193 



The Berners Bay wilderness that is being proposed north of 

 Juneau will cut off any opportunity for road access from Juneau 

 into Skagway or Haines and do away with that. 



These areas are being very skillfully chosen to really maximize 

 the ability to have any additional development in the area. 



The second issue for today's hearing concerns Congressionally 

 mandated buffer strips. H.R. 987 requires buffer strips on all Class 

 I, II, and III streams. The Forest Service has determined that this 

 would reduce the allowable sale quantity for the Tongass by ap- 

 proximately 21 or 22 percent. 



This is displayed in my written testimony in one of the exhibits. 



Alternatively, the Forest Service will be forced to enter roadless 

 areas at a more rapid rate to sustain the industry. It is important 

 to spend just a moment looking at what the Forest Service is re- 

 quired to do and what the National Marine Fisheries proposes, and 

 if you will refer to pages 8 and 9 of my written testimony. 



I cite the Forestry Management Act as the requirements present- 

 ly followed by the Forest Service. The aquatic habitat management 

 units handbook was developed by the Forest Service inter-discipli- 

 nary team to give resource professionals site-specific directions for 

 protection of fish habitat. Special consideration is given to the area 

 at least 100 feet on either side of the streams. 



The Forest Service implements these laws, regulations, policies, 

 site-specifically in order to best manage habitat to meet the fisher- 

 ies goals. Following on the ground investigations and analyses, 

 inter-disciplinary teams select streamside prescriptions that will 

 best protect the fish habitat at that site. 



Many site-specific factors, such as stream channel, bank condi- 

 tion, water temperatures, fish passage, and so forth, are included in 

 these considerations, along with inter-disciplinary teams that meas- 

 ure widths and make these determinations. 



The National Marine Fisheries Service policy is based on the de- 

 sirability of recruiting large wooden debris into a stream for the 

 spawning and rearing purposes. It is clear that 99 percent of the 

 large organic debris originates from the area within 100 feet of a 

 stream. This is the reason for the 100-foot buffer strip. 



However, as National Marine Fisheries Service's own research 

 points out, most of the large woody debris falls from areas much 

 closer to the streams. For example, trees fall in as streams under- 

 cut the banks and wind-blown and so forth. The National Marine 

 Fisheries research notes that 97 to 98 percent of the large woody 

 debris originates within 82 feet of the stream, and 89 percent from 

 within 50 feet of the stream, and 82 percent from within 32 feet of 

 the stream. 



Indeed, nearly 50 percent of the large woody debris came from 

 the stream bank areas less than three feet from the stream and 

 two-thirds from within 15 feet. In other words, the National 

 Marine Fisheries Service policy focuses solely on the large woody 

 debris aspect of the riparian management, to the exclusion of 

 equally important biological considerations which even the Nation- 

 al Marine Service acknowledges. 



Congressional direction in Section 6[g][I][E] of the National 

 Forest Management Act explicitly requires the Forest Service to 

 manage in consideration of additional criteria. Because the Nation- 



