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Xn. RIPARIAN PRESCRIPTIONS IN TLMP REVISION ARE NOT A 



SUBSTITUTE FOR MANDATORY 100' BUFFER STRIPS ON CLASS I, 

 CLASS 2, AND CERTAIN CLASS 3 STREAMS. 



The TLMP Revision Riparian Prescriptio ns do not provide as much protection for salmon 

 habitat as does the National Mari ne Fisheries Service (NMFS) buffer strip policy. 



The NMFS policy calls for 100 foot buffers on all class 1 and class 2 streams, but only those 

 class 3 streams that directly affect class I streams, have gradient less than 8%, and which 

 generally can be identified from aerial photographs. 



The Forest Service proposes to use two riparian prescriptions in the TLMP Revision. 

 Prescription 13 is titled "Riparian Management Requirement" and is designed to meet the 

 minimum requirements of the National Forest Management Act (NFMA). Prescription 14 is 

 titled "Stream and Lake Protection" and is intended to provide additional habitat protection not 

 granted by prescription 13. 



Each riparian prescription calls for various management practices along specific stream classes 



and specific stream channel types. Stream classes are the same as those used in the NMFS 



policy. Channel types are defined by gradient (steepness) and geography. 



Both prescriptions 13 and 14 allow clearcutting within 100 feet of class 1 streams. For 



example: 



1) Under prescription 13: 



a) clearcutting can occur as close as 60 feet from class 1 streams of channel types 

 Bl and B8 (low gradient flood plain streams); 



b) clearcutting can occur as close as 25 feet from class 1 streams of channel types 

 C2 and C5 (large low gradient streams); 



3) timber salvage sales are allowed up to the banks of class 1 streams of most 



channel types. 



2) Under prescription 14: 



a) clearcutting can occur as close as 60 feet from class 1 streams of channel types 

 Bl and B8 (low gradient floodplain streams); 



b) timber salvage sales are allowed up to the banks of class 1 streams of most 

 channel types. 



The Forest Service riparian prescriptions are co mplex and will require large numbers of 

 Professional staff to implement and monitor in the field. 



The TLMP Revision prescriptions have specific road building, logging, and other resource 

 management standards for every combination of three stream classes and over 20 channel types 

 The problem with this system is that it is too complex to be practical and enforceable on the 

 ground. 



The truth is that the Forest Service and the state of Alaska do not have enough biologists to 

 monitor timber sale implementation continuously, and that neither federal or state biologists 

 have the authority to compel compliance with the riparian prescriptions in the field. In 



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