220 



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Ketchikan Pulp Company 



A wot-diary ot 



UioAaf a-P»cAc Corc<vjliOn 



Post Office Box 6600 

 Ketchikan. Alaska 99901. U.S.A. 

 Telephone- 907-225-2151 

 Telefax 907-225-8260 



March 2, 1990 



Honorable Bennett J. Johnston 

 United States Senate 

 136 Senate Hart Building 

 Washington, D. C. 20510 



Dear Senator Johnston: 



Mr. James Brooks' (NMFS) testimony at your hearing on February 

 26, 1990, states that the NMFS buffer strip policy - 30 meter 

 minimum - is "based on scientific evidence." This is not pre- 

 cisely correct. Most all biologists agree that buffer strips 

 are necessary on anadromous fish streams, but the required 

 extent of those buffer strips is not well documented or even 

 well understood. It appears that, in many cases, less than 3 

 meters will suffice and in some cases more than 30 meters will 

 be necessary. Further, there are many cases where a prohibi- 

 tive buffer strip policy can cause more problems than it will 

 resolve. For example: 



1. Blowdown, exacerbated by leaving windthrow prone 

 trees, can greatly increase erosion of streambanks on 

 certain channel types. This blowdown can also cause 

 fish blockages or even debris dams that could cause a 

 catastrophic washout (see attached Koski paper from 

 1986 Canadian Journal of Fisheries and Aquatic 

 Sciences ) . 



2. Disallowing yarding across portions of certain minor 

 fish streams will necessitate additional road con- 

 struction. The impacts from these roads might exceed 

 the impacts from fully suspending logs across selected 

 portions of minor streams. 



3. Not all class l streams are the same size. Can you 

 imagine a 3 foot wide fish stream with a 6 foot 

 diameter tree falling full length in it? 



TL:280 



Trees are a Renewable Resource 



