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lands) and INFISH (protecting riparian habitat in watersheds on USPS lands bearing native fish, 

 with particular emphasis on bull trout). 



Planning at the regional level is necessary to ensure that imperiled aquatic species, water supplies 

 and aquatic ecosystems generally are protected adequately . Ideally, site-specific activities known 

 to adversely affect listed species would be precluded or conditioned on regional and Forest Plans. 

 The National Marine Fisheries Service (NMFS) has stated its behef that existing forest plans do 

 not reflect current science because a comprehensive, landscape level conservation strategy is 

 lacking. (NMFS Biological Opinion on Eight Land and Resource Management Plans, March 1, 

 1995, at 45). Even as amended by PACFISH, current plans fail to "provide for a network of well- 

 distributed watersheds containing high quality spawning and rearing and readily restorable habitats 

 and reduce risks to these habitats;" "prioritize restoration;" "plan activities and conservation 

 strategies after landscape-scale analysis," and, "conduct implementation monitoring and begin 

 gathering data for effectiveness and validation monitoring." These issues must be fully addressed 

 by regional guidance in order to ensure that ESA and other requirements are met. The ICBEMP 

 process examines these issues with the spatial perspective needed to correct these identified 

 deficiencies. 



The biological fact is that the needs of many imperiled species, like salmon, are affected by the 

 combined impacts of activities which take place across a wide geographic range. Thus, habitat 

 protection strategies must be implemented at a broader scale; 



"For example, potential broad-scale adverse effects include the effects of road 

 construction and timber harvest in roadless areas and other areas of remaining 

 high-quality habitat on the availability and quality of habitat refugia for 

 remaining subpopulations of listed salmon. The adequacy of remaining 

 refugia cannot be determined by examining one action or even one 

 watershed at a time. (NMFS Biological Opinion on PACFISH, at 26) 

 (emphasis added). 



We have come to "ecosystem management" (sadly, through trial and lots of error) as the only 

 rational way to manage for sustained yield of multiple uses. The fundamental principle of 

 ecosystem management tells us that we must manage within the biophysical constraints of the 

 land, water and air to support life and function together as ecosystems. But this model of 

 management meets with opposition from those whose primary concern is the quantification of 

 "outputs," as per the "ASQ," "AUM," "RVD" and other such measurements. Under an ecosystem 

 model we use information developed through watershed and ecosystem analysis on the premise 

 that good information about ecosystem capabilities should guide our "output" expectations. 



Moreover, regional planning is the only way to address the decline of wide-ranging species such 

 as salmon and bull trout. These fish are of substantial economic value and priceless spiritual value 

 to the northwest. With regard to the listed Snake River salmon, the National Marine Fisheries 

 Service has found that unless the degradation of tributary habitats where salmon rear and spawn is 

 halted and reversed, salmon populations will not recover to self-sustaining levels. The recovery 



