205 



As the responsible agency, the Forest Service has the obligation 

 to manage riparian zones for criteria in addition to LOD, which the 

 Forest Service did in this case. 



The NMFS policy is based on the desirability of recruit- 

 ing large organic debris (LOD) into a stream for 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 NMFS ' s 

 own research points out, most of the LOD falls from areas much 

 closer to the streams; for example, trees fall in as streams under 

 cut stream banks. The NMFS research notes that 97-98 percent of 

 the LOD originates from within 82 feet (25m) of the stream, 89 

 percent from within about 50 feet (15m), and 82 percent from within 

 33 feet of the stream (Murphy, et al., 1987). Indeed, nearly 50 

 percent of the large woody debris came from stream bank areas less 

 than one meter from the stream and two-thirds from within 5 meters. 



In other words, the NMFS policy focuses solely on the LWD 

 aspect of riparian management to the exclusion of equally important 

 biological considerations, which even NMFS acknowledges. Congres- 

 sional direction in Section 6(g)(1)(E) of NFMA explicitly requires 

 the Forest Service to manage in consideration of additional 

 criteria. Because the NMFS LOD policy deals with only one aspect 

 of streamside management, it is impossible to see how fisheries are 

 in any way injured by the Forest Service adoption of the more 

 comprehensive policy for fisheries protection as described by the 



11 



