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timber will be necessary above and beyond what the Forest Service 

 is now doing, which is some improvement. 



One example is the long-term timber sale for KPS. We are talk- 

 ing a net adjustment of 215 acres out of a total harvest of 812,000 

 acres for 100-foot buffers on Class I and II streams. Class III 

 streams would add a few hundred acres more. 



This is well within the realm of multiple use and economic prac- 

 ticality. It is for these reasons that UFA views the buffer strip pro- 

 vision as a pro-logging, a pro-multiple use management tool. 



So the question then becomes why a prescriptive tool, as opposed 

 to a site-specific approach? I think the answer lies again in the 

 Forest Service's practices. The AHMU handbook is a nice, three- 

 inch document, which I have tried to get through and was lost by 

 it, like many others. 



But I think the best example is a quote that I would like to take 

 out of the EIS once again, and that is, as of 1988, one-third of the 

 existing aquatic habitat management units — they call them 

 AHMU's — have been harvested. Past harvest in the AHMU has 

 been concentrated on sensitive anadromous channels, with two- 

 thirds of the past harvest taking place on Class I streams. 



This statement makes apparent two flaws in the AHMU flexibil- 

 ity system: one, fisheries biologists do not make the decisions on ri- 

 parian management. They have no enforceable field presence. 



Two, there is a variable commitment to adequate non-timber 

 staffing over the life of the timber sales. 



Under the AHMU flexibility system, commonly logging interests 

 win over fisheries interests when push comes to shove for those 

 valuable money trees. We need money trees, too, for our money 

 fish. We think there is more money trees left for them as well. 



The Forest Service is quick to point out that the riparian man- 

 agement practices have changed. Well, we might see some spot im- 

 provements in some areas, but there is no consistency. As part of 

 my written testimony, I provided you with a report prepared by 

 Alaska Department of Fish and Game which shows that the Forest 

 Service has actually gone in and logged buffer strips that were 

 once reserved. 



That also is supplemented by an additional report which shows 

 that they are still currently logging up to the stream banks on 

 some important anadromous streams. There just is no consistency. 



So it is our opinion that the site-specific approach is not working, 

 and there are substantial advantages to a minimum 100-foot buffer 

 strip along Class I, II, and important Class III streams, first of all 

 including the protection that is needed, as Dr. K. Koski pointed 

 out. 



The second one is it is a more effective, efficient, and enforceable 

 policy for all to follow. Even the timber operator will gain by know- 

 ing ahead of time what is expected of him in logging next to 

 streamside areas. 



Despite the request of NMFS and United Fishermen of Alaska 

 and all the political and legal attention the buffer strip issue has 

 received, future Forest Service practices are likely to remain the 

 same as they are today. 



A case in point is the ongoing revision of TLMP. Right now the 

 Forest Service is generating management alternatives. The NMFS 



