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aquatic conservation strategies presently being considered by the 

 Interior Columbia Basin Ecosystem Management Project that are 

 the subject of my testimony today. 



The project's aquatic conservation strategy goal is to maintain 

 and restore ecological function of aquatic and riparian areas and to 

 replace the interim direction for management of anadromous and 

 resident fish, referred to as PACFISH and INFISH. But the Forest 

 Service and BLM are struggling with both of these goals, and may 

 fail to achieve either of them through the ICBEMP. 



The PACFISH approach needs replacement. It has been criticized 

 as a one-size-fits-all measure that is not compatible with sound 

 management of ecosystems. In at least three of the six alternatives 

 considered by the project, PACFISH is replaced with a new set of 

 interim strategies that are, in reality, just PACFISH. 



I believe that most Forest Service and BLM managers are trying 

 to progress beyond the PACFISH strategies. However, they are 

 finding it difficult because of the influence of the regulatory agen- 

 cies, the National Marine Fisheries Service, the National Wildlife 

 Service, and even to some degree, the EPA. 



The Land Management agencies — the Forest Service and BLM — 

 have the responsibility of ensuring that their actions and inactions 

 are ecologically and economically responsible, and they have the 

 land management expertise that can allow them to be successful. 

 But the regulatory agencies don't share these same responsibilities 

 and don't have land management expertise. The regulatory agen- 

 cies are wedded to the notion that wide buffer strips along streams 

 where management is seldom allowed is the best strategy for 

 aquatic and riparian water preservation. They are wrong because 

 they have ignored the natural ecosystem process of wildfire so 

 prevalent within eastside forests. 



Eastside ecosystems are naturally dynamic systems; they are not 

 static. Things change. And one of the principal elements of change 

 is wildfire. Eastside forests have become unnaturally dense and 

 often insect and disease infested, as we heard today, with the re- 

 sult that they are now subject to unnaturally widespread and in- 

 tense wildfire. Riparian areas often burn and the results are often 

 catastrophic. Entire watersheds have been devastated by unnatural 

 fires, and it isn't over yet. 



My independent analysis demonstrates that at least 20 percent 

 of the forest area in the Basin falls within the riparian areas in not 

 less than five of the six action alternatives considered by the 

 ICBEMP. 



Furthermore, effective management of the forest health problem 

 within the riparian areas will not occur in at least some of these 

 strategies, and perhaps in all of them. In my opinion, if the project 

 management standards do not allow wildfire hazards to be effec- 

 tively treated within entire watersheds, including riparian areas, 

 they will all too often burn. 



The project must analyze how alternative management strategies 

 will affect Basin ecosystems and resources. However, there has 

 been inadequate verification of how resources are affected at the 

 local level. For example, based on analysis of broadscale maps 

 where only a fraction of all streams are shown, the project reported 



