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Consistency: Not only do the BLM and the Forest Service have different npanan policies, the agencies are not 

 internally consistent. For example, internal reviews in Forest Service Region 6 reported disparate standards and 

 guidelines among forest plans for Fishery resource protechon, concludmg that none of the plans reviewed ensure the 

 continued viabihty of salmonid populations. (Heller et. al., 1991). As one investigator discovered, "planmng criteria, 

 mdicators for measuring resource values, modeling assumptions, and analytic procedures varied substantially among 

 forests, such that direct quantitative comparisons between plans are of only limited value.' (FnsselL 1992). Likewise, 

 standards and guidelines for riparian management varied considerably among forests: the Willamette (Oregon) and 

 Shasta-Trinity (California) National Forests have adopted a no-cut buffer averagmg 1(X) to 200 feet wide, and rangmg up 

 to 400 feet, on all class 1, II and III streams, whJe the Mt. Baker-Snoqualmie and Olympic National Forests 

 (Washmgton) allow extensive logging m all riparian areas, with a few restrictions to prevent total stand removal. Few 

 plans provide any protection at all for Class IV tributaries and fewer still protect riparian areas along headwater streams, 

 despite their important contributions to the downstream environment. 



An example of new authorities needed: I) Inter- Agency PoUcy Consistency and Alignment to Manage at the Watershed 



level. 



Although a number of federal statues speak to inter-agency coordination, agencies are still authorized to act based on 

 their own statutory goals and mandates and internal agency pnorities. Legislation which defmes common missions and 

 goals, and aligns agency management policies of riverine-ripanan ecosystems and biodiversity is needed to provide 

 watershed level coordmation and consistency. 



CONCLUSION: PRC beheves that new policies is needed to provide uniform watershed protection and restoration 

 directives for all federal land management agencies. These poUcies must include riparian management directives 

 directly from Congress, elevating important issues of riparian pohcy from the lowest levels of administrative authority to 

 the highest level of government. 



