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prescriptions are not always practical (see attached 

 December 13, 1989 letter from John A. Knauss, Under 

 Secretary, U.S. Department of Commerce, to F. Dale 

 Robertson, Chief of the USFS) . However, as we stated 

 before, protection and management may still be custom- 

 designed in each case because NMFS believes that the 100 

 foot buffer strip is only a minimum. 



13. If so, then why do we need prescribed buffer strips? Can't 

 we achieve the same result through the Forest Service policy 

 with which you just said you agreed? 



If not, I have a December 13, 1989 letter from John A. 

 Knauss, Under Secretary of the Department of Commerce to 

 Dale Robertson, Chief of the Forest Service. It appears to 

 say that NMFS agrees that site-specific management is best, 

 but doesn't trust the Forest Service to implement it: 



"Your letter states that the Forest Service 'requires 

 a no harvest buffer zone along streams when needed to 

 maintain or enhance fish habitat and maintain water 

 quality; the width of the buffer to be dependent on the 

 on-site conditions. The NMFS agrees that site-specific 

 evaluations are theoretically the best way to manage 

 streamside zones. In reality, however, the Forest 

 Service policy has failed because it is too complex 

 and relies on too many people variously interpreting 

 Forest Service guidance to protect riparian 

 vegetation." 



Dr. Brooks, doesn't this letter agree that site specific 

 management is best? 



While site-specific management may theoretically be best, we 



believe that the USFS has not been able to satisfactorily 



apply site-specific prescriptions to protect fish habitat. 



We believe that a required minimum 100-foot zone would 



ensure this protection. Site-specific management is still 



required to determine if wider zones are needed to protect 



fish habitat, to determine whether a stream is a Class I, 



6 



