of Idaho, Oregon, and Washington have fiailed 

 to control non-point source pollution and enforce their water quality standards developed under 

 the Clean Water Act (CRITFC, 1991a). These states have also failed to develop water quality 

 standards that fully protect fish habitat. In tandem, this has allowed severe degradation of fish 

 habitat on federal and private lands. Most of the problems existing in fish habitat are attributable 

 to the failure of regulatory agencies to enforce the Clean Water Act. 



The Forest Practices Rules in Idaho, Washington, and Oregon are inadequate to fully 

 protect salmon habitat. At a minimum, these Forest Practices Rules will have to be amended to 

 require full protection of riparian vegetation, if salmon populations are to be protected and 

 restored. 



The states should begin to fully enforce existing water quality standards and immediately 

 develop Total Maximum Daily Loads for streams that have been identified as "Water Quality 

 Limited" under the Clean Water Act. The state water quality authorities should also rigorously 

 review existing data and identify all streams as "Water Quality Limited" where existing water 

 quality standards are not being met and the beneficial use of the water by anadromous fish is 

 impaired. The water quality agencies should also immediately develop and adopt water quality 

 standards that are biologically based, and that are designed to fully protect fish habitat. These 

 agencies should also develop and adopt mandatory management practices for agriculture and 

 mining. 



The states also need to analyze water right applications for their effect on fish habitat 



