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plan specifically finds that a regional approach to federal lands management is necessary to 

 address these concerns. 



All federal managers are required to prepare land management plans in accordance with the 

 National Environmental Policy Act (NEPA). Without regional assessments and planning, it is 

 unclear how federal managers will meet their duties to fully disclose the environmental impacts of 

 its actions. These steps will ensure that the indirect and cumulative effects of past, existing, and 

 proposed management on water quantity and quality, soil productivity and stability, riparian 

 vegetation and fish and riparian-dependent species in the planning area will be adequately 

 considered, analyzed and disclosed. 



Past planning approaches have permitted federal managers to adopt strategies (such as maximum 

 dispersal of logging activities) that purported to minimize adverse impacts, but which actually 

 increases overall risks to salmonid species and habitat by negatively impacting dl samon 

 populations throughout their range. (Frissell, 1991). We believe that the federal managers must 

 undertake to conduct planning based on regional analysis in order in assure meaningflil 

 compliance with NEPA and other land planning laws requiring cumulative impacts analysis. 



2. Regional planning, though costly at the front-end, is more eflicient in the long-run. 



Regional planning makes sense both biologically and fiscally. Broad-scale decisions allow the 

 agencies to deal programmatically with broad-scale problems. For example, the Interior 

 Columbia Basin Ecosystem Management Project and the Sierra Nevada project are in a position 

 to deal with the land use and allocation issues relevant to the protection and recovery of declining 

 fisheries. Moreover, regional planning saves resources by providing a framework for developing 

 projects which are more likely to meet NMFA, FLPMA, ESA and CWA from the outset. 



Although planning for projects like timber sales, mining and grazing still will have to involve 

 environmental analysis, planning and evaluations will be much more difBcultwithout benefit of a 

 regional and forest-level management framework designed to meet legal and biological 

 requirements. Without a broad-scale framework and set of management principles and land 

 allocations within which to plan, each project will have to be scrutinized much more careflilly to 

 determine if the standards developed for that project are adequate, and implementation is more 

 likely to be delayed pending this analysis. At the larger scale, the needs of species and common 

 characteristics of certain types of actions, and their impacts on species, can be assessed early and 

 consistently. 



All of this results in cost savings to the federal government. As you are aware. Forest Service 

 Chief Thomas has estimated that the costs of amending federal management plans in the basin on 

 an individual basis will be almost ten times more costly than will a single, regional amendment 

 decision based on regional ecosystem planning. 



If we continue the failed approach of the past, we are certain to cause further extinctions of 

 salmon and native fish across the West and project implementation is likely to become increasingly 

 contentious. Piecemeal analysis of environmental impacts has brought us to the point where our 



